特氟龙润滑剂
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3403195000 | 40.8% | CN | US | Official Doc |
| 3920992000 | 39.2% | CN | US | Official Doc |
| 3920995000 | 40.8% | CN | US | Official Doc |
AI Analysis
🧪 Teflon Lubricants (特氟龙润滑剂)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: Understanding "Teflon Lubricants"
Teflon (PTFE - Polytetrafluoroethylene) lubricants are high-performance fluid additives or coatings designed to reduce friction, wear, and corrosion. In international trade, the classification hinges on whether the product is a liquid/paste additive or a solid film/coating.
1. Lubricating Preparations (Liquids/Pastes/Sprays):
If the Teflon is mixed with solvents, oils, or greases to create a spray, paste, or oil additive, it falls under Chapter 34 (Wax, Lubricating Preparations). This is the most common classification for "Teflon Lubricant" in aerosol cans or bottles.
2. Plastic Films/Sheets:
If the product is a solid sheet or roll of PTFE material intended to be used as a non-stick coating substrate, it falls under Chapter 39 (Plastics and Articles Thereof). Note that true "Teflon" is PTFE, so it is classified as a plastic, not a metal coating.
⚠️ Key Distinction Point:
- If it is a liquid/spray/paste intended for application → HS Code 3403
- If it is a solid film/roll/sheet → HS Code 3920
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, here are the specific HS Codes and their rationales:
| HS Code | Product Description | Rationale for Classification | Form/State |
|---|---|---|---|
3403.19.50.00 |
Teflon Lubricants | Classified under Lubricating Preparations. The PTFE is an additive in a lubricating base (oil/solvent). | Liquid/Paste/Spray |
3920.99.50.00 |
Teflon Films | Classified as Plastic plates, sheets, film, foil, and strip, not cellular or reinforced. | Solid Film/Sheet |
3920.99.20.00 |
Teflon Films (Non-cellular/Non-reinforced) | Classified as Plastics not reinforced, laminated, or supported. Specific sub-category for non-cellular plastic films. | Solid Film/Sheet |
🔍 Key Reminder:
- Do not confuse "Teflon Spray" (HS 3403) with "PTFE Coated Fabric" (often HS 59 or 39 depending on backing).
- The data provided strictly categorizes Teflon products into Lubricating Preparations (3403) and Plastic Films (3920).
💰 III. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Time: 2025 November 10 onwards (including subsequent imports)
🎯 1. 3403.19.50.00 —— Teflon Lubricant (Lubricating Preparations)
| Item | Content |
|---|---|
| Base Tariff | 5.8% (Ad Valorem) |
| Trade War Tariff (Section 301) | +25.0% (China-specific) |
| Section 122 Tariff | +10.0% (Specific trade remedy) |
| Total Tariff Rate | 40.8% |
| Tax Calculation | CIF Value × 40.8% |
| De Minimis Eligibility | ❌ Not Eligible (Due to Section 301 & 122 surcharges) |
| Legal Basis Path | Base Tariff: 5.8% → Section 301: +25% → Section 122: +10% |
📌 Explanation:
- Base Tariff (5.8%): Standard Most Favored Nation (MFN) rate for lubricating preparations.
- Section 301 Tariff (+25%): The primary trade war tariff imposed on Chinese goods.
- Section 122 Tariff (+10%): An additional duty often applied to specific strategic or sensitive goods.
- Total Burden: 40.8% is a significant cost driver. Pre-import cost analysis is crucial.
🎯 2. 3920.99.50.00 —— Teflon Film (Plastic, Non-cellular, Unreinforced)
| Item | Content |
|---|---|
| Base Tariff | 5.8% (Ad Valorem) |
| Trade War Tariff (Section 301) | +25.0% (China-specific) |
| Section 122 Tariff | +10.0% (Specific trade remedy) |
| Total Tariff Rate | 40.8% |
| Tax Calculation | CIF Value × 40.8% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | Base Tariff: 5.8% → Section 301: +25% → Section 122: +10% |
📌 Explanation:
- Although this is a plastic product, it attracts the same total tariff burden (40.8%) as the lubricant due to the combination of base rates and Chinese-origin surcharges.
- Ensure the product is indeed a plastic film and not a metal-coated film, which might have different classifications.
🎯 3. 3920.99.20.00 —— Teflon Film (Non-cellular, Non-reinforced Plastic)
| Item | Content |
|---|---|
| Base Tariff | 4.2% (Ad Valorem) |
| Trade War Tariff (Section 301) | +25.0% (China-specific) |
| Section 122 Tariff | +10.0% (Specific trade remedy) |
| Total Tariff Rate | 39.2% |
| Tax Calculation | CIF Value × 39.2% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | Base Tariff: 4.2% → Section 301: +25% → Section 122: +10% |
📌 Explanation:
- This sub-category has a slightly lower base tariff (4.2%) compared to3920.99.50.00(5.8%).
- However, the total impact is still high (39.2%).
- Optimization Tip: If your product qualifies for this specific sub-code (non-cellular/non-reinforced), it saves 1.6% in total tariffs compared to the other plastic film code. Verify technical specifications carefully.
🛠️ IV. Customs Clearance Practical Advice (Avoiding Pitfalls)
✅ 1. Essential Documentation Checklist
| Document | Required? | Notes |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must clearly state: Chemical composition (PTFE %), state (liquid/solid), intended use. |
| ✅ Safety Data Sheet (SDS) | ✔️ | Critical for lubricants to verify flammability and hazardous material status. |
| ✅ Commercial Invoice | ✔️ | Clearly describe as "Teflon Lubricant Spray" or "PTFE Film Roll". Avoid vague terms like "Chemical". |
| ✅ Packing List | ✔️ | Detail net/gross weight, volume. |
| ✅ Certificate of Origin (CO) | ✔️ | Mandatory for verifying Chinese origin and applying surcharges. |
| ✅ Test Reports | ✔️ | For films: Thickness, tensile strength. For lubricants: Viscosity, flash point. |
✅ 2. Declaration Strategy (Key Mantras)
🔥 "State Defines Code, Origin Defines Tax!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Teflon Spray Can | 3403.19.50.00 - "Lubricating preparation containing PTFE" |
Misclassify as "Chemical" or "Plastic" → 10-15% penalty risk + wrong tax |
| PTFE Roll/Film | 3920.99.20.00 or 3920.99.50.00 - "Polytetrafluoroethylene film" |
Misclassify as "Rubber" or "Textile" → Seizure |
| Coated Fabric | NOT in Data | Do NOT use 3920/3403 if it's fabric-backed. Check Chapter 59. |
| Kit (Spray + Applicator) | Main Item Rule | Declare the lubricant if it's the dominant value/use. Don't split unless necessary. |
✅ 3. Special Handling for High-Tariff Goods
| Situation | Handling Advice |
|---|---|
| High Tariff (40.8%) | Pre-Calculate Cost: Include 40.8% in your landed cost model. Are you still competitive? |
| Section 301 Exclusion | Check if your specific HS code has any exclusions. Most PTFE products are not excluded. |
| Country of Origin | If the PTFE resin is from US/Vietnam but processed in China, origin rules apply. Generally, processing in China = Chinese Origin for these goods. |
| Hazardous Materials | Lubricants in aerosols may require Hazmat Declaration. Ensure UN packaging is used. |
🌍 V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Base Tariff | Surcharges (China) | Total Approx. | Notes |
|---|---|---|---|---|---|
| 🇺🇸 USA | 3403.19.50.00 / 3920.99.xx |
4.2% - 5.8% | +35% (301+122) | ~39-41% | High Barrier. Plan carefully. |
| 🇨🇳 China | 3403.19.50.00 / 3920.99.xx |
5.8% / 4.2% | 0% | ~5% | Low import cost for domestic use. |
| 🇪🇺 EU | 3403.90 / 3920.99 |
0% - 6.5% | 0% (Generally) | ~0-6.5% | No Section 301 equivalent. Favored market. |
| 🇬🇧 UK | 3403.19 / 3920.99 |
0% - 6.5% | 0% | ~0-6.5% | Post-Brexit, generally lower than US. |
| 🇯🇵 Japan | 3403.99 / 3920.99 |
0% - 5% | 0% | ~0-5% | Favorable for high-tech plastics/lubricants. |
📌 Conclusion:
- The USA is the most challenging market due to the ~40% total tariff burden.
- EU, UK, Japan, and China have significantly lower tariff barriers for these goods.
- Strategy: If targeting the US, consider supply chain diversification (e.g., manufacturing in Vietnam/Mexico) to avoid Section 301 tariffs, if feasible.
📌 VI. Common Mistakes & Pitfall Guide (Lessons Learned)
❌ Mistake 1: Calling it "Non-Stick Coating" without specifying state.
👉 Consequence: Customs may reject the classification or assign a higher duty rate for "Chemicals".
✅ Fix: Always specify: "Liquid Lubricant" or "Solid Plastic Film".
❌ Mistake 2: Using HS Code 3920 for Teflon Spray.
👉 Consequence: Rejection at port. Sprays are preparations, not solid plastics.
✅ Fix: Use HS Code 3403 for sprays/pastes.
❌ Mistake 3: Ignoring Section 122 Tariff.
👉 Consequence: Under-declaration of duties. The 10% add-on is often forgotten in total cost calculations.
✅ Fix: Include the 10% Section 122 in your financial model.
❌ Mistake 4: Misidentifying "Reinforced" vs. "Unreinforced" Films.
👉 Consequence: Wrong sub-code (3920.99.50 vs 3920.99.20). Small difference in base rate, but compliance risk.
✅ Fix: Check if the film has fabric/mesh backing. If yes, it might be reinforced (different code). If pure PTFE, it is unreinforced.
🎯 VII. Conclusion: Professional Clearance, Cost Optimization!
🎯 Remember the Mantra:
🔹 "Liquid = 3403, Solid = 3920. Origin = China = ~40% Tax!"
🔹 "State defines the Chapter, Origin defines the Tariff!"
📌 Pro Tip:
- If you are importing Teflon Lubricants into the US, the 40.8% total duty is substantial.
- Consider Advance Rulings from CBP (Customs and Border Protection) to confirm the HS code before shipment.
- For films, verify if
3920.99.20.00applies to save the 1.6% difference.
📣 Action Required:
📞 Contact Customs Broker: Confirm SDS requirements for lubricants.
📊 Cost Analysis: Model the 40.8% tariff impact on your profit margin.
🚀 Optimize: Explore non-China origins if margins are tight.
✨ Precision in Classification, Profit in Clearance!
💼 Every percentage point matters in international trade!
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.