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CN β†’ US
HS Code Tariff Rate Origin Destination Doc
4818200040 35.0% CN US Official Doc
3926909950 22.8% CN US Official Doc
5603110070 35.0% CN US Official Doc
5603910090 35.0% CN US Official Doc
4818200020 35.0% CN US Official Doc

AI Analysis

🧼 Facial Cleansing Pads (Cotton/Tissue/Paper Towels for Face)


🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
πŸ“Œ I. Product Definition & Classification: Do You Really Understand "Facial Cleansing Pads"?

Facial cleansing pads are single-use or disposable hygiene products used for facial cleaning, makeup removal, or disinfection. In international trade, their classification depends strictly on material composition and manufacturing process. Misclassification is the most common cause of customs delays and penalty assessments.

There are three main material categories in the provided data: 1. Paper-based (Cellulose): Traditional disposable tissues or cotton-like paper products. 2. Non-woven Fabrics: The most common type for wet wipes and dry cleansing pads, made from bonded fibers (polyester, viscose, etc.). 3. Plastic/Fiber Composites: Often used for specific disinfection wipes or synthetic fiber pads.

⚠️ Key Distinction Point:
- If the pad is made of paper pulp or cellulose fibers processed into a sheet β†’ It falls under Chapter 48 (Paper). - If the pad is made of bonded fibers (non-woven) β†’ It falls under Chapter 56 (Textiles/Non-wovens). - If the pad is made of plastic films or synthetic fibers not fitting non-woven definitions β†’ It may fall under Chapter 39 (Plastics).


πŸ“¦ II. HS Code Classification Details (2026 Latest Tariff Authoritative Comparison)

Based on the provided data, here is the precise breakdown for "Facial Cleansing Pads" (洁青巾):

HS Code Product Description Material Type Key Characteristics
4818.20.00.40 Facial Cleansing Pads (Paper) Paper / Cellulose Purely paper-based, used for facial cleaning. No fabric structure.
4818.20.00.20 Facial Cleansing Pads (Paper Pulp) Paper Pulp / Cellulose Fiber Made from pulp or cellulose fibers specifically for face cleaning.
5603.11.00.70 Facial Cleansing Pads (Non-woven) Non-woven Fabric Standard non-woven pads (e.g., spunlace). Thick or standard density.
5603.91.00.90 Facial Cleansing Pads (Non-woven, Light) Non-woven Fabric Thin/lightweight non-woven pads. Classified under "Other" lightweight non-wovens.
3926.90.99.50 Facial Cleansing Pads (Plastic/Fiber) Plastic / Synthetic Fiber Used for disinfection/cleaning wipes; material is plastic-based or composite fiber not covered by non-woven codes.

πŸ” Focus Reminder:
- "Non-woven" (ιžη»‡ι€ εΈƒ) is the critical keyword for textile-based pads. These are classified in Chapter 56, NOT Chapter 48. - "Paper" (ηΊΈ) refers to cellulose-based products. These are classified in Chapter 48. - Mislabeling a non-woven pad as "paper" can lead to severe penalties due to the significant difference in tariff rates.


πŸ’° III. 2026 Latest Tariff Rate Details (Including Additional Taxes & Policy Surcharges)

βœ… Applicable Country: United States (US)
βœ… Origin: China (CN)
βœ… Effective Date: 2025/2026 (Current Trade Policy)

🎯 1. 4818.20.00.40 & 4818.20.00.20 β€”β€” Facial Cleansing Pads (Paper Material)

Item Detail
Base Tariff 0.0% (Ad Valorem)
Additional Tariff (Section 301) +25.0% (USITC Footnote 9903.88.01)
122 Clause Tariff (IEEPA) +10.0% (Targeting China/HK products, effective from specific dates)
Total Tariff Rate 35.0%
Tax Calculation CIF Value Γ— 35%
De Minimis Exemption ❌ Not Available (deny_de_minimis)
Legal Basis Path Base: 0% β†’ Section 301: +25% β†’ 122 Clause: +10%

πŸ“Œ Explanation:
- Although the base tariff for paper products is 0%, the Section 301 and 122 Clause surcharges result in a high effective rate of 35%. - This applies to both 4818.20.00.40 and 4818.20.00.20.

🎯 2. 5603.11.00.70 & 5603.91.00.90 β€”β€” Facial Cleansing Pads (Non-woven Fabric)

Item Detail
Base Tariff 0.0% (Ad Valorem)
Additional Tariff (Section 301) +25.0%
122 Clause Tariff (IEEPA) +10.0%
Total Tariff Rate 35.0%
Tax Calculation CIF Value Γ— 35%
De Minimis Exemption ❌ Not Available
Legal Basis Path Base: 0% β†’ Section 301: +25% β†’ 122 Clause: +10%

πŸ“Œ Note:
- Non-woven fabrics often have a 0% base rate, but the additional tariffs push the total to 35%. - Both standard density (5603.11) and lightweight/thin (5603.91) non-woven pads face the same 35% total rate.

🎯 3. 3926.90.99.50 β€”β€” Facial Cleansing Pads (Plastic/Fiber for Disinfection)

Item Detail
Base Tariff 5.3% (Ad Valorem)
Additional Tariff (Section 301) +7.5%
122 Clause Tariff (IEEPA) +10.0%
Total Tariff Rate 22.8%
Tax Calculation CIF Value Γ— 22.8%
De Minimis Exemption ❌ Not Available
Legal Basis Path Base: 5.3% β†’ Section 301: +7.5% β†’ 122 Clause: +10%

πŸ“Œ Comparison:
- This code has a lower total rate (22.8%) compared to paper/non-woven pads (35%). - However, it is strictly for products made of plastic or specific fiber types used for disinfection/cleaning, not standard cellulose paper. Misclassification here is risky if the product is actually paper-based.


πŸ› οΈ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Avoidance)

βœ… 1. Required Documentation Checklist

Document Mandatory? Description
βœ… Product Specification Sheet βœ”οΈ Must clearly state material (e.g., "100% Cotton Wood Pulp" vs. "Spunlace Non-woven Polyester/Viscose").
βœ… Material Composition Certificate βœ”οΈ Critical for distinguishing between Chapter 48 (Paper) and Chapter 56 (Non-woven).
βœ… Product Photos (Labeled) βœ”οΈ Show texture, packaging, and any claims like "Biodegradable" or "Disinfecting."
βœ… Commercial Invoice βœ”οΈ Description must match HS Code. E.g., "Non-woven Facial Cleansing Pads" NOT just "Pads."
βœ… Bill of Lading (B/L) βœ”οΈ Ensure weight and volume match invoice.

βœ… 2. Declaration Strategy (Key Mnemonics)

πŸ”₯ "Material First, Code Second, Description Third!"

Scenario Correct Declaration Incorrect Action
Paper-based Pad Use 4818.20.xx.xx. Describe as "Paper Facial Towel." Call it "Wipe" β†’ Risk of being classified as textile.
Non-woven Pad Use 5603.xx.xx.xx. Describe as "Non-woven Facial Wipe." Call it "Cotton Pad" β†’ If synthetic, wrong classification.
Disinfecting Wipe Check if 3926.90.99.50 applies (Plastic/Fiber). Assume all wipes are the same code.
Mixed Materials Separate declaration or identify dominant material. Bundle different materials into one HS Code β†’ Audit risk.

βœ… 3. Special Circumstances Handling

Situation Recommendation
"Biodegradable" Claims Ensure the material is truly cellulose (Chapter 48) or specific bio-based non-woven. If plastic-coated, it may fall under Chapter 39.
Wet vs. Dry Pads Wet wipes (impregnated with solution) may have different classification rules depending on the solution. Dry pads are simpler.
Customs Audits Provide microscopic fiber analysis if challenged on Paper vs. Non-woven distinction.

🌍 V. Global Market Customs Comparison (2026 Latest)

Country/Region Recommended HS Code (Example) Total Tariff (China Origin) Notes
πŸ‡ΊπŸ‡Έ USA 4818.20.xx / 5603.xx 35.0% High due to 301 + 122 Clause tariffs.
πŸ‡¨πŸ‡³ China 4818.20 / 5603.11 Low/Zero Domestic consumption benefits from lower rates.
πŸ‡ͺπŸ‡Ί EU 6307.90 (Often used for wipes) Variable EU has different coding for wipes; often under 6307.90.90. Check local rules.
πŸ‡¬πŸ‡§ UK 4818.20 / 5603.11 Post-Brexit Rules Generally aligned with EU but verify current UK Tariff Book.

πŸ“Œ Conclusion:
- USA is the most challenging market due to 35% total tariffs for paper and non-woven pads. - Cost Optimization: Consider if the product can be classified under 3926.90.99.50 (22.8%) if it meets the material criteria for plastic/synthetic disinfection wipes, but do not force this classification if the material is paper/non-woven.


πŸ“Œ VI. Common Errors & Pitfall Guide (Lessons Learned)

❌ Error 1: Calling "Non-woven Pads" "Paper Towels"
πŸ‘‰ Result: Customs may reclassify to 5603 or penalize for false description. Rate difference is minimal here (both 35%), but documentation failure causes delays.

❌ Error 2: Assuming all "Cotton Pads" are 4818
πŸ‘‰ Result: If the "cotton" is actually spunlace polyester (non-woven), it must be 5603. If declared as paper, it triggers an audit for material mismatch.

❌ Error 3: Ignoring the "122 Clause"
πŸ‘‰ Result: Underpaying by 10%. The 122 Clause is a significant addition for Chinese goods, often overlooked by brokers. Always check for this 10% surcharge.

❌ Error 4: Using Generic Descriptions like "Cleaning Wipes"
πŸ‘‰ Result: Customs officers will use their best judgment, often defaulting to higher tariff codes or demanding extensive proof.
βœ… Correct Practice:

"Facial Cleansing Pads, Non-woven, 100% Viscose, White, Packaged in Plastic Pouch"


🎯 VII. Conclusion: Professional Declaration Saves Money!

🎯 Remember the Golden Rules:

πŸ”Ή "Paper is 48, Non-woven is 56, Plastic is 39."
πŸ”Ή "Base 0% or 5.3%? Add 25% + 10% = 35% or 22.8%."
πŸ”Ή "Describe Material, Not Just Function!"


πŸ“Œ Pro Tip:
If your product is not made in China (e.g., Vietnam, Indonesia), you may avoid the Section 301 (25%) and 122 Clause (10%) tariffs, potentially reducing the total rate to 0%-5.3%. Always verify the Country of Origin.


πŸ“£ Immediate Action:

πŸ“ž Confirm material composition with your supplier.
πŸ“„ Request a Material Analysis Report.
πŸš€ Apply for a Pre-Ruling if the material is ambiguous (e.g., hybrid fibers).


✨ Accurate Classification is the First Step to Profitability!
πŸ’Ό Don't let tariff errors eat your margins!

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.