制动油防冻液
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3820000000 | 24.0% | CN | US | Official Doc |
| 3403191000 | 35.2% | CN | US | Official Doc |
| 3819000090 | 41.5% | CN | US | Official Doc |
| 3811190000 | 41.5% | CN | US | Official Doc |
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AI Analysis
🚗 Brake Fluid & Antifreeze (Brake Fluids & Coolants)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: Do You Really Understand "Brake Fluid" and "Antifreeze"?
In the automotive and industrial maintenance sectors, Brake Fluid (制动液) and Antifreeze/Coolant (防冻液) are critical chemical additives and functional liquids. However, they serve distinct purposes and often fall under different HS Code categories due to their specific chemical compositions and functions.
1. Brake Fluid (制动液):
A hydraulic fluid used to transfer force/pro pressure in brake systems. It is often categorized under lubricants, preparation materials for lubricants, or other hydraulic transmission fluids depending on its base composition (petroleum-based vs. synthetic).
2. Antifreeze/Coolant (防冻液/抗冻剂):
A liquid additive added to water in cooling systems to prevent freezing in cold climates and boiling in hot climates. It is generally classified as an "other prepared anti-freezing preparations and other prepared brines" or as a "prepared other chemical products" depending on whether it is a pure additive or a complete mixture.
⚠️ Key Distinction Point:
- If the product is primarily a hydraulic transmission fluid or lubricant additive for braking systems → Look towards Chapter 34 or 3819.
- If the product is an anti-freezing agent or coolant mixture for radiators → Look towards Chapter 3820.
- If the product is a chemical additive (like an anti-corrosion or anti-knock agent) mixed into other liquids → Look towards Chapter 3811.
📦 II. HS Code Classification Details (2026 Latest Tariff Authoritative Comparison)
Based on the provided data analysis, here are the four potential HS Codes and their rationales:
| HS Code | Product Description | Application Scenario | Rationale for Classification |
|---|---|---|---|
3820.00.00.00 |
Antifreeze/De-icing Liquids | Radiator coolants, windshield washer fluids, automotive antifreezes | Direct match: "Antifreeze" in name aligns with "Anti-freezing preparations" in classification. Liquid form fits perfectly. No material conflict. |
3403.19.10.00 |
Other Lubricating Preparations | Petroleum-based brake fluids, functional liquid agents | Inference: Brake fluids are functional liquid agents containing petroleum/mineral oils. Fits "Lubricating and related preparations." |
3819.00.00.90 |
Other Hydraulic Transmission Fluids | Brake fluids, hydraulic oils for automotive systems | Direct match: "Brake Fluid" aligns with "Hydraulic brake fluids." Categorized under "Other" (catch-all) for hydraulic transmission fluids. Liquid form fits attribute. |
3811.19.00.00 |
Prepared Additives (e.g., Anti-knock, Anti-corrosion) | Chemical additives for fuels/lubricants, prepared anti-corrosion agents | Inference: "Antifreeze" can be viewed as a chemical additive for liquid systems. Fits "Prepared anti-knock, corrosion, or other additives." |
🔍 Critical Warning:
- Brake Fluid is most commonly associated with3819.00.00.90(Hydraulic Transmission Fluids) or3403.19.10.00(Lubricants), depending on its specific chemical base. - Antifreeze is most commonly associated with3820.00.00.00(Anti-freezing preparations). - Do not confuse general "coolants" with "hydraulic fluids." The function dictates the code.
💰 III. 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Additions)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: From November 10, 2025 (including subsequent imports)
🎯 1. 3820.00.00.00 —— Antifreeze / De-icing Liquids (防冻液)
| Item | Content |
|---|---|
| Basic Tariff | 6.5% (ad valorem) |
| Section 301 Surtax (USITC) | +7.5% (Specific surtax for this category in the provided data) |
| IEEPA Surtax (122 Clause) | +10% (For Chinese products) |
| Total Tariff Rate | 24.0% |
| Tax Calculation | CIF Value × 24.0% |
| De Minimis Exemption? | ❌ No (Not eligible for Section 321 de minimis exemption due to high surtaxes) |
| Legal Basis Path | IEEPA:122 → USITC:3820.00.00.00 |
📌 Explanation:
- This is the most straightforward classification for "Antifreeze." - The total tax burden is 24%, which is moderate but significant. - Ensure the product description clearly states "Antifreeze" or "Coolant Concentrate" to avoid misclassification.
🎯 2. 3403.19.10.00 —— Other Lubricating Preparations (Brake Fluid - Petroleum Based)
| Item | Content |
|---|---|
| Basic Tariff | 0.2% |
| Section 301 Surtax (USITC) | +25.0% (High surtax for lubricants/preparations) |
| IEEPA Surtax (122 Clause) | +10% (For Chinese products) |
| Total Tariff Rate | 35.2% |
| Tax Calculation | CIF Value × 35.2% |
| De Minimis Exemption? | ❌ No |
| Legal Basis Path | IEEPA:122 → USITC:3403.19.10.00 |
📌 Explanation:
- If the brake fluid is inferred to contain petroleum/mineral oil components, it may fall here. - High Risk: The 25% USITC surtax makes this a very expensive classification. - Only use if the product is chemically closer to a lubricant than a hydraulic fluid.
🎯 3. 3819.00.00.90 —— Other Hydraulic Transmission Fluids (Brake Fluid)
| Item | Content |
|---|---|
| Basic Tariff | 6.5% |
| Section 301 Surtax (USITC) | +25.0% (High surtax for "Other" hydraulic fluids) |
| IEEPA Surtax (122 Clause) | +10% (For Chinese products) |
| Total Tariff Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Exemption? | ❌ No |
| Legal Basis Path | IEEPA:122 → USITC:3819.00.00.90 |
📌 Explanation:
- This is a strong candidate for Brake Fluid if classified as a hydraulic transmission fluid. - Highest Risk: At 41.5%, this is the most expensive classification for Brake Fluid in this dataset. - Customs may scrutinize this code if the product lacks specific hydraulic transmission certifications.
🎯 4. 3811.19.00.00 —— Prepared Additives (Antifreeze/Anti-corrosion)
| Item | Content |
|---|---|
| Basic Tariff | 6.5% |
| Section 301 Surtax (USITC) | +25.0% (High surtax for additives) |
| IEEPA Surtax (122 Clause) | +10% (For Chinese products) |
| Total Tariff Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Exemption? | ❌ No |
| Legal Basis Path | IEEPA:122 → USITC:3811.19.00.00 |
📌 Explanation:
- If "Antifreeze" is considered a "prepared additive" for corrosion prevention or other chemical purposes, it falls here. - Like3819, this carries a 41.5% total tax rate. - Use this only if the product is marketed specifically as a chemical additive rather than a bulk coolant.
🛠️ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)
✅ 1. Documentation Checklist (Must-Haves)
| Document | Required | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must detail chemical composition, base fluid (petroleum/synthetic), and intended use (brake vs. radiator). |
| ✅ Safety Data Sheet (SDS) | ✔️ | Critical for chemical imports. Must classify under GHS standards. |
| ✅ Product Photos (with Label) | ✔️ | Clear view of the label showing "Brake Fluid," "DOT 3/4/5.1," or "Engine Coolant/Antifreeze." |
| ✅ Commercial Invoice | ✔️ | Must explicitly state "Antifreeze" or "Brake Fluid" – avoid vague terms like "Car Care Chemicals." |
| ✅ Certificate of Origin (CO) | ✔️ | To determine eligibility for any potential trade agreements (though unlikely to mitigate 122/301 taxes). |
| ✅ Packaging List | ✔️ | Show net/gross weight, volume, and container type. |
✅ 2. Declaration Tips (Key Mantras)
🔥 “Brake Fluid is Hydraulic, Antifreeze is Coolant, Label Clearly, Taxes Are Clear!”
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Brake Fluid (DOT Rated) | 3819.00.00.90 (Hydraulic Fluid) or 3403.19.10.00 (Lubricant) |
Misdeclare as "Antifreeze" → Wrong code, potential penalty. |
| Radiator Coolant/Antifreeze | 3820.00.00.00 (Anti-freezing Prep) |
Misdeclare as "Lubricant" → 35.2% vs 24% (Save money, but be accurate). |
| Chemical Additive Packets | 3811.19.00.00 (Prepared Additive) |
Over-declare as bulk fluid → Inspection delay. |
| Mixed Kits (Fluid + Filter) | Separate the fluid | Declare as "Auto Parts Kit" → Complex classification, high risk. |
✅ 3. Special Circumstances Handling
| Situation | Handling Advice |
|---|---|
| OEM Private Label Brake Fluid | Provide contract/license agreement. Ensure labeling matches HS Code description precisely. |
| Brake Fluid with Corrosion Inhibitors | Still likely 3819.00.00.90 or 3403.19.10.00. Do not default to 3811 unless it's a pure additive concentrate. |
| Antifreeze for Industrial Machinery | Still 3820.00.00.00 if it's an anti-freezing preparation. Provide end-use statement if requested. |
| Small Samples (De Minimis) | ❌ Do Not Attempt: Even small quantities of these chemicals are subject to the full tariff due to the 122 Clause and are not eligible for de minimis exemption if the total duty exceeds $800. |
🌍 V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3820.00.00.00 (Antifreeze) 3819.00.00.90 (Brake) |
24.0% (Antifreeze) 41.5% (Brake) |
None specific, but SDS required | High taxes due to 301 + 122 Clauses. |
| 🇨🇳 China | 3820.00.00.00 |
6.5% | No extra surtax | Much cheaper domestically. |
| 🇪🇺 EU | 3820.00.00.00 |
0-6.5% (Varies) | REACH, CLP | No US-style surtaxes. |
| 🇬🇧 UK | 3820.00.00.00 |
0-6.5% | UKCA | Post-Brexit rules apply. |
| 🇯🇵 Japan | 3820.00.00.00 |
5-6.5% | JIS Standards | Stable tariff environment. |
📌 Conclusion:
- USA is the most expensive market for these products due to layered surtaxes. - Antifreeze (3820) is the most cost-effective classification (24%). - Brake Fluid (3819) is significantly more expensive (41.5%) if classified as hydraulic fluid.
📌 VI. Common Errors & Pitfall Guide (Blood & Tears Lessons)
❌ Error 1: Declaring "Brake Fluid" as "Antifreeze" to save tax.
👉 Consequence: Customs will inspect the SDS, find it's hydraulic, not cooling fluid, and apply 41.5% + penalties.
❌ Error 2: Declaring "Antifreeze" as "Lubricant" (3403).
👉 Consequence: Higher tax (35.2%) than necessary (24%). No benefit, just risk.
❌ Error 3: Using vague descriptions like "Car Chemical."
👉 Consequence: Customs will request additional documentation, delay clearance by 2-4 weeks, and possibly assess the highest possible duty.
❌ Error 4: Ignoring the 122 Clause.
👉 Consequence: Even if the base tariff is low, the 10% IEEPA surtax is mandatory for Chinese-origin goods.
✅ Correct Practice:
"Engine Coolant Antifreeze, Concentrate, Ethylene Glycol Based, Model XYZ, SDS Available" →
3820.00.00.00
"Automotive Brake Fluid, DOT 3 Compliant, Hydraulic, Synthetic Base, Model ABC, SDS Available" →3819.00.00.90
🎯 VII. Conclusion: Professional Declaration, Save Time & Money!
🎯 Remember the Mantra:
🔹 "Antifreeze is 24%, Brake Fluid is 41.5%. Label Clearly, Don't Guess!"
🔹 "HS Code Determines Duty, Tax Difference is 17.5%, One Mistake Costs Thousands!"
📌 Tips:
- If your products are originating from Vietnam, Mexico, Thailand, or Malaysia, you MAY be eligible to avoid the IEEPA 10% surtax, potentially lowering the total tax to ~16.5% for Antifreeze and ~31.5% for Brake Fluid.
- Recommendation: Apply for a Binding Ruling from CBP (Customs and Border Protection) before shipment if you are unsure about the classification. This provides legal certainty.
📣 Take Action Now:
📞 Contact a Professional Customs Broker + Provide Product Images + Apply for HS Code Pre-Ruling
🚀 Let your Brake Fluid & Antifreeze pass through customs smoothly, efficiently, and cost-effectively!
✨ Professional Customs Clearance Starts with Accurate Classification!
💼 Every cent of your cost is worth precise calculation!
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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.