脂肪酸油
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3402311000 | 41.5% | CN | US | Official Doc |
| 3824994140 | 39.6% | CN | US | Official Doc |
| 1518004000 | 25.5% | CN | US | Official Doc |
| 3823130020 | 20.7% | CN | US | Official Doc |
| 3823110000 | 0.0% | CN | US | Official Doc |
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🧪 Fatty Oil (Fatty Acids & Derivatives) – Ultimate HS Code Classification & Customs Clearance Guide (2026)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Tier-1 Strategy
📌 I. Product Definition & Classification: Do You Really Understand "Fatty Oil"?
"Fatty Oil" in international trade is not a single chemical entity but a broad category encompassing Fatty Acids, Fatty Acid Salts (Soaps/Surfactants), and Modified Oils. The classification depends entirely on the chemical structure, purity, and industrial application.
In customs terms, it is divided into two main branches: 1. Surface Active Agents (Surfactants/Soaps): Salts of fatty acids used for cleaning or emulsifying. 2. Industrial Single Carboxylic Acids & Modified Oils: Raw materials for chemical synthesis, lubricants, or polymers.
⚠️ Key Distinction Point:
- If the product is a salt of fatty acid (ionic, soap-like) → Classified under Chapter 34 (Soap, Surface Active Agents).
- If the product is free fatty acid (acidic, raw material) → Classified under Chapter 38 (Chemical Products).
- If the product is a chemically modified oil/fat (esterification, hydrogenation) → Classified under Chapter 15 (Animal/Vegetable Fats & Oils).
📦 II. HS Code Classification Matrix (2026 Latest Authority)
Based on the provided data, here is the authoritative breakdown for Fatty Oil derivatives imported into the USA from China.
| HS Code | Product Description | Chemical Nature | Key Classification Criteria |
|---|---|---|---|
3402.31.10.00 |
Fatty Acid Salts (Surface Active Agents) | Ionic Salt | Belongs to organic surface active agents. Fits Chapter 34 definition. |
3824.99.41.40 |
Fatty Acid Ester Mixture | Ester Compound | Fatty acid salts/esters mixed with other materials. Consistent with fatty acid ester mixtures. |
1518.00.40.00 |
Modified/Refined Oils | Chemically Modified Fat | Raw fatty materials undergoing chemical modification/distribution. Fits "oil fractionation" characteristics. |
3823.13.00.20 |
Industrial Single Carboxylic Acid | Free Fatty Acid (Secondary) | Primary form of industrial single carboxylic fatty acids. |
3823.11.00.00 |
Industrial Single Carboxylic Acid | Free Fatty Acid (Primary) | Consistent with material characteristics of single carboxylic fatty acids in primary form. |
🔍 Critical Note:
- Salts vs. Acids: A "Fatty Acid" (e.g., Stearic Acid) is Chapter 38. Its salt (e.g., Sodium Stearate) is Chapter 34.
- Mixtures: If the product is a blend of esters and other organic compounds, it may fall under 3824.
- Processing Level: Slightly processed oils stay in Chapter 15; heavily modified or specific industrial acids go to Chapter 38.
💰 III. 2026 Tariff Rate Breakdown (Detailed Analysis)
✅ Applicable Country: USA (US)
✅ Origin: China (CN)
✅ Effective Time: 2025–2026 (Including Section 301 & IEEPA tariffs)
🎯 1. 3402.31.10.00 – Fatty Acid Salts (Surfactants)
| Item | Detail |
|---|---|
| Base Tariff | 6.5% |
| Section 301 Additional Tariff | +25.0% |
| IEEPA / Section 122 Tariff | +10.0% |
| Total Effective Rate | 41.5% |
| Calculation Basis | CIF Value × 41.5% |
| De Minimis Exemption | ❌ NOT Eligible (Section 301/IEEPA goods are excluded from de minimis) |
| Legal Path | USITC:3402.31.10.00 → Footnote:301_41.5% → IEEPA:122_10% |
📌 Explanation:
- Fatty acid salts are considered "chemical preparations" for surface active purposes.
- The 41.5% rate is a heavy burden. Ensure your invoice clearly states "Fatty Acid Salts" and not generic "Fatty Oils" to avoid mismatch penalties.
🎯 2. 3824.99.41.40 – Fatty Acid Ester Mixtures
| Item | Detail |
|---|---|
| Base Tariff | 4.6% |
| Section 301 Additional Tariff | +25.0% |
| IEEPA / Section 122 Tariff | +10.0% |
| Total Effective Rate | 39.6% |
| Calculation Basis | CIF Value × 39.6% |
| De Minimis Exemption | ❌ NOT Eligible |
| Legal Path | USITC:3824.99.41.40 → Footnote:301_39.6% → IEEPA:122_10% |
📌 Explanation:
- This code is for mixtures of fatty acid esters. If your product is a pure ester, check Chapter 29 or 3823. If it's a complex blend, this is the correct bucket.
- Slightly lower total tax than pure salts, but still high due to trade war tariffs.
🎯 3. 1518.00.40.00 – Chemically Modified Oils/Fats
| Item | Detail |
|---|---|
| Base Tariff | 8.0% |
| Section 301 Additional Tariff | +7.5% |
| IEEPA / Section 122 Tariff | +10.0% |
| Total Effective Rate | 25.5% |
| Calculation Basis | CIF Value × 25.5% |
| De Minimis Exemption | ❌ NOT Eligible |
| Legal Path | USITC:1518.00.40.00 → Footnote:301_25.5% → IEEPA:122_10% |
📌 Explanation:
- This is the most cost-effective option IF your product qualifies as a "modified fat/oil" (e.g., hydrogenated oils, ricinoleic derivatives) rather than a pure fatty acid.
- Strategic Note: If you can prove the product is a modified oil derivative, this code saves ~16% in total tax compared to the 3402 classification.
🎯 4. 3823.13.00.20 – Industrial Single Carboxylic Fatty Acid
| Item | Detail |
|---|---|
| Base Tariff | 3.2% + Specific Duty? (See Below) |
| Section 301 Additional Tariff | +7.5% |
| IEEPA / Section 122 Tariff | +10.0% |
| Total Effective Rate | 20.7% (Ad Valorem) |
| Calculation Basis | CIF Value × 20.7% |
| De Minimis Exemption | ❌ NOT Eligible |
| Legal Path | USITC:3823.13.00.20 → Footnote:301_20.7% → IEEPA:122_10% |
📌 Explanation:
- For industrial-grade single carboxylic acids (e.g., non-edible grade).
- The base rate is low, but the 301 tariff (7.5%) is lower than the 25% applied to other chemical preparations.
- Crucial: Must prove it is "Industrial Grade" (not food/cosmetic).
🎯 5. 3823.11.00.00 – Other Single Carboxylic Fatty Acids (Primary)
| Item | Detail |
|---|---|
| Specific Duty | 2.1¢/kg |
| Base Tariff (Ad Valorem) | +3.8% |
| Section 301 Additional Tariff | +7.5% |
| IEEPA / Section 122 Tariff | +10.0% |
| Total Effective Rate | 3.8% + 2.1¢/kg + 17.5% |
| Calculation Basis | (CIF Value × 21.3%) + (Weight in kg × $0.021) |
| De Minimis Exemption | ❌ NOT Eligible |
| Legal Path | USITC:3823.11.00.00 → Footnote:301_7.5% → IEEPA:122_10% |
📌 Explanation:
- This is the BEST RATE for pure, unmodified Fatty Acids (e.g., Stearic Acid, Palmitic Acid) in primary form.
- Total tax burden is significantly lower (~21.3% + minimal specific duty).
- Requirement: Must be in "Primary Form" (straight-chain, not chemically altered).
🛠️ IV. Customs Clearance Practical Advice (Pitfall Avoidance)
✅ 1. Document Checklist (Mandatory)
| Document | Required? | Description |
|---|---|---|
| Product Specification Sheet | ✅ | Must list IUPAC Name, CAS Number, Chain Length (C12, C16, C18, etc.), and Purity %. |
| Certificate of Analysis (COA) | ✅ | Proves it is "Fatty Acid" vs. "Fatty Alcohol" vs. "Salt". |
| Industrial Use Statement | ✅ | If claiming 3823 or 1518, state "Used for Lubricant/Plasticizer Manufacturing" to exclude Food/Cosmetic chapters. |
| Commercial Invoice | ✅ | Must describe goods precisely: e.g., "Stearic Acid, Technical Grade, CAS 57-11-4". |
| MSDS (SDS) | ✅ | Required for chemical shipments. Section 14 must list HS code or chemical nature. |
✅ 2. Declaration Tips (Key Mantras)
🔥 "Acid is 38, Salt is 34, Oil is 15; Get it wrong, pay 20% more!"
| Scenario | Correct HS Code | Error Consequence |
|---|---|---|
| Stearic Acid (Raw) | 3823.11.00.00 |
Misclassifying as Soap → 41.5% Tax instead of ~21%. |
| Sodium Stearate (Soap) | 3402.31.10.00 |
Misclassifying as Acid → Customs may reject for wrong chapter. |
| Hydrogenated Oil | 1518.00.40.00 |
Misclassifying as Raw Fat → Higher base rate & 301 penalty. |
| Mixture of Esters | 3824.99.41.40 |
Vague description "Fatty Oil" → Delay & Inspection. |
✅ 3. Special Case Handling
| Situation | Handling Advice |
|---|---|
| OEM/Private Label | Provide the supplier's technical data sheet. Do not use generic "Fatty Oil" on the invoice. |
| Food Grade vs. Industrial | Food Grade falls under Chapter 15 (usually 0-2.5% base, but check specific rules). Industrial falls under 38. Do not mix. |
| Small Samples (De Minimis) | ❌ DO NOT USE. Section 301 and IEEPA tariffs apply to ALL shipments, even under $800. Do not ship via USPS/Small Parcel without paying tariffs. |
🌍 V. Global Market Comparison (2026)
| Market | Recommended HS Code (Acid) | Base Tax | Trade War Tax | Total Est. Tax | Notes |
|---|---|---|---|---|---|
| 🇺🇸 USA | 3823.11.00.00 |
3.8% + Spec | 17.5% (301+IEEPA) | ~21.3% + Spec | High scrutiny. Use CAS numbers. |
| 🇨🇳 China | 2915.39.00 (Example) |
~0-3% | 0% | Low | Exports from China usually enjoy zero duty. |
| 🇪🇺 EU | 2915.39.00 |
~4-6% | 0% | ~5% | No US-style Section 301. |
| 🇮🇳 India | 2915.39.00 |
~7.5% | 0% | ~7.5% | BIS certification required for some grades. |
📌 Conclusion:
- USA is the most expensive market due to Section 301 & IEEPA.
- Optimization Strategy: If possible, ensure the product is classified under 3823.11 (Pure Acid) rather than 3402 (Salt) or 3824 (Mixture), as it has the lowest combined rate.
- Document Precision: Use CAS Numbers and IUPAC Names in all commercial documents to prevent customs reclassification.
📌 VI. Common Mistakes & Pitfalls (Blood & Tears)
❌ Mistake 1: Calling everything "Fatty Oil" on the invoice.
👉 Result: Customs assigns a default high-tax code or demands a formal classification ruling, delaying cargo by weeks.
❌ Mistake 2: Shipping "Fatty Acid Salts" under 3823.
👉 Result: 41.5% Tax applied if corrected to 3402, or penalties for misdeclaration. Salts are surfactants, not acids.
❌ Mistake 3: Using De Minimis ($800 exemption) for Fatty Acids.
👉 Result: Seizure or Back-tariff. IEEPA/301 tariffs explicitly waive the de minimis threshold for China-origin chemicals.
❌ Mistake 4: Ignoring "Industrial Grade" proof.
👉 Result: If customs suspects Food Grade, they may shift it to Chapter 15, which has different regulatory requirements (FDA) and different tax rates.
✅ Correct Approach:
"Stearic Acid, Technical Grade, CAS No. 57-11-4, Purity >99%, Used for Polymer Manufacturing. HS: 3823.11.00.00."
🎯 VII. Conclusion: Precision Saves Money
🎯 Remember the Mantra:
🔹 "Acid is 38, Salt is 34. Pure Acid pays less (21%), Salt pays more (41.5%)."
🔹 "No De Minimis for China Chemicals. Always pay the 17.5% extra."
📌 Pro Tip:
If your product is a Mixture, try to qualify it under 1518.00.40.00 (Modified Oil) if chemically justifiable, as the total tax is 25.5%, significantly lower than the 41.5% for salts.
📣 Immediate Action:
📞 Consult a Customs Broker with your CAS Number and COA.
📄 Declare Precisely: Avoid generic names. Use chemical names.
🚀 Plan for Tariffs: Budget for the 17.5% Additional Tariff in your cost model.
✨ Professional Classification, Zero Surprises!
💼 Every Cent Counts in Chemical Trade!
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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.