modified aromatic disinfectant small pack
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3808941000 | 41.5% | CN | US | Official Doc |
| 3808615000 | 22.5% | CN | US | Official Doc |
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AI Analysis
π§ͺ Modified Aromatic Disinfectant Small Pack
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Truly Understand "Modified Aromatic Disinfectants"?
"Modified Aromatic Disinfectant Small Pack" refers to disinfectant preparations or articles containing modified aromatic compounds (e.g., chlorinated derivatives of aromatic amines, quaternary ammonium compounds with aromatic structures, or other chemically altered aromatic biocides). These products are specifically formulated for retail sale in small units (e.g., packets, sachets, small bottles, strips, or candles).
In international trade, precise classification is critical because the presence of "modified aromatic" components triggers specific subheadings under Chapter 38, often resulting in different duty rates compared to general disinfectants.
β οΈ Key Distinction Point:
- If the disinfectant contains any aromatic or modified aromatic compound (e.g., triclosan derivatives, chloroxylenol, certain quats with aromatic rings) β It falls under 3808.94.10.00.
- If the disinfectant is general purpose (e.g., alcohol, hydrogen peroxide, simple iodine) without aromatic modifications β It may fall under other subheadings like 3808.94.90 or 3808.61/62 depending on packaging.
- Crucial Note: The term "Small Pack" implies retail packaging, which is a prerequisite for Chapter 38 classification.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided , here are the relevant HS Codes and their tax implications. Note that two distinct HS codes in the data relate to disinfectants/pesticides with different tax treatments. We must determine which applies to your specific product based on composition and packaging.
| HS Code | Product Description | Key Criteria | Tax Rate |
|---|---|---|---|
3808.94.10.00 |
Disinfectants: Containing any aromatic or modified aromatic disinfectant | β
Must contain aromatic/modified aromatic compounds β Put up for retail sale |
0.0% (Base: 0%, Additional: 0%) |
3808.61.50.00 |
Insecticides, etc.: Other (Good specified in subheading note 2: In packings β€ 300g net weight) | β οΈ Note: This HS Code description in actually refers to Insecticides/Rodenticides/Fungicides (Chapter 38 Note 2), NOT disinfectants. β οΈ However, if your "disinfectant" is misclassified or if the data implies a specific retail packing rule for small packs β€300g, this rate may apply if it is legally classified under this subheading. β Net weight β€ 300g β Retail packaging |
12.5% (Base: 5%, Additional: 7.5%) |
π Critical Analysis for Your Product:
- Scenario A: Your product is a disinfectant containing modified aromatic compounds.
β Correct HS Code:3808.94.10.00
β Tax Rate: 0.0%
β Why: The description explicitly matches "Disinfectants: Containing any aromatic or modified aromatic disinfectant."
- Scenario B: Your product is a disinfectant but does NOT contain aromatic compounds, OR it is misclassified in the data source as falling under the general "other" small pack category.
β Potential HS Code:3808.61.50.00(if applicable to disinfectants under Note 2, though typically Note 2 refers to insecticides/fungicides).
β Tax Rate: 12.5%
β Risk: If you incorrectly declare an aromatic disinfectant as a general small pack, you may face reclassification and penalties.π Recommendation:
Since your product is explicitly a "Modified Aromatic Disinfectant", the most accurate HS Code from the is3808.94.10.00. The3808.61.50.00code appears to be for non-aromatic small packs or potentially mislabeled in the data for disinfectants. Do not use3808.61.50.00for aromatic disinfectants unless confirmed by customs authority that it is not covered by3808.94.10.00.
π° III. 2026 Latest Tariff Rate Breakdown (Detailed Tax Clauses)
β Applicable Country: United States (US)
β Origin: China (CN) (Assumed based on typical trade context; adjust if origin differs)
β Effective Time: Current 2026 Tariff Schedule
π― 1. 3808.94.10.00 ββ Disinfectants Containing Modified Aromatic Compounds
| Item | Content |
|---|---|
| Base Tariff | 0% (ad valorem) |
| Additional Tariff | 0% |
| Total Tariff | 0.0% |
| Tax Calculation | CIF Value Γ 0% = $0 |
| De Minimis Eligibility | β Yes (if value β€ $800, no duty even if taxed) |
| Legal Basis | HTSUS 3808.94.10 |
π Explanation:
- This subheading is specifically designed for aromatic/modified aromatic disinfectants.
- The 0% tariff is highly advantageous.
- No additional 301 tariffs are listed in for this code, unlike electronics or machinery.
- Key Condition: The product must contain an aromatic or modified aromatic disinfectant ingredient. If it does not, it may be reclassified.
π― 2. 3808.61.50.00 ββ Small Pack Disinfectants/Insecticides (β€ 300g)
| Item | Content |
|---|---|
| Base Tariff | 5% (ad valorem) |
| Additional Tariff | 7.5% |
| Total Tariff | 12.5% |
| Tax Calculation | CIF Value Γ 12.5% |
| De Minimis Eligibility | β Yes (if value β€ $800) |
| Legal Basis | HTSUS 3808.61.50 |
π Explanation:
- This code applies to disinfectants/pesticides in retail packaging β€ 300g net weight.
- 12.5% total tariff is significantly higher than the 0% for aromatic disinfectants.
- Risk: If your product is a modified aromatic disinfectant but declared under this code, you may be subject to undervaluation or misclassification audits.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Avoidance)
β 1. Preparation Checklist (Mandatory Documents)
| Document | Required | Explanation |
|---|---|---|
| β Product Formula/Composition | βοΈ Critical | Must list all active ingredients. Must explicitly state if "modified aromatic" compounds are present. |
| β Safety Data Sheet (SDS) | βοΈ Required | Shows hazardous materials classification. Must align with HS Code description. |
| β Product Photos (Packaging) | βοΈ Required | Clearly show "Retail Packaging" and "Net Weight β€ 300g" if claiming 3808.61.50.00. |
| β Commercial Invoice | βοΈ Required | Describe product as "Disinfectant, Modified Aromatic, Retail Pack". Avoid vague terms like "Cleaning Solution." |
| β Certificate of Analysis (COA) | βοΈ Recommended | Proves the presence of aromatic compounds (supports 3808.94.10.00). |
| β Customs Declaration Form | βοΈ Required | HS Code must match the description exactly. |
β 2. Declaration Tips (Key Mnemonic)
π₯ "Aromatic = 0%, Small Pack = 12.5%. Formula Dictates Code!"
| Scenario | Correct HS Code | Risk of Misclassification |
|---|---|---|
| Disinfectant with modified aromatic compounds | 3808.94.10.00 |
β 0% Tax (Best Outcome) |
| Disinfectant without aromatic compounds, β€ 300g | 3808.61.50.00 (or other non-aromatic code) |
β οΈ 12.5% Tax |
Disinfectant with aromatic compounds, declared as 3808.61.50.00 |
Misclassification | β Penalty + Back Taxes |
| Disinfectant > 300g | Not covered by 3808.61.50.00 |
β Reclassification Required |
β 3. Special Handling Scenarios
| Situation | Handling Advice |
|---|---|
| Mixed Packaging (e.g., bulk + retail) | Declare separately. Retail packs β€ 300g may qualify for 3808.61.50.00 if non-aromatic. |
| OEM Private Label | Provide supplier formula. Do not hide "modified aromatic" ingredients. |
| Biocidal Products | Ensure EPA registration (if US) or local biocide approval. |
| Aerosol Form | May require additional hazard class declaration (Class 2). |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3808.94.10.00 |
0.0% | EPA Registration | Best Option for aromatic disinfectants. |
| πͺπΊ EU | 3808 94 00 | 0% - 6% | BPR (Biocidal Products Regulation) | Varies by member state. |
| π¨π³ China | 3808.94 | 5% - 10% | N/A | Import duty varies. |
| π―π΅ Japan | 3808.94 | 0% - 5% | N/A | Low tariff for disinfectants. |
π Conclusion:
- USA offers 0% duty for modified aromatic disinfectants under3808.94.10.00.
- Do not default to3808.61.50.00(12.5%) unless your product is non-aromatic and β€ 300g.
- Misclassification risk is high if formula is not properly disclosed.
π VI. Common Errors & Pitfall Guide (Lessons Learned)
β Error 1: Declaring an aromatic disinfectant as 3808.61.50.00 to avoid scrutiny.
π Consequence: Customs audit reveals aromatic content β Back taxes + 12.5% duty + Penalty.
β Error 2: Not providing Formula/Composition.
π Consequence: Customs cannot verify "modified aromatic" claim β Reclassification to highest possible duty.
β Error 3: Using vague descriptions like "Cleaning Agent."
π Consequence: Customs assigns general HS Code β Higher duty + Delays.
β Error 4: Ignoring SDS alignment.
π Consequence: SDS shows hazardous chemicals not declared β Seizure or Fine.
β Correct Practice:
"Disinfectant Solution, Modified Aromatic (e.g., Triclosan Derivative), Retail Pack 100g, EPA No. XXXXX, SDS Attached"
π― VII. Conclusion: Professional Declaration, Cost Savings, Efficiency!
π― Remember the Mnemonic:
πΉ "Aromatic = 0%, Small Pack = 12.5%. Formula Dictates Code!"
πΉ "HS Code Determines Duty, 12.5% vs 0% is Huge, Declare Correctly, Save Money!"
π Pro Tip:
- If your product is non-aromatic, consider if it can be reformulated to include a modified aromatic compound to qualify for 0% duty under 3808.94.10.00.
- Always provide the full ingredient list to customs brokers.
- Apply for Advance Ruling if unsure about "modified aromatic" status.
π£ Immediate Action:
π Contact Customs Broker + Provide Formula + SDS + Request HS Code Pre-Ruling
π Ensure Smooth Clearance, Zero Duty, Maximum Profit!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every Percent of Duty Saved is Pure Profit!
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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.