silicone ice cube
CN β USAI Analysis
π§ Silicone Ice Cube Trays & Molds (Household Articles of Plastics)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Strategy for US Imports from China
π Part 1: Product Definition & Classification β What Exactly is a "Silicone Ice Cube"?
In international trade, "silicone ice cube" usually refers to silicone ice cube trays or ice molds used in households, bars, and offices. It is critical to distinguish between the raw silicone material and the finished household article.
Key Classification Logic: 1. Finished Ice Tray/Mold: A manufactured product with a specific shape (cubes, spheres, etc.) used to make ice. This falls under Chapter 39 (Plastics and articles thereof). 2. Raw Silicone Sheet/Block: If you are importing raw silicone rubber sheets to be molded later, this falls under Chapter 39 or Chapter 40 depending on the exact polymer type, but typically silicone is classified under plastic articles for finished goods. 3. Kitchen Utensil: Some might argue it's a "kitchen utensil," but HS codes prioritize the material for plastics over the function for kitchenware (unlike stainless steel trays). Therefore, Chapter 39 prevails.
β οΈ Critical Distinction:
- If it is a finished tray/mold β HS Code 3924.10.00.00 (Tableware and kitchenware, of plastics).
- If it is raw silicone rubber β HS Code 4014.90.00.00 or 3910.00 (depending on form), but usually, importers import the finished tray, not raw silicone.
- Do NOT classify under 8213 (Knives/Utensils) or 7323 (Iron/Steel) unless mixed with other materials. Pure silicone = Plastic Chapter.
π¦ Part 2: HS Code Classification Details (2026 Latest Tariff Schedule)
| HS Code | Product Description | Applicable Scenario | Material Basis |
|---|---|---|---|
3924.10.00.00 |
Tableware and kitchenware, of plastics | Silicone ice cube trays, molds, bakeware | β Plastic (Silicone is a plastic/elastomer) |
4014.90.00.00 |
Other articles of vulcanized rubber other than hard rubber | Rare for finished trays; more for seals/gaskets | β Not recommended for trays |
9618.00.00.00 |
Cut-composition articles and articles of cut textile materials | Old classification for some textiles; incorrect for silicone | β Wrong chapter |
π Key Reminder:
- Silicone is legally classified under Chapter 39 as a plastic article in most customs jurisdictions (including the US).
- The specific subheading 3924.10.00.00 covers "Tableware and kitchenware, of plastics." Ice trays are considered kitchenware.
- Do not confuse with food containers (3924.90), which have different rates.
π° Part 3: 2026 Latest Tariff Rate Details (Including Additional Duties & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: November 10, 2025 (and subsequent imports)
π― 1. 3924.10.00.00 ββ Tableware and Kitchenware, of Plastics (Silicone Ice Trays)
| Item | Content |
|---|---|
| Base Duty Rate | 5.7% (ad valorem) |
| USITC Additional Duty (Section 301) | +25% (Footnote 9903.88.01) |
| IEEPA Additional Duty | +10% (Targeting China/HK products, effective Nov 10, 2025) |
| Total Duty Rate | 40.7% |
| Duty Calculation | CIF Value Γ 40.7% |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis) |
| Legal Pathway | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3924.10.00.00 β FOOTNOTE:9903.88.01 |
π Explanation:
- 5.7% is the standard MFN (Most Favored Nation) rate for plastic kitchenware.
- 25% is the Section 301 tariff added by the US Trade Representative (USTR) on Chinese goods.
- 10% is the new IEEPA (International Emergency Economic Powers Act) tariff targeting specific categories of Chinese imports, effective late 2025.
- Total: 40.7%. This is a high-duty item. Profit margins will be severely impacted if not planned for.
π― 2. Alternative: If Classified as "Other Plastic Articles" (Riskier)
| HS Code | Description | Total Duty | Note |
|---|---|---|---|
3926.90.98.90 |
Other articles of plastics, n.e.s. | ~40.7% | Usually not applicable for kitchenware; customs may reclassify to 3924.10. |
π Warning:
- Misclassifying as a non-kitchenware plastic item may lead to penalties for undervaluation or misclassification.
- Always use 3924.10.00.00 for ice trays.
π οΈ Part 4: Customs Clearance Practical Advice (Battle-Tested Pitfall Avoidance Guide)
β 1. Required Documentation Checklist (Non-Negotiable)
| Document | Required | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must state: "100% Food-Grade Silicone," "BPA Free," "Temperature Range." |
| β FDA Compliance Statement | βοΈ | Essential for food-contact articles. Must confirm FDA 21 CFR 177.2600 compliance. |
| β Commercial Invoice | βοΈ | Must describe item as "Silicone Ice Cube Tray" or "Kitchen Molds," NOT "Rubber Parts." |
| β Packing List | βοΈ | Show weight and dimensions accurately for duty calculation. |
| β Country of Origin Certificate | βοΈ | To prove Chinese origin (subject to tariffs). |
| β CE/RoHS Report (Optional) | βοΈ | Useful for EU market, less critical for US but good for brand credibility. |
β 2. Declaration Tips (Key Mantras)
π₯ βDescribe Clearly, Material Specific, Avoid βRubberβ Mislabeling!β
| Scenario | Correct Declaration | Incorrect Practice |
|---|---|---|
| Finished Silicone Tray | 3924.10.00.00 β "Silicone Ice Cube Tray for Household Use" |
"Rubber Mold" β 4014.90 (Higher scrutiny) |
| Bulk Silicone Sheets | 4014.90.00.00 or 3910.00 |
Calling it a "Tray" β Misclassification |
| Mixed Material (Plastic Handle + Silicone Tray) | Classify as Kitchenware (3924) if silicone is principal material | Splitting items β Complicates customs |
β 3. Special Cases Handling
| Situation | Handling Advice |
|---|---|
| Food-Grade Certification | Must provide FDA Letter of Guarantee. Without it, customs may detain for safety inspection. |
| Private Labeling | If importing under your own brand, ensure the invoice reflects the brand and model. |
| Small Quantities (Gifts) | Below $800 (de minimis) is not exempt for China-origin goods under current policies (deny_de_minimis). Pay duty even for samples. |
| Packaging | If packed in cardboard, ensure the cardboard is not counted as part of the product value for duty (separate line items). |
π Part 5: Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Duty Rate (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3924.10.00.00 |
40.7% (5.7% + 25% + 10%) | FDA 21 CFR 177.2600 | Highest duty burden |
| π¨π³ China | 3924.10.00.00 |
5% | GB 4806.11 (Food Contact) | Low domestic duty |
| πͺπΊ EU | 3924.10.00 |
6.5% | LFGB / EU 10/2011 | No major political tariffs |
| π¬π§ UK | 3924.10.00 |
6.5% | UKCA / FSA Guidelines | Post-Brexit rules apply |
| π¦πΊ Australia | 3924.10.00 |
5% | Australian Standards | No major tariffs |
π Conclusion:
- USA is the most expensive market for Chinese silicone kitchenware due to layered tariffs.
- EU and Asia offer significantly lower duty burdens (5-7%).
- Consider supply chain diversification (e.g., Vietnam, Thailand) if targeting the US market heavily to avoid IEEPA/301 tariffs.
π Part 6: Common Errors & Pitfall Guide (Blood Lessons)
β Error 1: Calling the product "Rubber Ice Tray"
π Consequence: Customs may classify under 4014.90 (Rubber), leading to higher scrutiny or misclassification penalties.
π Fix: Always use "Silicone" and HS Code 3924.10.00.00.
β Error 2: Ignoring FDA Food-Contact Compliance
π Consequence: Cargo held at port for FDA testing, delaying clearance by weeks.
π Fix: Provide FDA compliance statement and test reports from accredited labs.
β Error 3: Under-declaring Value to Avoid Duty
π Consequence: Seizure, fines, and loss of import privileges.
π Fix: Declare accurate CIF value. Duty is unavoidable; optimize profit margins instead.
β Error 4: Assuming De Minimis ($800) Applies
π Consequence: Surprises at customs with 40.7% duty bill on small shipments.
π Fix: Budget for duties even on small orders from China.
π― Part 7: Conclusion β Smart Declaration, Cost Control, Profit Protection!
π― Remember the Mantra:
πΉ "Silicone is Plastic (3924), Not Rubber (4014)."
πΉ "FDA Compliance is Mandatory for Food Contact."
πΉ "USA Duty is 40.7% β Plan Your Margin Accordingly!"
πΉ "De Minimis Does Not Apply to China β Pay Your Duties."
π Pro Tip:
- If your silicone trays are made in Vietnam, Malaysia, or Thailand, you may qualify for lower or zero tariffs under US trade agreements (e.g., GSP, though limited for China-adjacent countries, or general MFN rates).
- Always apply for a Binding Ruling from CBP if you are unsure about the classification or if your product has mixed materials.
π£ Immediate Action:
π Contact Your Customs Broker + Provide FDA Docs + Verify HS Code 3924.10.00.00
π Ensure Smooth Clearance, Avoid Delays, Protect Your Margins!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every Percent of Duty Matters β Know Your Code, Save Your Profit!
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.