无毛牛皮坯皮
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 4101501010 | 17.5% | CN | US | Official Doc |
| 4101201010 | 17.5% | CN | US | Official Doc |
| 4203290500 | 47.6% | CN | US | Official Doc |
| 4203290800 | 49.0% | CN | US | Official Doc |
| 4107117040 | 15.0% | CN | US | Official Doc |
AI Analysis
🐂 Hairless Cowhide Skins (Unprepared)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
📌 I. Product Definition & Classification: Understanding "Hairless Cowhide Skins"
"Hairless Cowhide Skins" (无毛牛皮坯皮) refers to raw hides or skins obtained from cattle, where the hair has been removed, but which have not undergone any tanning, bleaching, or further chemical treatment beyond the preservation process (such as salting or liming) intended to keep them in good condition during transport.
In international trade, the key distinction lies in the state of preservation and preparation: * "Skins/Hides" (坯皮): Raw, un-tanned, or merely preserved. They fall under Chapter 41 (Raw Hides and Skins). * "Leather" (皮革): Tanned or crusted leather. They fall under Chapter 41 (L) or Chapter 42 (Articles of Leather).
⚠️ Critical Classification Point:
- If the product is raw/un-tanned, even if hairless, it is classified as Raw Hide/Skin (HS Chapter 41, Heading 4101).
- If the product is tanned and specified for garment use, it may fall under Tanned Leather (HS Heading 4107).
- Note: The term "坯皮" (Bǐpí) in Chinese customs terminology explicitly denotes un-tanned or semi-processed raw skins, directing the classification to Heading 4101, not 4107.
📦 II. HS Code Classification Details (2026 Latest Tariff对照)
| HS Code | Product Description | Applicability | Key Feature |
|---|---|---|---|
4101.50.10.10 |
Hairless Cowhide Skins, Unprepared (Matches: "Cowhide" + "Skin/Hide" state) |
Raw hides, un-tanned, hair removed | ✅ Raw/Un-tanned |
4101.20.10.10 |
Cowhide Skins, Unprepared (Matches: "Cowhide" + "Raw State") |
Raw hides, standard classification for cattle skins | ✅ Raw/Un-tanned |
4107.11.70.40 |
Garment-Use Hairless Cowhide Leather (Matches: "Hairless" + "Garment Use") |
Tanned leather specifically for apparel | ⚠️ Tanned (Only if processed) |
4107.19.70.40 |
Other Garment-Use Hairless Cowhide Leather (Matches: "Hairless" + "Leather" + "Garment") |
Tanned leather for clothing | ⚠️ Tanned (Only if processed) |
4203.29.05.00 |
Other Articles of Apparel Clothing Accessories (Matches: "Cowhide" + "Garment Use") |
Semi-finished leather accessories or partial garments | ⚠️ Finished/Semi-finished |
🔍 Key Reminder:
- The term "坯皮" (Raw Skin) strongly points to HS 4101.50.10.10 or 4101.20.10.10.
- If the product is tanned and explicitly marketed as "Garment Use Leather", it might be classified under 4107.11.70.40 or 4107.19.70.40, but this requires proof of tanning.
- Do not misclassify raw skins as tanned leather (4107) to avoid tariffs, as customs may demand samples for chemical testing.
💰 III. 2026 Latest Tariff Rate Details (Including Surtaxes & Policy Additions)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: From November 10, 2025 (including subsequent imports)
🎯 1. 4101.50.10.10 & 4101.20.10.10 —— Raw Cowhide Skins (Unprepared)
| Item | Content |
|---|---|
| Base Tariff Rate | 0% (ad valorem) |
| Section 301 Surtax | +7.5% (USITC Footnote 9903.88.01) |
| IEEPA Surtax | +10% (Targeting China/Hong Kong products, effective Nov 10, 2025) |
| Total Tariff Rate | 17.5% |
| Tax Calculation | CIF Value × 17.5% |
| De Minimis Eligibility | ❌ Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 → IEEPA:9903.01.24 → USITC:4101.50.10.10 → FOOTNOTE:9903.88.01 |
📌 Explanation:
- "Raw hides/skins" are generally exempt from base tariffs.
- However, Section 301 Surtax of 7.5% applies to raw animal hides from China.
- IEEPA 10% is added as a targeted surcharge for Chinese origin.
- Total 17.5% is relatively moderate compared to finished goods, but still significant for low-margin raw materials.
🎯 2. 4107.11.70.40 & 4107.19.70.40 —— Tanned Garment Leather (If Applicable)
⚠️ Note: These codes apply ONLY IF the product is tanned and intended for garments. If your product is "坯皮" (raw), do NOT use these codes.
| Item | Content |
|---|---|
| Base Tariff Rate | 5% (ad valorem) |
| Section 301 Surtax | 0% (No 301 surtax for tanned leather under specific subheadings) |
| IEEPA Surtax | +10% (Targeting China/Hong Kong products) |
| Total Tariff Rate | 15.0% |
| Tax Calculation | CIF Value × 15.0% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | IEEPA:9901.25 → IEEPA:9903.01.24 → USITC:4107.11.70.40 |
📌 Explanation:
- If you can prove the product is tanned leather for garments, the total rate is 15%, which is 0.5% lower than raw skins.
- However, the risk of misclassification is high. If customs finds it's raw, they will reclassify to 4101 and charge 17.5% + penalties.
🎯 3. 4203.29.05.00 —— Articles of Apparel (Semi-finished/Accessories)
| Item | Content |
|---|---|
| Base Tariff Rate | 12.6% |
| Section 301 Surtax | +25% |
| IEEPA Surtax | +10% |
| Total Tariff Rate | 47.6% |
| Tax Calculation | CIF Value × 47.6% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | IEEPA:9903.01.25 → IEEPA:9903.01.24 → USITC:4203.29.05.00 |
📌 Warning:
- This code applies to finished or semi-finished garment accessories (e.g., belts, gloves, partially assembled leather parts).
- DO NOT USE for raw "坯皮".
- 47.6% is a high tariff rate. Misclassifying raw skins as finished goods is a common audit trigger.
🛠️ IV. Customs Clearance Practical Advice (Real-World Pitfall Avoidance)
✅ 1. Preparation Checklist (Essential Documents)
| Document | Required | Notes |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Clearly state: "Un-tanned," "Hair Removed," "Salting/Liming Process Only." |
| ✅ Photos of Raw Skin | ✔️ | Show texture, absence of tanning chemicals (no dye/stiffeners). |
| ✅ Third-Party Lab Report | ✔️ | Chemical analysis to confirm lack of tanning agents. Critical for disputes. |
| ✅ Commercial Invoice | ✔️ | Describe as "Raw Hairless Cowhide Skins, Un-tanned" (NOT "Leather"). |
| ✅ Packing List | ✔️ | Include quantity, weight, and condition (wet salted, dry, etc.). |
| ✅ Bill of Lading | ✔️ | Ensure no misleading terms like "Garment Leather." |
✅ 2. Declaration Tips (Key Mnemonics)
🔥 "Raw is Raw, Tanned is Tanned; Name Matters, Tariffs Change!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Raw, Hairless, Un-tanned | 4101.50.10.10 (17.5%) |
Mislabel as "Leather" → 15% (Risk of Audit) |
| Raw, Hairless, Un-tanned | 4101.50.10.10 (17.5%) |
Mislabel as "Finished Goods" → 47.6% |
| Tanned, for Garments | 4107.11.70.40 (15%) |
Label as "Raw Skin" → 17.5% (Overpaid, but safer) |
| Semi-finished Leather Parts | 4203.29.05.00 (47.6%) |
Label as "Raw Skin" → 17.5% (High Risk) |
✅ 3. Special Situations
| Situation | Handling Advice |
|---|---|
| Wet-Salted vs. Dry-Salted | Specify in documents. Wet-salted may have different preservation rules, but HS code remains 4101. |
| Hair Removal Method | If "Chemically Dehaired," still raw. If "Limed," still raw. Only tanning changes classification. |
| Intended Use | "For Garment Use" does not change raw skins to tanned leather. It is a commercial description, not a customs classification criterion for Chapter 41. |
| Audit Defense | Keep samples and lab reports ready. Customs may test for chromium content (absence proves raw). |
🌍 V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 4101.50.10.10 |
17.5% | None | High risk of audit; prove raw status. |
| 🇨🇳 China | 4101.50.10.10 |
0% | N/A | No surtax for raw hides. |
| 🇪🇺 EU | 4101.50.10.10 |
0% | REACH | No surtax; strict on chemical residues. |
| 🇦🇺 Australia | 4101.50.10.10 |
5% | N/A | No surtax. |
| 🇯🇵 Japan | 4101.50.10.10 |
0% | None | No surtax. |
📌 Conclusion:
- USA is the only major market with significant surtaxes (17.5%) for raw hides.
- EU, Japan, and Australia have 0% or low tariffs, making them more cost-effective for raw hide imports.
- Misclassification in the US leads to 47.6% or penalties.
📌 VI. Common Mistakes & Pitfall Guide (Lessons Learned)
❌ Mistake 1: Calling "Raw Skins" "Leather" to save 0.5%
👉 Consequence: Customs audit → 17.5% + Back Taxes + Fines!
❌ Mistake 2: Declaring "Garment Use" on Raw Skins
👉 Consequence: Customs may suspect tanning → Delay in release for testing.
❌ Mistake 3: Misclassifying Raw Skins as 4203.29.05.00
👉 Consequence: Tax jumps from 17.5% to 47.6%!
❌ Mistake 4: Ignoring "Hairless" Status
👉 Consequence: If hair is present, it might fall under 4101.20.10.10 (still 17.5%), but if hair is removed chemically, ensure documentation reflects this to avoid ambiguity.
✅ Correct Practice:
"Raw Hairless Cowhide Skins, Un-tanned, Wet-Salted, For Further Processing"
🎯 VII. Conclusion: Precise Classification, Cost Savings!
🎯 Key Takeaway:
🔹 "坯皮" = Raw = 4101.50.10.10 (17.5%)
🔹 "皮革" = Tanned = 4107.11.70.40 (15%)
🔹 "制品" = Finished = 4203.29.05.00 (47.6%)
📌 Tip:
If your product is raw, stick to 4101.50.10.10. Do not try to claim "Garment Use" to lower rates unless it is tanned. Provide lab reports proving no tanning agents are present.
📣 Immediate Action:
📞 Consult with a licensed customs broker.
📄 Prepare lab reports to prove "Un-tanned" status.
🚀 Clear customs smoothly, avoid 47.6% traps!
✨ Professional Customs Clearance Starts with Accurate Classification!
💼 Every Dollar Saved is a Dollar Earned!
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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.