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CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3926909989 | 22.8% | CN | US | Official Doc |
| 4205001000 | 35.0% | CN | US | Official Doc |
| 4205000500 | 37.9% | CN | US | Official Doc |
| 6813810050 | 35.0% | CN | US | Official Doc |
| 6813890050 | 35.0% | CN | US | Official Doc |
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AI Analysis
🛑 Synthetic Leather Friction Pads: HS Code Classification & US Customs Clearance Guide (2026)
🌐 HS Code Reference & Clearance Strategy | 2026 Latest Tariff Analysis | High-Tax Risk Alert
📌 I. Product Definition & Core Classification Dilemma: Is it Plastic or Leather?
Synthetic Leather Friction Pads (often used for brakes, clutches, or industrial machinery) are a high-risk classification item for US Customs. They sit at the intersection of Chapter 39 (Plastics) and Chapter 42 (Leather Articles), or even Chapter 68 (Mineral Products).
The core dispute lies in the material composition and end-use: 1. Plastic-Based: If the substrate is primarily synthetic polymer/resin with friction modifiers → Chapter 39. 2. Leather/Composite-Based: If the base is layered leather, paper, or asbestos-free composite with a leather-like surface → Chapter 42 or Chapter 68. 3. Brake-Specific: If designed specifically for vehicle/aircraft braking systems → Chapter 68.
⚠️ Critical Warning:
- Misclassifying "Synthetic Leather" as "Plastic" (3926) can lead to severe penalties if Customs determines it is a "Friction Material" (6813/4205).
- Chapter 68 (Asbestos-free friction materials) and Chapter 42 (Leather articles) carry significantly higher tariffs due to Section 301 and IEEPA provisions.
- Do not assume "Synthetic" always means "Plastic Chapter." Function dictates classification for friction pads.
📦 II. HS Code Classification Matrix (2026 Data Source)
Based on the provided data, here are the 5 specific HS Codes applicable to Synthetic Leather Friction Pads, ranked by tariff impact.
| HS Code | Classification Summary | Total Tax Rate | Key Tax Components |
|---|---|---|---|
| 3926.90.99.89 | Other Plastic Articles (Classified as a Plastic Product) |
22.8% | Base: 5.3% + Sec 301: 7.5% + IEEPA: 10% |
| 4205.00.10.00 | Leather Articles for Mechanical Use (General Mechanical Leather) |
35.0% | Base: 0.0% + Sec 301: 25.0% + IEEPA: 10% |
| 4205.00.05.00 | Leather for Conversion to Belts (Transmission Belt Materials) |
37.9% | Base: 2.9% + Sec 301: 25.0% + IEEPA: 10% |
| 6813.81.00.50 | Asbestos-Free Brake Lining (Non-Asbestos Brake Pads) |
35.0% | Base: 0.0% + Sec 301: 25.0% + IEEPA: 10% |
| 6813.89.00.50 | Other Asbestos-Free Friction Materials (Non-Aviation Use) |
35.0% | Base: 0.0% + Sec 301: 25.0% + IEEPA: 10% |
🔍 Analysis of the Data:
- Lowest Tax Option:3926.90.99.89(22.8%). This applies only if the item is strictly defined as a general "Plastic Article" and not a specialized "Friction Material."
- High Tax Options:4205and6813codes carry a 35.0% - 37.9% total tax burden due to a 25% Section 301 surcharge.
- Key Differentiator: The 25% Additional Tariff is the biggest cost driver for Chapters 42 and 68, whereas Chapter 39 has a lower 7.5% surcharge in this dataset.
💰 III. Detailed Tax Breakdown & Legal Basis
🎯 1. The "Low-Tax" Path: 3926.90.99.89
Summary: Classified as "Other Plastic Articles" (General Plastics).
Tax Calculation:
| Component | Rate | Source |
|-----------|------|--------|
| Base Duty | 5.3% | USITC General Rate |
| Section 301 (Trade War) | 7.5% | USTR List 3/4 (Specific to this code in dataset) |
| IEEPA (China-Specific) | 10% | International Emergency Economic Powers Act |
| TOTAL | 22.8% | |
📌 Note: This is the most favorable classification if the friction pad can be legally argued as a general plastic component rather than a specialized friction material.
🎯 2. The "High-Tax" Path: 4205.00.10.00 & 6813.xx.xx.xx
Summary: Classified as Mechanical Leather or Brake Friction Materials.
Tax Calculation:
| Component | Rate | Source |
|-----------|------|--------|
| Base Duty | 0.0% - 2.9% | USITC General Rate (Low base!) |
| Section 301 (Trade War) | 25.0% | USTR List 3/4 (High surcharge) |
| IEEPA (China-Specific) | 10% | International Emergency Economic Powers Act |
| TOTAL | 35.0% - 37.9% | |
📌 Warning: Even though the Base Duty is low (0-2.9%), the 25% Section 301 tariff makes the total cost much higher than the plastic classification. This highlights the importance of correct HS Code selection.
🛠️ IV. Customs Clearance Strategy & Practical Advice
✅ 1. Pre-Classification Risk Assessment
| Scenario | Recommended HS Code | Risk Level | Reasoning |
|---|---|---|---|
| Product is pure plastic/resin composite with no special "brake" or "leather" designation. | 3926.90.99.89 |
✅ Low | Lowest tax (22.8%). Argue it is a general plastic part. |
| Product is marketed as "Brake Lining" or "Clutch Plate" with technical specs for friction. | 6813.81.00.50 or 6813.89.00.50 |
⚠️ High | High tax (35%). Customs will likely reclassify from 3926 if function is evident. |
| Product is sold as "Industrial Leather Material" for belts or machinery. | 4205.00.10.00 |
⚠️ High | High tax (35%). Must prove it is "Leather Article" and not general plastic. |
| Product is for Aviation/Business Jet Brakes. | ❌ Not in Data | 🚫 Prohibited | Note: 6813.89.50 specifies "Non-Aviation." Aviation parts may have different, often stricter, rules. |
✅ 2. Documentation Checklist for Clearance
To avoid reclassification from 3926 (22.8%) to 6813 (35.0%), you must prepare:
| Document | Purpose | Key Details to Include |
|---|---|---|
| Product Specification Sheet | Prove composition | List % of plastic, resin, additives. Emphasize "Plastic-based" if aiming for 3926. |
| Technical Data Sheet | Prove usage | Avoid words like "Brake," "Friction," or "Abrasion-resistant" if possible. Use "General Purpose Pad." |
| Photo of Product | Visual confirmation | Show no branding or specific automotive/aviation markings that imply specialized use. |
| Bill of Materials (BOM) | Material proof | Show raw materials are primarily polymers/resins. |
| Commercial Invoice | Declared Value | Accurate CIF value. |
✅ 3. Common Pitfalls & Mitigation
| Mistake | Consequence | Mitigation Strategy |
|---|---|---|
| Calling it "Brake Pad" in the invoice | Customs reclassifies to 6813 → Tax jumps to 35% |
Use generic terms like "Industrial Pad," "Synthetic Plate," or "Friction Disc" if legally permissible. |
| Ignoring Section 301 | Unexpected bill at customs | Always calculate the 25% surcharge for Chapters 42 and 68. Budget for it. |
| Assuming "Synthetic = Plastic" | Incorrect classification | "Synthetic Leather" can be chemically treated paper, fabric, or asbestos-free composites (Chapter 68). Do not assume Chapter 39. |
| Failing to declare IEEPA | Penalties | Ensure 10% IEEPA tariff is included in landed cost calculations for all China-origin goods. |
🌍 V. Global Market Comparison (Focus on US)
| Market | Typical HS Code for Friction Pads | Est. Total Tax (China Origin) | Key Requirement |
|---|---|---|---|
| 🇺🇸 USA | 3926 (22.8%) or 6813 (35%) |
22.8% - 37.9% | High scrutiny on Section 301; strict IEEPA compliance. |
| 🇨🇳 China | 6813 or 3926 |
~10% - 15% | Standard import VAT + Duty. No Section 301. |
| 🇪🇺 EU | 6813 or 3926 |
~0% - 6% | Low base duty. No major trade war tariffs like US. |
📌 Conclusion for US Importers:
The US tariff differential (22.8% vs 35%+) is significant.
- If your product is a general industrial pad, fight for 3926.90.99.89.
- If it is a specialized brake/clutch component, budget for 35.0%.
- Never ignore the 25% Section 301 surcharge on Chapters 42 and 68.
📌 VI. Final Recommendation & Action Plan
- Consult a Customs Broker: Provide your product's technical datasheet and request an Advance Ruling from US CBP if the classification is ambiguous.
- Review Product Naming: Ensure marketing materials do not explicitly state "Brake Pad" or "Aviation Component" if you intend to classify under
3926. - Cost Calculation:
- If 3926: CIF Value × 22.8%
- If 6813/4205: CIF Value × 35.0% (or 37.9%)
- Compliance: Ensure all documents reflect the Chinese origin to correctly apply the 10% IEEPA tariff.
🔥 "HS Code is King. One digit change can save you 12% in taxes!"
🔹 Low-Hanging Fruit: Try to classify under 3926.90.99.89 if the product allows.
🔹 High-Risk Reality: If it’s a brake part, accept 35.0% under 6813.
📣 Immediate Action:
📞 Contact a licensed US Customs Broker today.
📄 Gather Tech Specs to support "Plastic Article" vs "Friction Material" argument.
💰 Update Landed Cost Models to reflect the 22.8% vs 35% scenarios.
✨ Professional Clearance Starts with Precision.
💼 Your Profit Margin Depends on Your HS Code!
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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.