无机杀菌剂涂抹剂
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 |
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AI Analysis
🧪 Inorganic Biocide Paste/Topping (无机杀菌剂涂抹剂)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
📌 I. Product Definition & Classification: Do You Really Understand "Inorganic Biocide Paste"?
"Inorganic Biocide Paste" (无机杀菌剂涂抹剂) refers to a chemical preparation primarily composed of inorganic salts, designed for sterilization, disinfection, or fungal control. The key characteristics are: * Composition: Inorganic substances (e.g., hypochlorites, chlorites, other inorganic salts). * Form: Paste, cream, or topical application (not a powder, liquid spray, or gas). * Function: Killing bacteria, fungi, or other microorganisms.
⚠️ Critical Distinction:
- If the product is purely chemical (inorganic salt) without specific pesticide registration, it may fall under Chapter 28 (Inorganic Chemicals).
- If the product is explicitly labeled as a biocide/fungicide with specific pesticidal properties, it typically falls under Chapter 38 (Miscellaneous Chemical Products).
- The "Paste" form is a physical state and does not change the chemical nature, but it must be compatible with the HS code description.
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, there are 5 potential HS Codes identified for this product. The classification depends on the primary function and specific chemical composition.
| HS Code | Product Description | Matching Logic (Why it fits) | Total Tax Rate |
|---|---|---|---|
| 2828.10.00.00 | Inorganic Hypochlorites and Chlorites | The name "Inorganic" suggests the core ingredient is a hypochlorite or chlorite salt. "Paste" is just a form, not conflicting with the chemical category. | 37.4% |
| 2827.39.90.50 | Other Chlorides, Bromides, Iodides | Biocides are often inorganic chemicals. If the active ingredient is a chloride-based inorganic compound, this "catch-all" for chlorides applies. No conflict with "Paste" form. | +10.0% |
| 3808.92.30.00 | Fungicides, Containing Inorganic Substances | Explicitly matches "Inorganic" material + "Biocide" (fungicide/bactericide) purpose. This is a strong match if the product is registered as a pesticide/fungicide. | 40.0% |
| 3808.99.70.00 | Other Biocides (Including Rodenticides, Fungicides, etc.) | Directly matches "Biocide" purpose and "Inorganic" material. This is a broad category for biocides not specifically listed elsewhere. | 40.0% |
| 2828.90.00.00 | Other Inorganic Salts (e.g., Hypochlorites/Chlorites) | Similar to 2828.10, but if it doesn't fit the specific hypochlorite/chlorite definition strictly, it falls under "Other Inorganic Salts." "Paste" form is acceptable. | 38.7% |
🔍 Key Insight:
- Chapter 28 (2828): Focuses on the chemical nature (Inorganic Salts). Lower base tariffs but high USITC/IEEPA add-ons.
- Chapter 38 (3808): Focuses on the function (Biocide). Higher base tariffs (5% vs 2.4%-3.7%) but same add-ons.
- Best Fit: If the product is a pesticide/registered biocide, 3808.92.30.00 or 3808.99.70.00 is more accurate. If it’s a pure chemical raw material for disinfection, 2828.10.00.00 is preferred.
💰 III. 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN)
✅ Effective Date: November 10, 2025 (and subsequent imports)
🎯 1. 2828.10.00.00 & 2828.90.00.00 – Inorganic Chemicals
| Item | Details |
|---|---|
| Base Tariff | 2.4% (for 2828.10) / 3.7% (for 2828.90) |
| USITC Surtax (Section 301) | +25% |
| IEEPA Surtax (China-specific) | +10% |
| Total Tax Rate | 37.4% (for 2828.10) / 38.7% (for 2828.90) |
| Tax Calculation | CIF Value × Total Rate |
| De Minimis Exemption | ❌ Not Eligible (denied for these HS codes) |
| Legal Basis Path | IEEPA:9903.01.25 → USITC:2828.10.00.00 → FOOTNOTE:9903.88.01 |
📌 Explanation:
- Base Tariff: Low, as these are raw chemicals.
- Surtaxes: High due to Section 301 and IEEPA provisions targeting Chinese goods.
- Impact: Nearly 40% of the CIF value is tax. This significantly impacts profit margins for chemical imports.
🎯 2. 3808.92.30.00 & 3808.99.70.00 – Biocides
| Item | Details |
|---|---|
| Base Tariff | 5.0% |
| USITC Surtax (Section 301) | +25% |
| IEEPA Surtax (China-specific) | +10% |
| Total Tax Rate | 40.0% |
| Tax Calculation | CIF Value × 40% |
| De Minimis Exemption | ❌ Not Eligible |
| Legal Basis Path | IEEPA:9903.01.25 → USITC:3808.99.70.00 → FOOTNOTE:9903.88.01 |
📌 Explanation:
- Base Tariff: Higher than Chapter 28 (5% vs ~2.4-3.7%).
- Surtaxes: Same high surtaxes.
- Total: 40.0% is the highest among all options.
- Why: Biocides are often considered "finished chemical products" with regulatory requirements, hence the higher base rate.
🎯 3. 2827.39.90.50 – Other Chlorides
| Item | Details |
|---|---|
| Base Tariff | 0% (Assumed based on "+10.0%" total) |
| USITC Surtax | 0% (Not listed in tax detail for this code in the source) |
| IEEPA Surtax | +10% |
| Total Tax Rate | 10.0% |
| Tax Calculation | CIF Value × 10% |
| De Minimis Exemption | ❓ Unclear (Source does not specify, but likely subject to IEEPA) |
| Legal Basis Path | IEEPA:9901.25 → USITC:2827.39.90.50 |
📌 Explanation:
- Lowest Tax: At 10.0%, this is the most cost-effective if applicable.
- Risk: This code is a "catch-all" for chlorides. If the product is not a chloride, or if it’s clearly a biocide, customs may reclassify it to Chapter 38 (40% tax).
- Use Case: Only use if the product is a simple inorganic chloride salt with incidental disinfectant properties, not a registered biocide.
🛠️ IV. Customs Clearance Practical Advice (Real-World Pitfall Avoidance Guide)
✅ 1. Documentation Checklist (Mandatory)
| Document | Required | Notes |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must detail chemical composition, concentration, and active ingredients. |
| ✅ SDS (Safety Data Sheet) | ✔️ | Required for all chemical imports. Must align with HS code classification. |
| ✅ EPA Registration Number | ✔️ | If classified under 3808 (Biocide), EPA registration is mandatory in the US. No EPA number = Detention/Rejection. |
| ✅ Commercial Invoice | ✔️ | Must clearly state: "Inorganic Biocide Paste," HS Code, and Country of Origin (China). |
| ✅ Packing List | ✔️ | Detail weight, dimensions, and quantity. |
| ✅ Certificate of Origin (CO) | ✔️ | For tariff verification. |
⚠️ Critical Note:
- If you declare under 3808.92.30.00 or 3808.99.70.00, the US EPA requires the product to be registered as a pesticide/biocide. If not registered, it will be seized.
- If you declare under 2828, you must prove it is a chemical raw material, not a finished pesticide. If it’s a finished product, EPA registration may still be required.
✅ 2. Declaration Strategy (Key Tips)
🔥 "Function Defines Code, EPA Defines Compliance, Origin Defines Tax!"
| Scenario | Recommended HS Code | Risk Level | Notes |
|---|---|---|---|
| Registered Biocide (Finished Product) | 3808.92.30.00 or 3808.99.70.00 |
⚠️ High | Must have EPA Reg #. Tax: 40%. |
| Raw Chemical (Inorganic Salt) | 2828.10.00.00 or 2828.90.00.00 |
✅ Medium | No EPA Reg needed if for industrial use only. Tax: 37.4%-38.7%. |
| Simple Chloride Salt | 2827.39.90.50 |
⚠️ High Risk | Tax: 10%. But customs may challenge if it’s clearly a biocide. |
✅ 3. Special Case Handling
| Scenario | Handling Advice |
|---|---|
| OEM/White Label Products | Provide a letter of authorization from the brand owner. Ensure the EPA Reg # is on the label if classified under 3808. |
| Mixed Shipments | Do not mix "Registered Biocides" with "Raw Chemicals." Different HS codes require different documentation. |
| Small Quantity (Sample) | Even small quantities require proper declaration. De Minimis ($800) does not apply to these HS codes. |
| Labeling Requirements | US EPA requires specific labeling for biocides (active ingredients, EPA Reg #, caution statements). Non-compliant labels = Rejection. |
🌍 V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3808.92.30.00 / 2828.10.00.00 |
37.4% - 40.0% | EPA Registration | High tariffs + strict EPA rules. |
| 🇨🇳 China | 3808.92.30.00 / 2828.10.00.00 |
5% - 10% | Agrochemical Registration | Lower base tariffs, but strict domestic registration. |
| 🇪🇺 EU | 3808.92.30.00 |
6.5% | BPR (Biocidal Products Regulation) | EU has its own biocide regulation (BPR). EPA registration is not accepted. |
| 🇬🇧 UK | 3808.92.30.00 |
6.5% | UK BPR | Post-Brexit, UK has its own biocide registration. |
| 🇯🇵 Japan | 3808.92.30.00 |
5% | Ministry of Agriculture (MAFF) | Strict registration for biocides. |
📌 Conclusion:
- USA is the most challenging market due to high tariffs (37-40%) and strict EPA requirements.
- EU/UK have lower base tariffs but equally strict biocide regulations (BPR).
- China has lower tariffs but requires domestic registration for biocides.
📌 VI. Common Mistakes & Pitfall Avoidance (Blood-Teaching Lessons)
❌ Mistake 1: Declaring a Registered Biocide under 2828 (Chemicals) to avoid EPA registration.
👉 Consequence: Customs will detect the biocidal function and reclassify to 3808, leading to penalties, back taxes, and product seizure.
❌ Mistake 2: Importing without EPA Registration under 3808.
👉 Consequence: Immediate detention by CBP and EPA. Product may be destroyed or re-exported at your cost.
❌ Mistake 3: Using "Biocide Paste" as a generic term without specifying active ingredients.
👉 Consequence: Customs may require additional documentation or samples for testing, causing delays.
❌ Mistake 4: Ignoring IEEPA 10% surtax for Chinese origin.
👉 Consequence: Underpayment of duties, leading to interest and penalties.
✅ Correct Approach:
"Inorganic Hypochlorite Paste, EPA Reg # 12345-67, Active Ingredient: Sodium Hypochlorite 5%, Model XYZ, Origin: China, HS Code: 3808.92.30.00"
🎯 VII. Conclusion: Precision Classification, Risk Mitigation, Cost Optimization!
🎯 Remember the Mantra:
🔹 "Function First, EPA Second, Tax Third!"
🔹 "HS Code Determines Duty, EPA Determines Legality!"📌 Pro Tip:
- If your product is a simple inorganic salt (e.g., Sodium Hypochlorite) for industrial water treatment, try to classify under 2828 to avoid EPA registration (if legally permissible).
- If it’s a consumer-facing biocide, you must have EPA registration and classify under 3808.
- Pre-shipment Consultation: Engage a licensed customs broker and EPA regulatory consultant before shipping.
📣 Immediate Action:
📞 Contact a Licensed Customs Broker + Provide SDS & EPA Reg # + Apply for Pre-Ruling (if possible)
🚀 Ensure Compliance, Avoid Seizure, Maximize Profit!
✨ Professional Clearance Starts with Accurate Classification!
💼 Every Dollar of Duty 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.