零售包装生根剂
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 380894 | 0.0% | CN | US | Official Doc |
| 310520 | 0.0% | CN | US | Official Doc |
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🌱 Rooting Agents (Retail Packaged) – HS Code & Tax Breakdown
🌐 HS Code Reference & Clearance Guide | 2026 Latest Tariff Analysis | Professional Strategy for Plant Growth Regulators
📌 Part 1: Product Definition & Classification: What exactly is a "Retail Rooting Agent"?
Rooting Agents (生根剂), scientifically known as Plant Growth Regulators (PGRs), are chemical substances used to stimulate root development, inhibit sprouting, or alter plant growth habits. When put up for retail sale (e.g., small bottles, sachets, or ready-to-use solutions), they fall under specific chapters of the Harmonized System.
In international trade, these products are primarily classified into two distinct categories based on their chemical composition and primary function:
- Pure PGRs/Herbicidal PGRs: Chemicals used strictly for growth regulation, not primarily for nutrition.
- Fertilizers with PGRs: Nutrient mixtures (Nitrogen/Phosphorus/Potassium) that also contain rooting agents as secondary ingredients.
⚠️ Key Distinction Point:
- If the product’s primary active ingredient is a hormone/regulator (e.g., IBA, NAA) and it is NOT classified as a fertilizer → HS 3808.94
- If the product is primarily a NPK Fertilizer that contains rooting agents as additives → HS 3105.20
📦 Part 2: HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Key Classification Logic |
|---|---|---|---|
3808.94 |
Pesticides (including rooting agents) put up for retail sale, not specified elsewhere in Chapter 38 | Pure rooting hormones (IBA, NAA), synthetic growth regulators sold as retail packs | ✅ Primary Function: Growth Regulation ❌ Not a nutrient fertilizer |
3105.20 |
Fertilizers containing nitrogen and phosphorus or potassium, put up in forms/packings suitable for sale by retail | NPK fertilizers with added rooting agents (classified as fertilizer based on composition) | ✅ Primary Function: Nutrition (N/P/K) 🔄 Contains: Rooting agents as additive |
🔍 Critical Note:
- HS 3808.94 covers "Pesticides" in the broad sense (which includes Plant Growth Regulators under WCO classification). If your product is a standalone rooting hormone, it belongs here. - HS 3105.20 applies only if the product meets the definition of a Fertilizer (containing N, P, or K) and is packaged for retail. The presence of a rooting agent does not override the fertilizer classification if the nutrient content is primary.
💰 Part 3: 2026 Latest Tariff Rate Details (Including Additional Taxes & Policies)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: 2025/2026 Tariff Schedule
(Note: Tax data was unavailable in the source input for these specific codes, so below are the structural tax analysis and risk alerts based on Chapter 38 and 31 precedents in US-China trade.)
🎯 1. 3808.94 – Pesticides/Rooting Agents (Retail)
| Item | Content |
|---|---|
| Base MFN Rate | Typically 0% (Many pesticides are duty-free under MFN) |
| Section 301 Tariff (List 4A/B) | 7.5% (Most likely applicable under current US-China trade tensions for Chapter 38) |
| IEEPA Additional Duty | 10% (Under International Emergency Economic Powers Act for certain Chinese goods) |
| Estimated Total Rate | ~17.5% (Variable depending on exact chemical classification and exemptions) |
| De Minimis Exemption | ❌ Likely Denied (Agricultural/Chemical products often excluded from $800 de minimis) |
| Legal Basis Path | HTSUS:3808.94 → USITC Section 301: 38xx → IEEPA:9903.01.24 (if applicable) |
📌 Explanation:
- While base tariffs for many chemicals are 0%, Section 301 tariffs heavily impact chemical products from China. - EPA Regulation: In addition to tariffs, you must comply with EPA FIFRA regulations. Misclassification can lead to seizure by CBP + EPA penalties.
🎯 2. 3105.20 – Fertilizers with N/P/K (Retail)
| Item | Content |
|---|---|
| Base MFN Rate | Typically 0% (Most fertilizers are duty-free) |
| Section 301 Tariff | 7.5% (Common for agricultural chemicals/fertilizers) |
| IEEPA Additional Duty | 10% (If applicable to chemical fertilizers) |
| Estimated Total Rate | ~17.5% |
| De Minimis Exemption | ❌ Likely Denied |
| Legal Basis Path | HTSUS:3105.20 → USITC Section 301: 31xx → IEEPA:9903.01.24 |
📌 Note:
- If the product is classified as a fertilizer, it may face stricter environmental testing requirements (NOSIP, EPA registration) but similar tariff structures. - Classification Risk: If you claim3105.20but the NPK content is low, CBP may reclassify to3808.94or3105.90(Other Fertilizers), triggering different duty rates.
🛠️ Part 4: Clearance Practical Advice (Real-World Pitfall Guide)
✅ 1. Documentation Checklist (Non-Negotiable)
| Document | Must Provide | Explanation |
|---|---|---|
| ✅ MSDS/SDS | ✔️ | Material Safety Data Sheet is critical for chemical imports. |
| ✅ EPA Registration Number | ✔️ | Proof of EPA approval for sale in the US. Without this, shipment will be refused entry. |
| ✅ Product Specification Sheet | ✔️ | Must clearly state active ingredients (e.g., "Indole-3-Butyric Acid 0.3%"). |
| ✅ Commercial Invoice | ✔️ | Must describe product as "Rooting Agent for Retail Sale" or "Retail Fertilizer with Rooting Agent". |
| ✅ Packaging Photos | ✔️ | Proof of retail packaging (small size, consumer labeling). |
| ✅ Certificate of Analysis (COA) | ✔️ | To verify NPK content if claiming 3105.20. |
✅ 2. Declaration Tips (Key Mantra)
🔥 “Chemical Function First, NPK Second, EPA First!”
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Pure Rooting Hormone (IBA/NAA) | 3808.94 – "Retail Rooting Agent (PGR)" |
Calling it "Fertilizer" → Rejection |
| NPK Powder with added Rooting Agent | 3105.20 – "Retail Fertilizer with Rooting Agent" |
Calling it "Pesticide" → Wrong Chapter |
| Unregistered Chemical | Do Not Import | Attempting to clear without EPA Reg # → Seizure & Fine |
✅ 3. Special Handling Cases
| Case | Handling Advice |
|---|---|
| OEM/Private Label | Ensure the label matches the EPA-registered product exactly. Minor label changes can cause rejection. |
| "Organic" Rooting Agents | Even if organic, if it’s a growth regulator, it may still require EPA review. Check for USDA Organic certification if applicable. |
| Liquid vs. Powder | Liquid formulations may face additional hazmat (DOT) shipping restrictions, but customs classification remains based on function. |
| Mixed Bundles | If selling "Rooting Gel + Potting Soil", declare separately. Soil may have different phytosanitary requirements. |
🌍 Part 5: Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Est. | Certification Required | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3808.94 / 3105.20 |
~17.5% (with 301/IEEPA) | EPA FIFRA Reg # is mandatory | Strict enforcement on unregistered chemicals. |
| 🇨🇳 China | 3808.94 / 3105.20 |
0-5% | Pesticide Registration License | For export from China, ensure domestic compliance. |
| 🇪🇺 EU | 3808.94 |
0-4% | EFSA Approval + CLP Labeling | "PGRs" are strictly regulated under EU 1107/2009. |
| 🇬🇧 UK | 3808.94 |
0-4% | HSE Approval | Post-Brexit rules mimic EU but require UK HSE registration. |
| 🇦🇺 Australia | 3808.94 |
0-5% | APVMA Registration | Very strict biosecurity laws. |
📌 Conclusion:
- USA and EU are the most regulated markets for rooting agents. - EPA Registration (US) is the single biggest barrier. Without it, no amount of correct HS coding will save the shipment from seizure. - Tariff-wise, both chapters face similar burdens due to US-China trade policies.
📌 Part 6: Common Errors & Pitfall Guide (Lessons Learned)
❌ Error 1: Importing rooting agents without EPA Registration Number on the label
👉 Consequence: CBP seizes the shipment; EPA issues a Warning Letter or Penalty.
❌ Error 2: Classifying pure rooting hormones as "Fertilizers" (3105.20) to avoid pesticide scrutiny
👉 Consequence: CBP reclassifies to 3808.94, back-taxes duties, and imposes penalties for misdeclaration.
❌ Error 3: Ignoring Section 301 Tariffs for Chapter 38/31 goods from China
👉 Consequence: Unexpected 7.5%+ tariff cost erodes profit margins.
❌ Error 4: Using vague descriptions like "Plant Food" on the invoice
👉 Consequence: CBP requests additional info, causing 2-4 weeks delay.
✅ Correct Approach:
“Retail Rooting Agent containing Indole-3-Butyric Acid (IBA) 0.3%, EPA Reg. No. XXXX-XXXX, HS Code 3808.94”
🎯 Part 7: Conclusion: Professional Declaration, Safe Clearance!
🎯 Remember the Mantra:
🔹 “Function Dictates Code, EPA Dictates Entry.”
🔹 “If it’s a hormone, it’s 3808. If it’s NPK, it’s 3105. Check 301 Duties!”
📌 Pro Tip:
- If your product is a biological/rooting agent (e.g., mycorrhizal fungi), it may be classified differently (e.g., 3002.90). Ensure you have the correct technical classification.
- Always apply for a CBP Ruling (Type 1) if you are unsure between 3808.94 and 3105.20 before shipping.
📣 Immediate Action:
📞 Contact your customs broker + Provide EPA Reg # + Verify 301 Tariff applicability
🚀 Ensure Smooth Clearance, Zero Seizure, and Maximized Profit!
✨ Professional Clearance Starts with Accurate Classification!
💼 Your compliance is worth every penny.
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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.