apple cider vinegar
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π Apple Cider Vinegar (ACV)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Really Understand "Apple Cider Vinegar"?
Apple Cider Vinegar (ACV) is a liquid condiment produced by fermenting apple juice into alcohol and then into acetic acid. In international trade, it is primarily classified based on its state (liquid vs. powder/concentrate) and processing level.
Core Distinction:
- Liquid ACV: The most common form, containing water, acetic acid, and trace components. Usually classified under Chapter 22 (Beverages/Spirits/Vinegar).
- Powdered/Granulated ACV: Often a mixture of ACV powder with carrier agents (like maltodextrin) or other ingredients. May fall under Chapter 21 (Miscellaneous Food Preparations) or Chapter 11 (Flour/Starch), depending on composition.
- Concentrates/Dried: Classified under Chapter 20 (Preparations of Vegetables/Fruits) if derived directly, or Chapter 21 if blended.
β οΈ Key Identification Point:
- If it is a liquid intended for culinary or beverage use β Chapter 22
- If it is a solid/powder for dietary supplement use β Chapter 21 or Chapter 29 (if pure chemical)
- If it is organic/certified, declaration must match customs requirements (may affect duty rates in certain countries).
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | State |
|---|---|---|---|
2209.00.10.00 |
Apple Cider Vinegar, undiluted, liquid | Raw vinegar for industrial or culinary use | Liquid |
2209.00.90.00 |
Other vinegar and substitutes for vinegar | Blended vinegars, flavored vinegars, non-apple vinegars | Liquid |
2106.90.98.00 |
Food preparations, n.e.c. (e.g., ACV supplements) | Dietary supplements, ACV powder mixed with carriers | Solid/Powder |
1106.20.00.00 |
Sifted flour, meal and powder of dried leguminous vegetables | Note: Sometimes misclassified if ACV powder is mislabeled | Solid |
2915.22.00.00 |
Acetic acid, glacial or solutions of >10% acetic acid | Pure chemical acetic acid (not food-grade ACV) | Liquid (Chemical) |
2009.89.00.00 |
Fruit juices, not fermented, other | Apple juice (pre-fermentation) | Liquid |
π Critical Reminder:
- Liquid ACV must be classified under 2209; do not misdeclare as "food preparation" (2106) unless it is a blended supplement.
- ACV Powder is often a blend; if >50% carrier (e.g., maltodextrin), it falls under 2106.90.98.00.
- Pure Acetic Acid (industrial grade) is 2915.22.00.00, which has different tariffs and safety regulations.
- Misclassification Risk: Declaring ACV powder as "vinegar" (2209) will lead to rejection or penalty.
π° III. 2026 Latest Tariff Rate Details (Including Surtaxes & Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: From November 10, 2025 (including subsequent imports)
π― 1. 2209.00.10.00 β Apple Cider Vinegar (Liquid)
| Item | Content |
|---|---|
| Base Rate | 2.5% (ad valorem) |
| USITC Surtax | +7.5% (under USITC Footnote 9903.88.01 for certain agricultural products) |
| IEEPA Surtax | +10% (for products originating from China/HK, from Nov 10, 2025) |
| Total Tariff | 20% |
| Calculation | CIF Value Γ 20% |
| De Minimis Exemption | β Not Available (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:2209.00.10.00 β FOOTNOTE:9903.88.01 |
π Explanation:
- The 7.5% USITC surtax is applied to certain agricultural/food products under Section 301.
- The 10% IEEPA surtax is the standard additional tariff on Chinese-origin goods.
- Total 20% is considered high for a food product; pre-calculation is essential.
π― 2. 2209.00.90.00 β Other Vinegar (Blended/Non-Apple)
| Item | Content |
|---|---|
| Base Rate | 2.5% |
| USITC Surtax | +7.5% |
| IEEPA Surtax | +10% |
| Total Tariff | 20% |
| Calculation | CIF Γ 20% |
| De Minimis Exemption | β Not Available |
| Legal Basis Path | Same as above |
π Note:
- If the product is labeled as "Apple Cider Vinegar" but contains additives (e.g., flavorings, sweeteners), it may still be classified under 2209.00.10.00 if ACV is the main component.
- If it is a blended vinegar (e.g., Apple Cider Vinegar + Balsamic), it may fall under 2209.00.90.00.
π― 3. 2106.90.98.00 β ACV Powder/Dietary Supplement
| Item | Content |
|---|---|
| Base Rate | 0% |
| USITC Surtax | +7.5% (if classified under specific food prep list) |
| IEEPA Surtax | +10% |
| Total Tariff | 17.5% |
| Calculation | CIF Γ 17.5% |
| De Minimis Exemption | β Not Available |
| Legal Basis Path | IEEPA:9903.01.24 β USITC:2106.90.98.00 |
π Note:
- ACV powder is often marketed as a dietary supplement.
- If declared as a "food supplement" (2106), it avoids the higher vinegar classification but still incurs surtaxes.
- Ensure FDA registration and DSHEA compliance for import into the US.
π οΈ IV. Customs Clearance Practical Advice (Battle-Proven Pitfall Guide)
β 1. Document Checklist (None Can Be Missing)
| Document | Required | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Ingredients, acetic acid content (%), volume/weight |
| β Free Sale Certificate | βοΈ | Issued by origin country authority |
| β Certificate of Origin (CO) | βοΈ | To determine eligibility for any potential exemptions |
| β FDA Registration | βοΈ | For food/supplement imports into the US |
| β Commercial Invoice | βοΈ | Clearly state "Apple Cider Vinegar" or "ACV Powder" |
| β Packing List | βοΈ | Detail net/gross weight, package type |
| β Label Copy | βοΈ | Must include English ingredient list, net content, manufacturer info |
β 2. Declaration Tips (Key Mnemonics)
π₯ "Liquid to 2209, Powder to 2106, Supplement to 2106, Don't Mix Them!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Liquid ACV (100% pure) | 2209.00.10.00 |
Declare as "food prep" β 17.5% vs 20% (slight diff, but compliance issue) |
| ACV Powder (with maltodextrin) | 2106.90.98.00 |
Declare as "vinegar" β Rejection/Fine |
| Blended Vinegar | 2209.00.90.00 |
Declare as "apple vinegar" β Misclassification |
| Industrial Acetic Acid | 2915.22.00.00 |
Declare as "food vinegar" β Safety/FDA Violation |
β 3. Special Case Handling
| Scenario | Handling Advice |
|---|---|
| Organic ACV | Provide Organic Certificate; may qualify for preferential treatment in some markets (not US) |
| ACV with "Mother" | Declare as "unfiltered"; no tariff difference, but affects FDA inspection |
| Bottled vs. Bulk | Bottled: Declare as retail; Bulk: Declare as industrial/commercial |
| Imported by Non-US Entity | Ensure Importer of Record is registered with CBP and FDA |
π V. Global Main Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ US | 2209.00.10.00 |
20% (CN origin) | FDA + Labeling | High due to surtaxes |
| π¨π³ China | 2209.00.10.00 |
5% | No surtax | Low tariff, easy entry |
| πͺπΊ EU | 2209.00.90.00 |
0-10% | EFSA Compliance | Check country-specific rules |
| π¬π§ UK | 2209.00.90.00 |
0-10% | FSA Compliance | Post-Brexit rules apply |
| π¦πΊ Australia | 2209.00.10.00 |
5% | FSANZ | Low tariff |
π Conclusion:
- US has the highest effective tariff (20%) for Chinese-origin ACV.
- China and Australia have low tariffs (5%).
- EU/UK have moderate tariffs (0-10%) but stricter food safety regulations.
π VI. Common Mistakes & Pitfall Guide (Lessons Learned)
β Mistake 1: Declaring ACV Powder as "Vinegar" (2209)
π Consequence: Customs rejection or fine because powder is not vinegar.
β Mistake 2: Under-declaring acetic acid content
π Consequence: Misclassification if >10% acetic acid β may require chemical safety data.
β Mistake 3: Not providing FDA Registration
π Consequence: Hold at port, destruction, or return.
β Mistake 4: Using "Apple Juice" for ACV
π Consequence: Major misclassification β 0% vs 20% β Penalty + Back Taxes.
β Correct Practice:
"Apple Cider Vinegar, Liquid, Unfiltered, 5% Acidity, Bottled, 16oz, FDA Registered, Origin: China"
π― VII. Conclusion: Precision Declaration, Cost Reduction, Efficiency!
π― Remember the Mnemonic:
πΉ "Liquid 2209, Powder 2106, Supplement 2106, Don't Mix!"
πΉ "Tariff 20% for US, 5% for China, 0-10% for EU/UK/ANZ"
πΉ "FDA is a must, Labeling is key, Classification is fate!"
π Tips:
- If your ACV is originating from Vietnam, Thailand, or Malaysia, you may apply for IEEPA exemption or GSP/FTA benefits (check latest agreements).
- Recommend applying for Advance Ruling from CBP for complex blends (e.g., ACV + herbs).
π£ Immediate Action:
π Contact a licensed customs broker + Provide product samples + Apply for HS Code Advance Ruling
π Ensure smooth clearance, maximize profit, and scale your ACV business globally!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every cent of your cost deserves precise calculation!
Customer Reviews
About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) β Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) β More specific grouping within the chapter
- Subheading (6 digits) β Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) β Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate β The standard duty rate applied to WTO members
- General rate β Applied to countries without trade agreements
- Trade remedy duties β Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.