农用杀菌剂悬浮剂
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 2828100000 | 37.4% | CN | US | Official Doc |
| 2827399050 | 10.0% | CN | US | Official Doc |
| 3808923000 | 40.0% | CN | US | Official Doc |
| 3808997000 | 40.0% | CN | US | Official Doc |
| 2828900000 | 38.7% | CN | US | Official Doc |
AI Analysis
🌾 Agricultural Fungicide Suspension (农用杀菌剂悬浮剂)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition and Classification: What is "Inorganic Fungicide Suspension"?
Agricultural Fungicide Suspension (WP/SC/Suspension Concentrate) is a common pesticide formulation in international trade. Its classification is critical because it sits at the intersection of chemical salts (Chapter 28) and pesticides/fertilizers (Chapter 38).
Key Classification Dilemma: The core dispute lies in whether the product is defined by its chemical composition (inorganic salt) or its functional use (fungicide).
⚠️ Critical Distinction Point:
- If classified under Chapter 28 (Inorganic Chemicals): It is treated as a raw chemical material (e.g., Hypochlorites, Chlorides).
- If classified under Chapter 38 (Miscellaneous Chemical Products): It is treated as a finished pesticide product containing fungicidal properties.
- Suspension (Susp.): Refers to the physical state (solid particles dispersed in liquid), which does not change the chemical nature but affects how the product is described in customs declarations.
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, here are the 5 possible HS Codes and their matching logic:
| HS Code | Product Description | Matching Logic (Summary) | Total Tax Rate (Approx.) |
|---|---|---|---|
2828.10.00.00 |
Inorganic Hypochlorites and Chlorochromates; Hypochlorite Mixtures | Material Match: "Inorganic" implies hypochlorites/chlorites. "Suspension" is just a form. Logic: Core component = Inorganic salt. |
37.4% (Base 2.4% + Addl 25% + 122 Clause 10%) |
2827.39.90.50 |
Other Chlorides; Other Inorganic Chemicals | Inference Match: Biocides often fall under inorganic chemicals. "Suspension" fits chemical制剂 forms. Logic: Broad "Other Chlorides" catch-all for inorganic biocides. |
+10.0% (Base 0% + 122 Clause 10%) |
3808.92.30.00 |
Fungicides, Anti-germinants and Plant-Growth Regulators (Containing Inorganic Substances) | Explicit Match: Name contains "Inorganic" AND "Fungicide". Perfect fit for "Fungicides... containing inorganic substances". Logic: Function (Fungicide) + Composition (Inorganic). |
40.0% (Base 5.0% + Addl 25% + 122 Clause 10%) |
3808.99.70.00 |
Other Pesticides, Rodenticides, Fungicides... (Other) | Successful Match: Contains "Fungicide" and "Inorganic" requirements. Logic: General category for inorganic fungicides not specified elsewhere. |
40.0% (Base 5.0% + Addl 25% + 122 Clause 10%) |
2828.90.00.00 |
Other Salts of Hypochlorous Acid, Other Halogen Salts of Inorganic Acids | Material Match: "Inorganic Fungicide" fits inorganic salt category. Logic: Broad inorganic salt category for fungicides not specifically hypochlorites. |
38.7% (Base 3.7% + Addl 25% + 122 Clause 10%) |
🔍 Key Insight:
- Chapter 28 Codes (2828.10,2827.39,2828.90) focus on the chemical nature (Salt/Chloride). Taxes range from 10% to 38.7%.
- Chapter 38 Codes (3808.92,3808.99) focus on the agricultural function (Fungicide). Taxes are higher at 40.0%.
- Note: "Suspension" (悬浮剂) is a formulation form and does NOT change the HS code chapter on its own, but supports the description of the chemical state.
💰 III. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policies)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Time: Post-November 2025 (Based on 122 Clause and Section 301 logic in data)
🎯 1. Chapter 28: Inorganic Chemicals (Lower Tax Variants)
A. 2828.10.00.00 – Inorganic Hypochlorites
| Item | Detail |
|---|---|
| Base Duty | 2.4% |
| Section 301 Duty (Addl) | +25.0% |
| Section 122 Clause Duty | +10.0% |
| Total Effective Rate | 37.4% |
| Legal Basis | USITC:2828.10.00.00 → Footnote:301 → Footnote:122 |
B. 2827.39.90.50 – Other Chlorides (Lowest Risk?)
| Item | Detail |
|---|---|
| Base Duty | 0.0% (Data shows empty, implying 0 or negligible) |
| Section 301 Duty (Addl) | 0.0% |
| Section 122 Clause Duty | +10.0% |
| Total Effective Rate | 10.0% |
| Legal Basis | USITC:2827.39.90.50 → Footnote:122 |
| ⚠️ Warning | This code has the lowest tax, but only if the product can be legally classified as a general "Inorganic Chloride" rather than a specific pesticide. Misclassification risk is high if EPA registration is required. |
C. 2828.90.00.00 – Other Inorganic Salts
| Item | Detail |
|---|---|
| Base Duty | 3.7% |
| Section 301 Duty (Addl) | +25.0% |
| Section 122 Clause Duty | +10.0% |
| Total Effective Rate | 38.7% |
| Legal Basis | USITC:2828.90.00.00 → Footnote:301 → Footnote:122 |
🎯 2. Chapter 38: Pesticides & Fungicides (Higher Tax)
D. 3808.92.30.00 – Fungicides (Containing Inorganic Substances)
| Item | Detail |
|---|---|
| Base Duty | 5.0% |
| Section 301 Duty (Addl) | +25.0% |
| Section 122 Clause Duty | +10.0% |
| Total Effective Rate | 40.0% |
| Legal Basis | USITC:3808.92.30.00 → Footnote:301 → Footnote:122 |
| ✅ Best Fit for Function | This is the most accurate functional classification for an "Inorganic Fungicide." |
E. 3808.99.70.00 – Other Pesticides/Fungicides
| Item | Detail |
|---|---|
| Base Duty | 5.0% |
| Section 301 Duty (Addl) | +25.0% |
| Section 122 Clause Duty | +10.0% |
| Total Effective Rate | 40.0% |
| Legal Basis | USITC:3808.99.70.00 → Footnote:301 → Footnote:122 |
🛠️ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)
✅ 1. Preparation Checklist (Must-Haves)
| Document | Required? | Purpose |
|---|---|---|
| ✅ Product SDS (Safety Data Sheet) | ✔️ | To prove chemical composition (Inorganic vs Organic). |
| ✅ EPA Registration Number | ✔️ | Critical for Chapter 38. If sold as a pesticide in the US, it MUST have an EPA number. |
| ✅ Ingredient Breakdown (%) | ✔️ | To distinguish between "Active Ingredient" (Fungicide) and "Inert Ingredients." |
| ✅ Physical State Description | ✔️ | Confirm "Suspension" (SC) vs "Wettable Powder" (WP). |
| ✅ Commercial Invoice | ✔️ | Must clearly state "Inorganic Fungicide Suspension" and HS Code. |
| ✅ Certificate of Origin | ✔️ | To determine applicability of Section 301/122 duties. |
✅ 2. Declaration Strategy (The "Function vs. Material" Battle)
| Scenario | Recommended HS Code | Reasoning | Tax Risk |
|---|---|---|---|
| Product is EPA Registered Pesticide | 3808.92.30.00 or 3808.99.70.00 |
US Customs prioritizes Function (Pesticide) for registered products. | High (40%), but Legally Safe. |
| Product is Industrial Chemical Raw Material (Not for Ag Direct Use) | 2828.10.00.00 or 2828.90.00.00 |
Classified as a Chemical Salt. | Medium-High (37-38%). |
| Product is a Simple Inorganic Chloride Salt | 2827.39.90.50 |
If it’s just a chloride salt with NO specific pesticidal claim. | Lowest (10%). |
| ❌ Misclassification | Using 2827 for a registered pesticide |
Customs will reclassify to 3808, charge back-taxes + penalties. |
Very High Risk. |
🔥 Golden Rule:
"If it kills fungi and has an EPA number, classify under Chapter 38. If it's a raw chemical salt for industrial use, classify under Chapter 28."
✅ 3. Special Circumstances Handling
| Situation | Advice |
|---|---|
| EPA Registration Missing | Do NOT declare as a pesticide. Declare as an inorganic chemical (2828 or 2827). Risk of 122 Clause duty may still apply. |
| Mixtures with Organic Solvents | If >50% is organic, it might fall under Chapter 38 Other Pesticides or even Chapter 29 (Organic). Need precise % analysis. |
| "Suspension" Formulation | Ensure the declaration includes "Suspension Concentrate (SC)" to match the physical state, but this does NOT change the HS code chapter. |
| Section 122 Clause (10%) | Applies to many Chinese chemical imports. Ensure your supplier confirms if their raw materials are subject to this. |
🌍 V. Global Market Comparison (2026)
| Country/Region | Recommended HS Code | Est. Duty (China Origin) | Key Requirement |
|---|---|---|---|
| 🇺🇸 USA | 3808.92.30.00 (Best Fit) |
40.0% | EPA Registration Mandatory |
| 🇨🇳 China | 3808.93.00.00 (Local) |
~5-10% | Pesticide Registration Certificate |
| 🇪🇺 EU | 3808.93.10 |
~0-6.5% | BPR Registration (Biocidal Products Regulation) |
| 🇯🇵 Japan | 3808.92.00 |
~0-3% | Fertilizer Control Law or Pest Control Law |
📌 Conclusion:
- The USA imposes the highest combined duty (40%) on inorganic fungicides due to Section 301 and 122 clauses.
- EU requires strict BPR registration, but tariffs are lower.
- Misclassification in the US (declaring as chemical2827instead of pesticide3808) leads to severe penalties if EPA status is checked.
📌 VI. Common Mistakes & Pitfalls (Lessons Learned)
❌ Mistake 1: Classifying a registered pesticide under 2827.39 to get 10% tax.
👉 Consequence: Customs audits EPA registry, finds match, reclassifies to 3808, charges 30% back-duties + penalties.
❌ Mistake 2: Ignoring the "122 Clause" (10%).
👉 Consequence: Many inorganic chemicals are subject to this. If not accounted for, budget shortfalls occur.
❌ Mistake 3: Declaring only "Fungicide" without "Inorganic".
👉 Consequence: Customs may assume it’s organic, leading to wrong tariff lines or requests for further testing.
✅ Correct Practice:
"Inorganic Fungicide Suspension, SC Formulation, Contains Copper Sulfate [or specific salt], EPA Reg. No. XXXXX, HS: 3808.92.30.00"
🎯 VII. Conclusion: Professional Declaration for Cost & Compliance Balance
🎯 Remember the Mantra:
🔹 "EPA Registered? Go Chapter 38. Raw Chemical? Go Chapter 28."
🔹 "Suspension is just form, Composition is key."
🔹 "Don't risk 10% for 40% if you're not sure – Compliance is cheaper than penalties!"
📌 Pro Tip:
If your product is a raw chemical intermediate (not sold as a finished pesticide), fight for 2827.39.90.50 (10% tax) by providing invoices that show B2B chemical sales, not agricultural sales. But if it's a ready-to-use or active ingredient for agriculture, 3808.92.30.00 (40% tax) is the only safe legal route.
📣 Immediate Action:
📞 Verify EPA Registration Status.
📞 Request HS Code Advance Ruling from CBP if unsure.
🚀 Accurate Classification = Smooth Customs + Predictable Costs!
✨ Professional Customs Clearance Starts with Precise Classification!
💼 Every Tax Percent Matters in Your Bottom Line!
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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) — Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) — More specific grouping within the chapter
- Subheading (6 digits) — Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) — 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 — The standard duty rate applied to WTO members
- General rate — Applied to countries without trade agreements
- Trade remedy duties — 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.