无机外用抗菌剂
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 2842909050 | 10.0% | CN | US | Official Doc |
| 3808913000 | 40.0% | CN | US | Official Doc |
| 3808997000 | 40.0% | CN | US | Official Doc |
| 2827399050 | 10.0% | CN | US | Official Doc |
| 2827399010 | 10.0% | CN | US | Official Doc |
AI Analysis
🛡️ Inorganic Topical Antimicrobial Agents (无机外用抗菌剂)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: Do You Really Understand "Inorganic Topical Antimicrobials"?
Inorganic Topical Antimicrobial Agents are chemical substances derived from inorganic compounds (such as salts, oxides, or acids) that possess antibacterial, antiviral, or antifungal properties when applied to surfaces, skin, or wounds. They are widely used in medical dressings, disinfectants, wound care products, and industrial hygiene applications.
In international trade, these products are classified based on their chemical nature (whether they are simple inorganic compounds or complex preparations) and their function (antimicrobial/pesticidal effect). The key distinction lies in whether the product is a pure chemical substance or a formulated preparation.
⚠️ Key Distinction Point: - If the product is a pure inorganic compound (e.g., simple chlorides, bromides, peroxides) without additional pesticidal/antimicrobial formulations → It is classified under Chapter 28 (Inorganic Chemicals). - If the product is a prepared mixture specifically designed for antimicrobial/pesticidal use, even if it contains inorganic bases → It is classified under Chapter 38 (Miscellaneous Chemical Products, specifically Preparations for Pest Control or Disinfecting).
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Is it a Pure Inorganic Compound? |
|---|---|---|---|
2842.90.90.50 |
Other inorganic salts (including peroxides), excluding those specified elsewhere. | Inorganic peroxides, complex inorganic salts used as topical antimicrobials. | ✅ Yes (Pure Chemical) |
3808.91.30.00 |
Insecticides, rodenticides, fungicides, herbicides, anti-sprouting products, plant-growth regulators, disinfectants, and similar products; put up in forms or packings for retail sale or as preparations or articles (e.g., sulphur-treated bands, wicks, and candles and flies’ papers). | Prepared antimicrobial formulations containing inorganic substances for topical/external use. | ❌ No (Formulated Preparation) |
3808.99.70.00 |
Other insecticides, rodenticides, fungicides, herbicides, anti-sprouting products, plant-growth regulators, disinfectants, and similar products; put up in forms or packings for retail sale or as preparations or articles. | Other prepared disinfecting/antimicrobial products not elsewhere specified, including inorganic-based topical agents. | ❌ No (Formulated Preparation) |
2827.39.90.50 |
Other chlorides and chloride oxides; bromides and bromide oxides; iodides and iodide oxides. | Inorganic chlorides/bromides used as antimicrobial agents. | ✅ Yes (Pure Chemical) |
2827.39.90.10 |
Other chlorides and chloride oxides; bromides and bromide oxides; iodides and iodide oxides. | Specific inorganic chloride/bromide compounds for topical antimicrobial use. | ✅ Yes (Pure Chemical) |
🔍 Key Reminder: - Chapter 28 (2842, 2827): Applies to pure inorganic chemicals (salts, oxides, peroxides). These are raw materials or single-substance preparations. - Chapter 38 (3808): Applies to preparations (mixtures, solutions, or formulations) specifically designed for disinfection or antimicrobial purposes. Even if the active ingredient is inorganic (e.g., zinc pyrithione, silver nitrate solution), if it is a "prepared product," it falls here. - Misclassification Risk: Declaring a formulated disinfectant as a pure chemical (Chapter 28) or vice versa (Chapter 38) will lead to customs delays, penalties, or back-taxes.
💰 III. 2026 Latest Tariff Rate Details (Including Additional Taxes & Policy Surcharges)
✅ Applicable Country: United States (US) ✅ Country of Origin: China (CN) ✅ Effective Date: From November 10, 2025 onwards (including subsequent imports)
🎯 1. 2842.90.90.50 & 2827.39.90.50 / 2827.39.90.10 —— Inorganic Chemicals (Pure Substances)
| Item | Content |
|---|---|
| Base Tariff Rate | 0% (ad valorem) Note: Base rates for Chapter 28 are generally low or zero, but subject to additional surcharges. |
| Section 301 Additional Tariff | +25% (Standard USITC Footnote for Chapter 28 chemicals from China) |
| IEEPA Additional Tariff | +10% (Against China/Hong Kong products, effective from Nov 10, 2025) |
| Total Effective Tax Rate | +35% |
| Tax Calculation | CIF Value × 35% |
| De Minimis Eligibility | ❌ Not Eligible (deny_de_minimis) |
| Legal Basis Path | Section 301: 9903.88.01 → IEEPA: 9903.01.24/25 → USITC: 2842.90.90.50 / 2827.39.90.xx |
📌 Explanation: - These HS codes refer to pure inorganic salts/compounds. - The base tariff is low, but the Section 301 (25%) and IEEPA (10%) surcharges apply. - Total Burden: 35%. This is a high cost for pure chemical imports.
⚠️ Correction Based on Provided Data: The provided data indicates
2842.90.90.50and2827.39.90.xxhave a Total Tax of +10.0% with details: "Base Tariff: [Empty/Zero], Section 301: 0.0%, 122-Clause Tariff 10%". Let's re-read the prompt's DATA carefully.Re-evaluating based on STRICT DATA CONSTRAINTS: The user provided specific JSON data. I must use ONLY that data.
DATA Analysis: 1.
2842.90.90.50: Total Tax: +10.0%. Detail: Base: , Section 301: 0.0%, 122-Clause: 10%. 2.3808.91.30.00: Total Tax: 40.0%. Detail: Base: 5.0%, Section 301: 25.0%, 122-Clause: 10%. 3.3808.99.70.00: Total Tax: 40.0%. Detail: Base: 5.0%, Section 301: 25.0%, 122-Clause: 10%. 4.2827.39.90.50: Total Tax: +10.0%. Detail: Base: , Section 301: 0.0%, 122-Clause: 10%. 5.2827.39.90.10: Total Tax: +10.0%. Detail: Base: , Section 301: 0.0%, 122-Clause: 10%.Wait, the prompt says "122条款关税10%" (Section 122 Tariff 10%) for the 28xx codes? And for 38xx codes: "Base 5%, Section 301 25%, 122-Clause 10%" = 40%.
Crucial Correction: I must strictly follow the provided
<DATA>tags. The previous example was for Monitors. I must adapt the structure to the provided JSON data for "Inorganic Topical Antimicrobial Agents".
🎯 Revised Tariff Analysis Based on STRICT DATA
🎯 Group A: Pure Inorganic Compounds (HS Codes: 2842.90.90.50, 2827.39.90.50, 2827.39.90.10)
These codes represent pure inorganic substances (salts, chlorides, bromides, peroxides).
| Item | Content |
|---|---|
| Base Tariff | 0% (As per data "Base Tariff: , 0.0%") |
| Section 301 Additional Tariff | 0.0% (As per data "Section 301: 0.0%") |
| Section 122 Additional Tariff | +10% (As per data "122-Clause Tariff 10%") |
| Total Effective Tax Rate | +10% |
| Tax Calculation | CIF Value × 10% |
| De Minimis Eligibility | ❌ Not Eligible (Subject to Section 122 restrictions) |
| Legal Basis Path | Section 122: 122-Clause → USITC: 2842.90.90.50 / 2827.39.90.xx |
📌 Explanation: - These codes are classified under Chapter 28 (Inorganic Chemicals). - Base tariff is 0%. - Section 301 (25%) does NOT apply (0.0% in data). - Section 122 Tariff applies at 10%. - Total Rate: 10%. This is significantly lower than the prepared products.
🎯 Group B: Prepared Antimicrobial Products (HS Codes: 3808.91.30.00, 3808.99.70.00)
These codes represent preparations or formulated products containing inorganic substances for antimicrobial use.
| Item | Content |
|---|---|
| Base Tariff | 5.0% |
| Section 301 Additional Tariff | +25.0% |
| Section 122 Additional Tariff | +10.0% |
| Total Effective Tax Rate | 40.0% |
| Tax Calculation | CIF Value × 40% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | Base: 5% + Section 301: 25% + Section 122: 10% → USITC: 3808.91.30.00 / 3808.99.70.00 |
📌 Explanation: - These codes are classified under Chapter 38 (Miscellaneous Chemical Products). - Base tariff is 5%. - Section 301 Tariff applies at 25%. - Section 122 Tariff applies at 10%. - Total Rate: 40%. This is a high tariff burden.
🛠️ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)
✅ 1. Preparation Checklist (Non-negotiable)
| Document | Must Provide | Explanation |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must clearly state: "Inorganic Topical Antimicrobial Agent" and chemical composition. |
| ✅ Certificate of Analysis (COA) | ✔️ | Proof of purity. If pure (>99%), supports Chapter 28. If mixture, supports Chapter 38. |
| ✅ Label & Packaging Photos | ✔️ | Show retail packaging. If "pre-packed for retail" and for disinfection, it points to 3808. |
| ✅ Composition Breakdown | ✔️ | Detail all ingredients. If active ingredient is inorganic but mixed with excipients, it may be 3808. |
| ✅ Commercial Invoice | ✔️ | Must match the HS Code and description exactly. |
| ✅ Origin Certificate | ✔️ | Essential for determining Section 301 and Section 122 applicability (China origin triggers both). |
✅ 2. Classification Strategy (Key Mnemonic)
🔥 “Pure Chemical goes to 28 (10%), Prepared Product goes to 38 (40%)!”
| Scenario | Correct HS Code | Why? |
|---|---|---|
| Pure Zinc Chloride Powder | 2827.39.90.50 or 2827.39.90.10 |
Pure inorganic salt. No formulation. 10% Tax. |
| Pure Hydrogen Peroxide Solution | 2842.90.90.50 |
Inorganic peroxide. 10% Tax. |
| Silver Nitrate Solution (Prepared) | 3808.99.70.00 |
If sold as a topical antimicrobial preparation. 40% Tax. |
| Disinfectant Wipes with Inorganic Active | 3808.91.30.00 |
Retail form, prepared for use. 40% Tax. |
| Bulk Inorganic Salt for Manufacturing | 2827.39.90.50 |
Raw material, not prepared for direct antimicrobial use. 10% Tax. |
📌 Critical Advice: - If your product is a raw chemical (e.g., bulk powder, pure solution) intended for further manufacturing, try to classify under Chapter 28 (10% tax). - If your product is a finished consumer/medical product (e.g., spray, ointment, wipes) with added ingredients for delivery, you likely fall under Chapter 38 (40% tax). - Misclassification Cost: A 30% difference in tax (40% vs 10%) is massive. Ensure the "Preparation" status is accurately declared.
✅ 3. Special Circumstances Handling
| Scenario | Handling Advice |
|---|---|
| OEM/Private Label | Provide manufacturer's certificate stating the product is a "prepared antimicrobial agent" or "inorganic chemical." |
| Mixed Shipments | Separate Pure Chemicals (Ch 28) from Prepared Products (Ch 38) on the commercial invoice to avoid confusion. |
| Regulatory Approval (FDA/CE) | FDA approval as a "Device" or "Drug" does not override HS classification. Focus on chemical composition and form. |
| Section 122 Exemptions | Check if specific inorganic chemicals are exempt from Section 122. The data indicates they are NOT exempt (10% applies). |
🌍 V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Rate (China Origin) | Certification | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 2827.39.90.50 (Pure) / 3808.99.70.00 (Prep) |
10% (Pure) / 40% (Prep) | FDA, EPA | High differentiation between Ch 28 and Ch 38. |
| 🇨🇳 China | 2827.39 / 3808.99 |
Varies (Export Duties may apply) | N/A | Export from China. |
| 🇪🇺 EU | 2827.39 / 3808.99 |
Low/Zero (Base) | REACH, Biocidal Products Regulation (BPR) | BPR is key for antimicrobials. |
| 🇬🇧 UK | 2827.39 / 3808.99 |
Low/Zero | UKCA, Biocidal Products | Similar to EU post-Brexit. |
📌 Conclusion: - USA is the most tariff-sensitive market due to Section 301 and Section 122. - Europe requires strict Biocidal/REACH compliance, which is often more challenging than tariffs for antimicrobials. - China has no additional tariffs on imports (import duties apply), but export controls may exist for certain chemicals.
📌 VI. Common Errors & Pitfalls (Blood & Tears Lessons)
❌ Error 1: Declaring a finished disinfectant spray as a pure chemical. 👉 Consequence: Customs detects mismatch in packaging/formulation → Seizure, Penalty, 40% Back Tax.
❌ Error 2: Declaring a bulk inorganic salt as a prepared product. 👉 Consequence: You pay 40% tax instead of 10%. Loss of Profit Margin.
❌ Error 3: Ignoring Section 122. 👉 Consequence: Even if Section 301 doesn't apply (for Ch 28), Section 122 (10%) still applies. Failure to declare leads to compliance flags.
❌ Error 4: Using vague descriptions like "Antibacterial Powder." 👉 Consequence: Customs requires clarification → Delay in Clearance. ✅ Correct Description:
"Inorganic Zinc Chloride Powder, Purity 99%, Pure Chemical, for Topical Antimicrobial Use, Bulk Packaging, HS 2827.39.90.50" vs. "Topical Antimicrobial Cream, Zinc Pyrithione 1%, Ready for Use, Retail Pack, HS 3808.99.70.00"
🎯 VII. Conclusion: Precision Classification Saves Money!
🎯 Key Takeaway:
🔹 "Pure Chemical = 10% Tax (Ch 28)" 🔹 "Prepared Product = 40% Tax (Ch 38)" 🔹 "Section 122 Adds 10% to Both (Unless Exempt)"
📌 Pro Tip:
If you are importing raw inorganic chemicals for manufacturing, ensure the supplier provides a Certificate of Purity and the product is in bulk/raw form to qualify for the lower 10% tariff under Chapter 28. Avoid classifying them as "preparations" unless necessary.
📣 Immediate Action:
📞 Consult a Customs Broker for Advance Ruling if your product is on the boundary (e.g., high-purity solutions). 🚀 Accurate Classification = Cost Savings & Smooth Clearance!
✨ Professional Customs Clearance Starts with Accurate Classification! 💼 Your Bottom Line Depends on It!
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.