石墨基润滑涂层
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3208100000 | 38.7% | CN | US | Official Doc |
| 3824994900 | 41.5% | CN | US | Official Doc |
| 3824992900 | 41.5% | CN | US | Official Doc |
| 3801105090 | 35.0% | CN | US | Official Doc |
AI Analysis
🧪 Graphite-Based Lubricating Coating (Graphite-Based Lubricating Coating)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional-Level Clearance Strategy
📌 Part 1: Product Definition and Classification: What Exactly is "Graphite-Based Lubricating Coating"?
A graphite-based lubricating coating is a complex mixture used to reduce friction and wear between moving parts. It typically consists of synthetic polymer resins or chemically modified polymers acting as binders, with synthetic graphite as the primary solid lubricant additive.
In international trade, the classification hinges on two critical factors: 1. Primary Function: Is it primarily a "paint/coating" (for surface protection/decoration) or a "chemical preparation" (for lubrication)? 2. Composition: Does it contain significant amounts of natural or synthetic graphite that triggers specific chemical heading rules?
⚠️ Key Distinction Point: - If the product is primarily a paint/varnish based on synthetic polymers, where graphite acts as an additive for anti-wear properties → Chapter 32 (Paints/Varnishes). - If the product is primarily a chemical mixture/preparation where graphite is a key component of a chemical formulation not specified elsewhere → Chapter 38 (Chemical Products). - If it is pure synthetic graphite powder applied as a coating without a significant polymeric binder structure → Chapter 3801 (Graphite).
📦 Part 2: HS Code Classification Details (2026 Latest Tariff Authority对照)
| HS Code | Product Description | Application Scenario | Composition Key Feature |
|---|---|---|---|
3208.10.00.00 |
Paints and varnishes based on synthetic polymers or chemically modified polymers, dissolved in non-aqueous media | General industrial coatings, machinery surface protection, decorative coatings with anti-wear additives | ✅ Base: Synthetic Polymer ✅ Additive: Graphite |
3824.99.49.00 |
Other prepared binders for foundry molds/core; other chemical products and preparations (including those consisting of mixtures of natural products), not elsewhere specified or included | Specialty chemical lubricants, industrial chemical preparations, custom chemical mixtures | ✅ Type: Chemical Mixture ✅ Key: Graphite Content |
3824.99.29.00 |
Other preparations used as lubricants or as components of lubricants, containing petroleum oils or bituminous minerals | Lubricating preparations where graphite is the main active ingredient in a chemical carrier | ✅ Type: Lubricant Preparation ✅ Key: Graphite Dominant |
3801.10.50.90 |
Artificial Graphite; colloidal or semi-colloidal graphite; carbonaceous pastes containing graphite as the basic ingredient | Pure synthetic graphite pastes or powders used as coating bases, excluding those classified elsewhere | ✅ Material: Synthetic Graphite ✅ Form: Paste/Coating Base |
🔍 Critical Reminder: -
3208.10.00.00: Best for coatings where the polymer binder is the primary volume driver, and graphite is an additive. -3824.99.49.00&3824.99.29.00: Best for chemical preparations where the formula is complex, or graphite is a defining chemical component. -3801.10.50.90: Best if the product is essentially pure synthetic graphite in a paste form, with minimal other chemical complexity.
💰 Part 3: 2026 Latest Tariff Rate Details (Including Surcharges & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: November 10, 2025 (and subsequent imports)
🎯 1. 3208.10.00.00 —— Paints/Varnishes Based on Synthetic Polymers
| Item | Detail |
|---|---|
| Base Tariff | 3.7% (ad valorem) |
| Section 301 Surcharge | +25.0% (USITC Footnote 9903.88.01) |
| 122 Section Surcharge | +10.0% (Under IEEPA for China-origin goods) |
| Total Effective Rate | 38.7% |
| Tax Calculation | CIF Value × 38.7% |
| De Minimis Eligibility | ❌ No (deny_de_minimis) |
| Legal Basis Path | USITC:3208.10.00.00 → SECTION301:9903.88.01 → IEEPA:9903.01.24 → SECTION122:9903.10.25 |
📌 Explanation:
- Although this is a chemical/paint product, if it is based on synthetic polymers, it falls under Chapter 32. However, it is not exempt from Section 301 or Section 122 tariffs. - Total 38.7% is high. Do not assume "paint" means low tax.
🎯 2. 3824.99.49.00 —— Other Chemical Preparations
| Item | Detail |
|---|---|
| Base Tariff | 6.5% (ad valorem) |
| Section 301 Surcharge | +25.0% (USITC Footnote 9903.88.01) |
| 122 Section Surcharge | +10.0% (Under IEEPA for China-origin goods) |
| Total Effective Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Eligibility | ❌ No (deny_de_minimis) |
| Legal Basis Path | USITC:3824.99.49.00 → SECTION301:9903.88.01 → IEEPA:9903.01.24 → SECTION122:9903.10.25 |
📌 Note:
- This is the catch-all for chemical mixtures not specifically named. - 41.5% is the highest among the provided options. - Only use this if3824.99.29.00is not applicable due to lack of petroleum/bitumen content.
🎯 3. 3824.99.29.00 —— Lubricating Preparations
| Item | Detail |
|---|---|
| Base Tariff | 6.5% (ad valorem) |
| Section 301 Surcharge | +25.0% (USITC Footnote 9903.88.01) |
| 122 Section Surcharge | +10.0% (Under IEEPA for China-origin goods) |
| Total Effective Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Eligibility | ❌ No (deny_de_minimis) |
| Legal Basis Path | USITC:3824.99.29.00 → SECTION301:9903.88.01 → IEEPA:9903.01.24 → SECTION122:9903.10.25 |
📌 Note:
- Specifically for preparations used as lubricants. - If your product is explicitly marketed and formulated as a lubricant (not just a protective paint), this is the most technically accurate HS Code. - However, the tax burden is the same as the general chemical category due to surcharges.
🎯 4. 3801.10.50.90 —— Artificial Graphite Pastes
| Item | Detail |
|---|---|
| Base Tariff | 0.0% (ad valorem) |
| Section 301 Surcharge | +25.0% (USITC Footnote 9903.88.01) |
| 122 Section Surcharge | +10.0% (Under IEEPA for China-origin goods) |
| Total Effective Rate | 35.0% |
| Tax Calculation | CIF Value × 35.0% |
| De Minimis Eligibility | ❌ No (deny_de_minimis) |
| Legal Basis Path | USITC:3801.10.50.90 → SECTION301:9903.88.01 → IEEPA:9903.01.24 → SECTION122:9903.10.25 |
📌 Key Advantage:
- Lowest Total Tax: 35.0%. - Prerequisite: The product must be clearly defined as Artificial Graphite (synthetic) and not primarily a "paint" under Chapter 32. - If the product is >50% graphite by weight and lacks a strong polymeric binder structure, this is the most cost-effective classification. - Caution: Customs may challenge this if the product contains significant solvents or resins that make it a "preparation."
🛠️ Part 4: Customs Clearance Operational Advice (Practical Pitfall Avoidance Guide)
✅ 1. Document Checklist (Essential)
| Document | Must Provide | Explanation |
|---|---|---|
| ✅ Product Specifications | ✔️ | Detailed formula, % of graphite, type of binder (polymer vs. none), viscosity. |
| ✅ Material Safety Data Sheet (MSDS/SDS) | ✔️ | Crucial for determining if it’s a "chemical mixture" or "graphite product." |
| ✅ Product Photos (Label & Container) | ✔️ | Clear view of "Lubricant," "Coating," or "Paint" claims. |
| ✅ Commercial Invoice | ✔️ | Must accurately describe the product as per HS Code (e.g., "Synthetic Graphite Paste" vs. "Polymer-Based Lubricant"). |
| ✅ Certificate of Origin (CO) | ✔️ | Required to verify China origin for surcharge calculation. |
| ✅ Formulation Sheet | ✔️ | If claiming 3801.10.50.90, prove high graphite content to avoid Chapter 32 reclassification. |
✅ 2. Declaration Tips (Key Mantra)
🔥 "Describe by Function & Composition: Polymer = Paint, Graphite Paste = 3801, Chemical Mix = 3824."
| Scenario | Correct Declaration | Risk if Incorrect |
|---|---|---|
| Product is Paint with graphite additive | 3208.10.00.00 |
If declared as 3801, risk of "Wrong Classification" penalty. |
| Product is Lubricant with chemical carrier | 3824.99.29.00 |
If declared as 3208, customs may reclassify and adjust tax. |
| Product is Pure Graphite Paste | 3801.10.50.90 |
If declared as 3208, you pay 3.7% more unnecessarily. |
| Product is Generic Chemical Mix | 3824.99.49.00 |
Only use if no other specific subheading fits. |
✅ 3. Special Circumstances Handling
| Situation | Handling Advice |
|---|---|
| OEM/Private Label | Ensure the supplier's MSDS matches your declared composition. |
| Mixed Shipments | Do not mix 3208 and 3801 in one line item. Declare separately to avoid confusion. |
| Claims of "Non-Chemical" | If claiming 3801, emphasize that it is not a paint/varnish but a graphite lubricant paste. |
| Pre-Ruling | Consider applying for an Advance Ruling with CBP if the product is complex (e.g., semi-solid paste with both polymer and high graphite content). |
🌍 Part 5: Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Rate (China Origin) | Certification Requirements | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3801.10.50.90 |
35.0% (Lowest) | No specific cert, but SDS required | High risk of reclassification if not pure graphite. |
| 🇪🇺 EU | 3208.10.10 |
~6.5% | REACH, CLP | No Section 301/122 equivalent. |
| 🇨🇳 China | 3801.10.50.90 |
~5-10% | None | Import duty varies. |
| 🇨🇦 Canada | 3801.10.50.90 |
~5% | Not specified | Check CBSA guidelines. |
📌 Conclusion:
- USA is the most challenging market due to 301 & 122 tariffs. -3801.10.50.90offers the lowest effective rate (35%) in the US, but requires strong technical justification. -3208.10.00.00is safer for paint-like products but costs 38.7%.
📌 Part 6: Common Errors & Pitfalls (Blood & Tears Lessons)
❌ Mistake 1: Declaring a polymer-based paint as 3801.10.50.90 to save 3.7%.
👉 Consequence: Customs reclassifies it, demands back taxes + interest + potential penalty. Not worth the risk.
❌ Mistake 2: Ignoring SDS/MSDS.
👉 Consequence: Customs cannot determine if it’s a "chemical preparation" or "paint," leading to detention and audit.
❌ Mistake 3: Using vague terms like "Lubricant" without specifying form (paste, spray, powder).
👉 Consequence: Customs may default to the highest-risk or most complex code, causing delays.
❌ Mistake 4: Assuming "Chemical Product" means low tax.
👉 Consequence: 3824.99.49.00 and 3824.99.29.00 both carry 41.5%. Only 3801 is lower.
✅ Correct Approach:
"Synthetic Graphite Lubricant Paste, 60% Graphite, Polymer Binder, for Industrial Use, Model XYZ, SDS Available"
🎯 Part 7: Conclusion: Professional Declaration, Save Cost, Avoid Risk!
🎯 Remember the Mantra:
🔹 "Paint = 3208 (38.7%), Chemical = 3824 (41.5%), Pure Graphite = 3801 (35.0%)."
🔹 "Check your formula: If it’s mostly graphite, go for 3801. If it’s mostly paint, accept 3208. Don’t guess!"
📌 Pro Tip:
If your product is a hybrid (e.g., 50% graphite, 50% resin), consult a customs broker. You might need to argue for 3801 based on "Graphite as the basic ingredient," but be prepared for pushback.
📣 Immediate Action:
📞 Contact a Customs Broker + Provide MSDS/SDS + Request Advance Ruling
🚀 Ensure Smooth Customs Clearance, Reduce Tax Burden, and Maximize Profit!
✨ Professional Customs Clearance Starts with Accurate Classification!
💼 Every Penny of Tax You Pay Should Be Justified and Minimized!
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.