制动液防冻液
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3820000000 | 24.0% | CN | US | Official Doc |
| 3403191000 | 35.2% | CN | US | Official Doc |
| 3819000090 | 16.5% | CN | US | Official Doc |
| 3819000010 | 41.5% | CN | US | Official Doc |
| 3819000090 | 16.5% | CN | US | Official Doc |
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AI Analysis
🚗 制动液 & 防冻液 (Brake Fluid & Coolant/Antifreeze)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: Do You Really Understand "Brake Fluid" & "Coolant"?
In international trade, Brake Fluid and Coolant/Antifreeze are often grouped together due to their liquid state, but their chemical composition and functional definitions lead to different HS Code classifications. The core distinction lies in whether they are classified as Anti-icing/Anti-freezing agents or Lubricating/Functional Liquid Preparations.
⚠️ Key Distinction Point:
- If the product is primarily defined as Antifreeze/Anti-icing liquid → It may fall under 3820.00.00.00.
- If the product is defined as a Lubricant/Functional Liquid containing petroleum/mineral oils → It may fall under 3403.19.10.00.
- If the product is specifically Hydraulic Brake Fluid (for braking systems) → It falls under 3819.00.00.10 or 3819.00.00.90.
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, here are the specific HS Codes and their corresponding rationales for Brake Fluid and Coolant.
| HS Code | Product Description | Rationale from Data | Total Tax Rate |
|---|---|---|---|
3820.00.00.00 |
Anti-freezing/Anti-icing Liquids | "Brake fluid and coolant are classified as anti-freezing/anti-icing agents, in liquid form, with no material conflict." | 24.0% |
3403.19.10.00 |
Lubricating/Functional Liquid Preparations | "Brake fluid and coolant belong to lubricating and functional liquid preparations, containing petroleum oil or mineral oil components, fitting the definition of lubricating preparations." | 35.2% |
3819.00.00.90 |
Other Hydraulic Transmission Fluids (General) | "Brake fluid corresponds to hydraulic brake fluid usage, liquid form fits hydraulic transmission fluid attributes, belongs to other catch-all category." | 16.5% |
3819.00.00.10 |
Hydraulic Brake Fluid (Specific) | "Brake fluid directly corresponds to the classification of hydraulic brake fluid usage, match successful." | 41.5% |
3819.00.00.90 |
Hydraulic Transmission Fluid (Repeat) | "Brake fluid corresponds to hydraulic brake fluid usage, fits hydraulic transmission fluid attributes, no material conflict." | 16.5% |
🔍 Important Note:
- Brake Fluid has two potential classifications:
1. Specific:3819.00.00.10(Direct match for hydraulic brake fluid) → 41.5%
2. General/Catch-all:3819.00.00.90(Other hydraulic transmission fluids) → 16.5%
- Coolant/Antifreeze can be classified as:
1. Anti-icing Agent:3820.00.00.00→ 24.0%
2. Lubricant/Functional Liquid:3403.19.10.00→ 35.2%
- Decision Factor: The chemical composition (presence of petroleum/mineral oil) and primary function (lubrication vs. anti-freezing) determine the correct code.
💰 III. 2026 Latest Tariff Rate Details (Including Surcharges & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: From Nov 10, 2025 (including subsequent imports)
🎯 1. 3820.00.00.00 —— Anti-freezing/Anti-icing Liquids
| Item | Content |
|---|---|
| Base Tariff | 6.5% |
| USITC Surcharge (Section 301) | +7.5% |
| IEEPA Surcharge (122 Clause) | +10% |
| Total Tariff Rate | 24.0% |
| Tax Calculation | CIF Value × 24% |
| De Minimis Exemption | ❌ Not Applicable (deny_de_minimis) |
| Legal Basis Path | Base: 6.5% → Section 301: 7.5% → IEEPA: 10% |
📌 Explanation:
- This code applies if the product is primarily defined as an anti-freeze or anti-icing agent. - The total tax of 24% is a combination of base tariff, Section 301 surcharge, and IEEPA surcharge. - Critical: Do not underestimate the 10% IEEPA surcharge on Chinese-origin goods.
🎯 2. 3403.19.10.00 —— Lubricating/Functional Liquid Preparations
| Item | Content |
|---|---|
| Base Tariff | 0.2% |
| USITC Surcharge (Section 301) | +25.0% |
| IEEPA Surcharge (122 Clause) | +10% |
| Total Tariff Rate | 35.2% |
| Tax Calculation | CIF Value × 35.2% |
| De Minimis Exemption | ❌ Not Applicable (deny_de_minimis) |
| Legal Basis Path | Base: 0.2% → Section 301: 25.0% → IEEPA: 10% |
📌 Explanation:
- This code applies if the product contains petroleum oil or mineral oil components and is classified as a lubricant or functional liquid preparation. - The high Section 301 surcharge of 25% significantly increases the cost. - Critical: If your coolant/brake fluid has high mineral oil content, this code may be triggered, leading to a 35.2% tax rate.
🎯 3. 3819.00.00.90 —— Other Hydraulic Transmission Fluids (General)
| Item | Content |
|---|---|
| Base Tariff | 6.5% |
| USITC Surcharge (Section 301) | +0.0% |
| IEEPA Surcharge (122 Clause) | +10% |
| Total Tariff Rate | 16.5% |
| Tax Calculation | CIF Value × 16.5% |
| De Minimis Exemption | ❌ Not Applicable (deny_de_minimis) |
| Legal Basis Path | Base: 6.5% → Section 301: 0.0% → IEEPA: 10% |
📌 Explanation:
- This code is a catch-all for hydraulic transmission fluids not specifically listed elsewhere. - Lowest Tariff Option: At 16.5%, this is the most cost-effective option for brake fluid if it can be classified here. - Condition: The product must be clearly defined as a hydraulic transmission fluid without being specifically classified as "hydraulic brake fluid" (which has its own code).
🎯 4. 3819.00.00.10 —— Hydraulic Brake Fluid (Specific)
| Item | Content |
|---|---|
| Base Tariff | 6.5% |
| USITC Surcharge (Section 301) | +25.0% |
| IEEPA Surcharge (122 Clause) | +10% |
| Total Tariff Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Exemption | ❌ Not Applicable (deny_de_minimis) |
| Legal Basis Path | Base: 6.5% → Section 301: 25.0% → IEEPA: 10% |
📌 Explanation:
- This code is the most specific for hydraulic brake fluid. - Highest Tariff Option: At 41.5%, this is the most expensive option due to the 25% Section 301 surcharge. - Critical: If the customs authority strictly classifies your product as "hydraulic brake fluid," this code will be mandatory, resulting in a 41.5% tax rate.
🛠️ IV. Customs Clearance Practical Advice (Combat Pitfall Guide)
✅ 1. Document Checklist (All Required)
| Document | Mandatory | Description |
|---|---|---|
| ✅ Product Spec Sheet | ✔️ | Must include chemical composition, viscosity, freezing point, and primary function. |
| ✅ Formula/Composition Analysis | ✔️ | Critical to determine if it contains petroleum/mineral oil (for 3403 classification) or is purely synthetic/anti-freeze (for 3820/3819). |
| ✅ Product Photos (Label/Nameplate) | ✔️ | Clear view of product name, brand, and intended use (e.g., "Brake Fluid" vs. "Engine Coolant"). |
| ✅ Third-Party Test Report | ✔️ | ASTM, SAE, or equivalent tests proving fluid properties. |
| ✅ Commercial Invoice | ✔️ | Must accurately describe the product (e.g., "Hydraulic Brake Fluid" or "Engine Coolant/Antifreeze"). |
| ✅ Certificate of Origin (CO) | ✔️ | Required for determining origin-based surcharges. |
| ✅ Packing List | ✔️ | Detailing quantity, weight, and packaging. |
✅ 2. Declaration Tips (Key Mantra)
🔥 "Define Function, Check Composition, Avoid Over-Specificity, Lower Tax!"
| Scenario | Correct Declaration | Error to Avoid |
|---|---|---|
| Brake Fluid | Declare as "Hydraulic Transmission Fluid" if possible → 3819.00.00.90 (16.5%) |
Directly declaring as "Brake Fluid" → 3819.00.00.10 (41.5%) |
| Coolant/Antifreeze | Declare as "Anti-icing/Anti-freezing Liquid" → 3820.00.00.00 (24.0%) |
Declaring as "Lubricant" if it doesn't contain mineral oil → 3403.19.10.00 (35.2%) |
| Coolant with Mineral Oil | Declare as "Lubricating/Functional Liquid" → 3403.19.10.00 (35.2%) |
Misdeclaring as anti-freeze to get 24% → Penalty for misclassification |
✅ 3. Special Case Handling
| Scenario | Handling Advice |
|---|---|
| Multi-purpose Fluid | If the product serves both as brake fluid and coolant, provide technical justification for the primary function. |
| OEM Private Label | Ensure the supplier's formula sheet is provided to match the declared HS Code. |
| Chemical Composition Change | If the product changes from petroleum-based to synthetic, the HS Code may shift from 3403 to 3819 or 3820. |
| Pre-Ruling Request | For large volumes, apply for a Customs Binding Ruling to confirm the HS Code and avoid post-import audits. |
🌍 V. Global Market Customs Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Rate | Certification Required | Remarks |
|---|---|---|---|---|
| 🇺🇸 USA | 3819.00.00.90 (Optimal) |
16.5% | No specific | 3819.00.00.10 is 41.5% |
| 🇺🇸 USA | 3820.00.00.00 |
24.0% | No specific | For anti-freeze only |
| 🇺🇸 USA | 3403.19.10.00 |
35.2% | No specific | For mineral oil-based fluids |
| 🇨🇳 China | 3819.00.00.00 |
Low | CCC (if applicable) | Lower base tariffs, no Section 301 |
| 🇪🇺 EU | 3819.00.00.00 |
0-6% | REACH + CLP | No Section 301 surcharges |
📌 Conclusion:
- USA is the most complex market due to Section 301 and IEEPA surcharges. - Optimal Strategy for USA: Aim for3819.00.00.90(16.5%) for brake fluid by emphasizing "hydraulic transmission fluid" rather than "brake fluid" if technically justifiable. - Alternative: For coolant,3820.00.00.00(24.0%) is often more favorable than3403.19.10.00(35.2%).
📌 VI. Common Mistakes & Pitfalls (Blood Lessons)
❌ Mistake 1: Declaring "Brake Fluid" as "Lubricant" to avoid high tariffs
👉 Consequence: If the product contains mineral oil, customs may reclassify it → Back taxes + fines.
❌ Mistake 2: Using "Coolant" and "Antifreeze" interchangeably without specifying composition
👉 Consequence: Ambiguity leads to customs audit → Delayed clearance.
❌ Mistake 3: Ignoring the 10% IEEPA Surcharge in cost calculations
👉 Consequence: Underestimating landed cost → Profit margin erosion.
❌ Mistake 4: Failing to provide Composition Analysis
👉 Consequence: Customs cannot verify if it falls under 3403 (oil-based) or 3819/3820 (synthetic/anti-freeze) → Dispute over HS Code.
✅ Correct Approach:
"Hydraulic Transmission Fluid, Synthetic, Non-Petroleum Based, For Automotive Brake Systems, Model XYZ, SAE J1703 Certified"
🎯 VII. Conclusion: Precise Classification, Save Costs, Smooth Clearance!
🎯 Remember the Mantra:
🔹 "Hydraulic Fluid, Not Brake Fluid → 16.5%!"
🔹 "Anti-Freeze, Not Lubricant → 24.0%!"
🔹 "Mineral Oil Present → 35.2%!"
🔹 "Direct Brake Fluid → 41.5%!"
📌 Pro Tip:
- If your product is synthetic and non-petroleum-based, emphasize this in the documentation to avoid 3403.19.10.00 (35.2%).
- For Brake Fluid, consult with a customs broker to see if 3819.00.00.90 (16.5%) is defensible based on technical specs.
- Consider Advance Ruling for high-volume shipments to lock in the HS Code and tax rate.
📣 Take Action Now:
📞 Contact a Professional Customs Broker + Provide Technical Data Sheets + Apply for HS Code Pre-Ruling
🚀 Ensure your Brake Fluid & Coolant clears customs efficiently, minimizing tax burden and maximizing profit!
✨ Professional Clearance Starts with Accurate Classification!
💼 Every cent of tax saved is pure profit earned!
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) — 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.