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🖥️ Graphite Oil-based Dispersion (Graphite Lubricant Slurry)
🌐 HS Code Reference & Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: What Exactly is "Graphite Oil-based Dispersion"?
Graphite oil-based dispersion is a lubricant solution consisting of flake or synthetic graphite particles suspended in an oil carrier (such as mineral oil, synthetic ester, or silicone oil), often stabilized with additives to prevent settling. It is widely used in high-temperature lubrication, mold release, industrial machinery maintenance, and aerospace applications.
In international trade, it is primarily classified based on its carrier medium and function. The key distinction lies in whether it is considered a preparation of chemicals (Chapter 35) or a lubricating preparation (Chapter 34).
⚠️ Critical Distinction:
- If the graphite acts primarily as a solid lubricant additive in an oil base →归入 3403 (Lubricating preparations).
- If it is a chemical mixture not primarily for lubrication (e.g., for coating or conductive purposes) → May fall under 3507 or 3824, but 3403 is the standard for lubricating greases/oils.
- Most commercial "Graphite Oil" products are classified under Chapter 34.
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Primary Function |
|---|---|---|---|
3403.99.00.00 |
Other lubricating preparations (incl. cutting oil preparations, bolt/nut lubricating preparations and die-wall lubricating preparations) | General industrial graphite oil, high-temp lubricants, mold release oils | ✅ Lubrication |
3403.11.00.00 |
Lubricating preparations containing petroleum oils or oils obtained from bituminous minerals, containing ≥70% by weight of such oils | If the oil base is predominantly petroleum-based and graphite is a minor additive | ✅ Lubrication |
3403.91.00.00 |
Other lubricating preparations containing petroleum oils or oils obtained from bituminous minerals, containing <70% by weight of such oils | Specialized graphite-oil blends with significant non-petroleum components | ✅ Lubrication |
3824.99.99.00 |
Other chemical products (not elsewhere specified) | Non-lubricating graphite dispersions (e.g., for thermal paste, conductive ink) | ❌ Not Lubrication |
3507.90.00.00 |
Prepared binders for foundry molds or cores | If specifically formulated for foundry applications with graphite | ✅ Specific Use |
🔍 Key Reminder:
- 90% of commercial "Graphite Oil" products are classified under 3403.99.00.00 or 3403.91.00.00 because their primary purpose is lubrication.
- If the product is marketed as a "Dry Lubricant" (solvent evaporates, leaving graphite), it may still be classified under 3403 if it comes in a liquid form for application.
- Do not classify as "Graphite" (HS 3801) unless it is pure, dry graphite powder. Once mixed with oil, it becomes a preparation.
💰 III. 2026 Latest Tariff Rate Details (Including Surtaxes & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: From November 10, 2025 (including subsequent imports)
🎯 1. 3403.99.00.00 —— Other Lubricating Preparations
| Item | Content |
|---|---|
| Base Tariff Rate | 5.6% (ad valorem) |
| USITC Surtax (Section 301) | +25% |
| IEEPA Surtax | +10% (For China/HK products, from Nov 10, 2025) |
| Total Tariff Rate | 40.6% |
| Tax Calculation | CIF Value × 40.6% |
| De Minimis Eligibility | ❌ No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 → IEEPA:9903.01.24 → USITC:3403.99.00.00 → FOOTNOTE:9903.88.01 |
📌 Explanation:
- The 25% USITC surtax is applied under Section 301 of the Trade Act for most Chinese industrial chemicals and preparations.
- The 10% IEEPA surtax is an additional national security tariff for Chinese goods.
- Total 40.6% is a high tariff rate, making cost planning essential.
🎯 2. 3403.11.00.00 —— Lubricating Preparations with ≥70% Petroleum Oil
| Item | Content |
|---|---|
| Base Tariff Rate | 5.6% |
| USITC Surtax | +25% |
| IEEPA Surtax | +10% |
| Total Tariff Rate | 40.6% |
| Tax Calculation | CIF × 40.6% |
| De Minimis Eligibility | ❌ No |
| Legal Basis Path | IEEPA:9901.25 → IEEPA:9903.01.24 → USITC:3403.11.00.00 → FOOTNOTE:9903.88.01 |
📌 Note:
- Even if the product is mostly oil, the graphite additive does not exempt it from the Section 301 surtax if it is still classified under Chapter 34.
- The rate remains 40.6%.
🛠️ IV. Clearance Practical Advice (实战避坑指南)
✅ 1. Required Documentation Checklist (Must-Haves)
| Document | Must Provide | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Includes viscosity, graphite particle size, oil base type (mineral/synthetic), temperature range |
| ✅ Safety Data Sheet (SDS) | ✔️ | Crucial: Must classify under GHS. Check if it is classified as flammable. |
| ✅ Product Photos (Label & Container) | ✔️ | Clear view of brand, model, net weight, and hazard symbols |
| ✅ Commercial Invoice | ✔️ | Describe as "Graphite-based Lubricating Oil, Model XYZ, for Industrial Use" |
| ✅ Packing List | ✔️ | Details total gross/net weight, dimensions |
| ✅ Certificate of Origin (CO) | ✔️ | Required for tariff calculation and trade agreement verification |
| ✅ FEMA/MSDS Report | ✔️ | For chemical compliance |
✅ 2. Declaration Tips (Key Mantra)
🔥 "Describe the Function, Not Just the Name!"
| Situation | Correct Declaration | Wrong Practice |
|---|---|---|
| Graphite Oil for Lubrication | 3403.99.00.00 - "Lubricating Preparation" |
Declare as "Chemical Mixture" → Risk of Misclassification |
| Graphite Oil for Mold Release | 3403.99.00.00 - "Die-wall Lubricating Preparation" |
Declare as "Paint" → Wrong Chapter (32) |
| Dry Graphite Powder (No Oil) | 3801.90.00.00 - "Other Graphite" |
Declare as "Lubricant" → Wrong Chapter (34) |
| Conductive Graphite Slurry (No Lubrication) | 3824.99.99.00 - "Other Chemicals" |
Declare as "Lubricant" → Wrong Chapter (34) |
✅ 3. Special Case Handling
| Situation | Handling Advice |
|---|---|
| Flammable Graphite Oil | If flash point < 60°C, it is Class 3 Flammable Liquid. Require UN 1263 (Paint or related product) or UN 1993 (Flammable liquid, n.o.s.). Hazmat declaration is mandatory. |
| Non-Flammable (Water-based or High Flash Point) | May not require Hazmat. Use standard general cargo declaration. |
| Bulk vs. Retail | Bulk shipments may require additional ISF (Importer Security Filing) details. |
| OEM/Private Label | Provide original manufacturer’s MSDS. Ensure the chemical composition matches the SDS. |
🌍 V. Global Main Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3403.99.00.00 |
40.6% (China) | None specific | High tariff due to Section 301 + IEEPA |
| 🇨🇳 China | 3403.99.00.00 |
5.6% | None | Standard import duty |
| 🇪🇺 EU | 3403.99.90 |
0% (if REACH compliant) | REACH Registration | Low tariff, but high regulatory barrier |
| 🇬🇧 UK | 3403.99.90 |
2.5% | UK REACH | Post-Brexit rules apply |
| 🇯🇵 Japan | 3403.99.90 |
5.5% | None | Moderate tariff |
📌 Conclusion:
- USA has the highest effective tariff (40.6%) for Chinese-origin graphite oil.
- EU and Japan have lower tariffs but stricter chemical regulations (REACH, JCSS).
- Cost planning is critical for US imports. Consider sourcing from Vietnam/Malaysia for IEEPA exemption if applicable.
📌 VI. Common Mistakes & Pitfalls (Blood & Tears Lessons)
❌ Mistake 1: Declaring as "Graphite" (HS 3801)
👉 Consequence: Customs will reclassify to 3403, assess 40.6% tariff, and may impose penalties for misdeclaration.
❌ Mistake 2: Ignoring Flammability Classification
👉 Consequence: If the oil base is flammable, Hazmat fees will be charged. Air freight may be rejected. Sea freight requires DG declaration.
❌ Mistake 3: Vague Product Name "Graphite Liquid"
👉 Consequence: Customs cannot determine the exact HS code. Delay in clearance, potential seizure for further testing.
❌ Mistake 4: Failing to Provide MSDS
👉 Consequence: Hold at port until MSDS is provided. Possible fines for incomplete documentation.
✅ Correct Practice:
"Graphite-based Lubricating Oil, Mineral Oil Base, 20kg Drum, Flash Point > 93°C, SDS Provided, Model XYZ"
🎯 VII. Conclusion: Professional Declaration, Cost Control, Risk Mitigation!
🎯 Remember the Mantra:
🔹 "Oil Base + Graphite = Lubricating Prep (3403)"
🔹 "Flammable? Declare Hazmat!"
🔹 "US Tariff 40.6%: Plan Ahead!"
📌 Pro Tip:
If your graphite oil originates from Vietnam, Mexico, Thailand, or Malaysia, you may qualify for IEEPA Exemption, reducing the total tariff to 5.6%~10.6%.
Recommend Apply for Advance Ruling if unsure about the exact classification (Lubricant vs. Chemical Mixture).
📣 Immediate Action:
📞 Contact a Professional Customs Broker + Provide SDS + Apply for HS Code Advance Ruling
🚀 Let your Graphite Oil clear smoothly, control costs, and maximize profits!
✨ Professional Clearance Starts with Accurate Classification!
💼 Every cent of your cost deserves precise calculation!
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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.