百菌清乳油
CN → USAI Analysis
🌿 Chlorothalonil EC (Emulsifiable Concentrate)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
📌 I. Product Definition & Classification: What Exactly is "Chlorothalonil EC"?
Chlorothalonil EC is a broad-spectrum, non-systemic fungicide widely used in agriculture to control fungal diseases on fruits, vegetables, nuts, and turf. The "EC" (Emulsifiable Concentrate) refers to its physical form: a liquid formulation where active ingredients are dissolved in organic solvents with emulsifiers, allowing it to mix with water to form an emulsion upon application.
In international trade, it is classified as a pesticide/herbicide/fungicide preparation, not just the raw chemical. The key distinction lies in whether it is the pure active ingredient or a formulated product for retail/use.
⚠️ Key Distinction:
- Pure Chemical (Technical Grade): If it is >90% purity Chlorothalonil powder/granules without formulation → Often classified under chemical intermediates or specific pesticide chapters depending on country.
- Formulated Product (EC): Mixed with solvents/emulsifiers for direct agricultural use → Must be classified under HS Code 3808.
- Bio-pesticides: If derived from natural sources with specific biological action → May fall under different codes, but synthetic Chlorothalonil is strictly 3808.
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Formulation Type |
|---|---|---|---|
3808.93.00.00 |
Pesticides, insecticides, fungicides, herbicides (others) | Chlorothalonil EC, ready-to-use agricultural formulations | ✅ Liquid EC |
2904.90.00.00 |
Halogenated derivatives of hydrocarbons (organic chemicals) | Technical Grade Chlorothalonil (pure active ingredient, >90%) | ❌ Pure Chemical |
3808.94.00.00 |
Other pesticides (not insecticides/fungicides) | Other non-specific agrochemicals | ✅ Formulated |
3824.99.99.00 |
Prepared binding agents for foundry molds, chemical products (n.e.c.) | Misclassification risk if labeled incorrectly | ❌ Avoid |
🔍 Critical Reminder:
- Most Importers of "Chlorothalonil EC" MUST use3808.93.00.00.
- Do NOT classify EC formulations under chemical chapters (29xx) unless they are pure technical-grade powders not intended for immediate use.
- The presence of solvents and emulsifiers pushes the classification firmly into Chapter 38 (Miscellaneous Chemical Products).
💰 III. 2026 Latest Tariff Rate Details (Including Surtax, Policy Surcharges)
✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN)
✅ Effective Date: From November 10, 2025 (including subsequent imports)
🎯 1. 3808.93.00.00 —— Fungicides (Chlorothalonil EC Formulation)
| Item | Content |
|---|---|
| Base Tariff Rate | 5.7% (ad valorem) |
| USITC Surtax (Section 301) | +25% |
| IEEPA Surtax | +10% (For China/HK products, effective Nov 10, 2025) |
| Total Effective Rate | 40.7% |
| Tax Calculation | CIF Value × 40.7% |
| De Minimis Eligibility | ❌ Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.24 → USITC:3808.93.00.00 → FOOTNOTE:9903.88.01 |
📌 Explanation:
- "USITC Surtax 25%": Comes from Section 301 of the Trade Act, targeting Chinese-made chemical preparations.
- "IEEPA 10%": Additional levy under the International Emergency Economic Powers Act, specifically targeting agricultural chemicals from China due to strategic resource concerns.
- Combined Total: 40.7%. This is a high tariff burden, significantly impacting profit margins.
🎯 2. 2904.90.00.00 —— Pure Chlorothalonil (Technical Grade)
| Item | Content |
|---|---|
| Base Tariff Rate | 5.7% |
| USITC Surtax (Section 301) | +25% |
| IEEPA Surtax | +10% |
| Total Effective Rate | 40.7% |
| Tax Calculation | CIF Value × 40.7% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | Same as above |
📌 Note:
- Even if you import the pure active ingredient, the tariff rate is identical to the formulated EC product in this context.
- However, regulatory requirements differ: Pure chemicals may require more complex chemical safety data sheets (SDS), while EC products require pesticide registration documents.
🛠️ IV. Customs Clearance Practical Advice (实战避坑指南)
✅ 1. Required Documentation Checklist (None of the following are optional)
| Document | Required | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must include CAS number (1685-83-6), purity, formulation type (EC), and active ingredient percentage. |
| ✅ Pesticide Registration Certificate (EPA) | ✔️ | CRITICAL: Must have valid EPA registration for the specific brand/formulation in the US. |
| ✅ Safety Data Sheet (SDS) | ✔️ | Must comply with OSHA HazCom Standard (GHS format). |
| ✅ Commercial Invoice | ✔️ | Clearly state "Chlorothalonil Emulsifiable Concentrate, Fungicide, CAS 1685-83-6". |
| ✅ Certificate of Origin (CO) | ✔️ | If not Chinese origin, may qualify for different rates (e.g., Vietnam, India). |
| ✅ Packaging Declaration | ✔️ | Confirm packaging meets DOT/IATA hazardous material regulations (if applicable). |
✅ 2. Declaration Tips (Key Mantras)
🔥 "Formulation is King, EPA is Mandatory, CAS Must Match, Tariff is High!"
| Scenario | Correct Declaration Method | Wrong Practice |
|---|---|---|
| EC Formulation | 3808.93.00.00 + EPA Reg Number |
Mislabeling as "Industrial Cleaner" → Customs Hold |
| Pure Chemical Powder | 2904.90.00.00 + Pure >90% |
Labeling pure chemical as "Ready-to-use Fungicide" → Misclassification |
| Bundled with Sprayers | Declare EC separately | Bundling → Complex valuation, potential duty evasion flags |
| Import from Non-China | 3808.93.00.00 + No IEEPA Surtax |
Assuming all imports have 10% IEEPA → Overpayment |
✅ 3. Special Case Handling
| Scenario | Handling Advice |
|---|---|
| EPA Non-Compliance | Without valid EPA registration, goods will be seized or destroyed. Ensure label matches EPA approval exactly. |
| Private Labeling | If you repackage bulk EC into smaller bottles, the importer of record must have their own EPA registration or act as a labeler under the manufacturer’s. |
| Hazardous Materials | EC formulations contain organic solvents. Ensure packaging is UN-certified for hazardous liquids. Provide MSDS/SDS. |
| Anti-Dumping/Countervailing Duties | Chlorothalonil may be subject to anti-dumping investigations from other jurisdictions. Check specific country rules (e.g., EU has different rules). |
🌍 V. Global Main Market Customs Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification Requirements | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3808.93.00.00 |
40.7% (Total) | EPA Registration + SDS | High regulatory barrier |
| 🇨🇳 China | 3808.93.00.00 |
5% | Pesticide Registration (China) | Domestic trade follows MOA rules |
| 🇪🇺 EU | 3808.94.00.00 |
6.5% + Anti-dumping | EU Pesticide Regulation (EC 1107/2009) | Anti-dumping duties may apply for Chinese Chlorothalonil |
| 🇦🇺 Australia | 3808.93.00.00 |
5% | APVMA Registration | Strict chemical management laws |
| 🇯🇵 Japan | 3808.93.00.00 |
5% | JAS/MHLW Standards | MRLs (Max Residue Limits) strictly enforced |
📌 Conclusion:
- USA: Highest tariff burden (40.7%) due to Section 301 + IEEPA. EPA compliance is non-negotiable.
- EU: Watch out for Anti-Dumping Duties on Chlorothalonil from China, which can be significant.
- Other Markets: Generally lower tariffs but strict MRL (Maximum Residue Limit) and registration requirements.
📌 VI. Common Mistakes & Pitfalls (Blood & Tears Lessons)
❌ Mistake 1: Labeling EC as "Industrial Solvent"
👉 Consequence: Customs Seizure for misdeclaration of pesticide. Heavy fines.
❌ Mistake 2: Importing without EPA Registration
👉 Consequence: Goods Destroyed at port. No appeal possible.
❌ Mistake 3: Ignoring the CAS Number (1685-83-6)
👉 Consequence: Customs may classify under wrong heading (e.g., 29xx), leading to post-entry audits and penalties.
❌ Mistake 4: Assuming "EC" means non-hazardous
👉 Consequence: EC contains flammable solvents. Improper packaging leads to rejection by carrier or safety violations.
✅ Correct Practice:
"Chlorothalonil EC, Fungicide, CAS 1685-83-6, EPA Reg. No. [XXXXX-XX], HS Code 3808.93.00.00, 40.7% Duty Applicable"
🎯 VII. Conclusion: Professional Declaration, Save Costs, Ensure Compliance!
🎯 Remember the Mantra:
🔹 "EC is Pesticide, HS 3808 is King, EPA is Mandatory, 40.7% is the Price!"
🔹 "HS Code determines duty, EPA determines legality, CAS determines truth!"
📌 Tips:
- If your Chlorothalonil is originated from India, Brazil, or Vietnam, you can avoid the 10% IEEPA surtax, reducing the total tariff to 30.7%.
- Consider supply chain diversification to non-China origins to save 10% on CIF value.
- Always apply for Advance Ruling if your formulation changes or if you are unsure about EPA label compliance.
📣 Immediate Action:
📞 Contact EPA-licensed customs brokers + Provide SDS + Verify EPA Registration Number
🚀 Let your Chlorothalonil clear smoothly, avoid seizures, and maximize profit margins!
✨ Professional Clearance Starts with Precise Classification!
💼 Every Percent of Duty Saved is Pure Profit!
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.