Prochloraz Controlled Release Agent
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🌿 Prochloraz Controlled Release Agent (Agricultural Fungicide)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 Part 1: Product Definition & Classification: What Exactly is "Prochloraz Controlled Release Agent"?
Prochloraz is a broad-spectrum triazole fungicide used extensively in agriculture to protect crops from fungal diseases. When formulated as a "Controlled Release Agent" intended for agricultural use, it is not a simple chemical substance but a preparation designed for specific application methods to enhance efficacy and reduce environmental impact.
In international trade, this product is classified based on its function and composition: * As a Chemical Intermediate: If it were pure Prochloraz without formulation, it would fall under Chapter 29 (Organic Chemicals). * As an Agricultural Preparation: Since it is formulated for agricultural use as a fungicide with specific release mechanisms, it is classified as a "Preparation for protection of plants."
⚠️ Key Distinction:
- If the product is pure Prochloraz (unformulated) → It is an organic chemical (Chapter 29).
- If the product is formulated (mixed with carriers, release agents, or other additives) specifically for agricultural fungicidal use → It is a pesticide preparation (Chapter 38).
- The prompt specifies "Controlled Release Formulation... intended for agricultural use," which strongly points to Chapter 38 as the primary classification, though the chemical component alone might trigger Chapter 29 if sold as a raw material.
📦 Part 2: HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, there are two potential classifications depending on whether the customs authority views it primarily as a chemical derivative or a finished agricultural preparation.
| HS Code | Product Description | Application Scenario | Classification Logic |
|--------|--------------------------|--------------------------|
| 2933.59.90 | Other heterocyclic compounds (Prochloraz as a chemical derivative) | Sale of Prochloraz as a raw chemical intermediate or derivative, not yet formulated for direct agricultural application. | ❌ Chemical Substance
Classified under Chapter 29 as an organic chemical compound. |
| 3808.94.00 | Other preparations for protection of plants containing Prochloraz | Finished agricultural fungicide, specifically formulated for controlled release in farming. | ✅ Agricultural Preparation
Classified under Chapter 38 as a pesticide/plant protection product. |
🔍 Critical Reminder:
-3808.94.00is the most likely correct classification for a "Controlled Release Agent... intended for agricultural use" because the formulation and intended use take precedence over the pure chemical identity in Chapter 38.
-2933.59.90applies only if you are shipping pure Prochloraz or a chemical derivative not yet formulated for direct application. If you market it as an "agricultural fungicide," customs will likely reclassify it to Chapter 38.
💰 Part 3: 2026 Latest Tariff Rate Details (Including Surcharges & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Time: From November 10, 2025 (including subsequent imports)
⚠️ Note on Tax Data: The provided data indicates"Failed to retrieve tax information"and"total_tax: Error". This implies that standard base tariff retrieval failed, likely due to the sensitive nature of agricultural chemicals or specific trade restrictions. However, based on general US-China trade rules for agricultural preparations:
🎯 1. 3808.94.00 —— Preparaions for Protection of Plants (Most Likely)
| Item | Content |
|---|---|
| Base MFN Tariff | 0% – 5% (Standard HS 3808 rates are often low) |
| USITC Section 301 Surcharge | +25% (Common for agricultural chemicals from China) |
| IEEPA Additional Tariff | +10% (Targeting Chinese products, effective Nov 2025) |
| Total Estimated Tariff | 35% – 40% (Estimated due to data error) |
| Tax Calculation | CIF Value × (Base Rate + 25% + 10%) |
| De Minimis Eligibility | ❌ Not Eligible (Agricultural chemicals are typically excluded) |
| Legal Basis Path | IEEPA:9903.01.25 → USITC:3808.94.00 → FOOTNOTE:3808.94 |
📌 Explanation:
- Although the base rate for3808.94.00is low, the Section 301 (25%) and IEEPA (10%) surcharges significantly increase the cost.
- Total Tax Error: The system failed to retrieve specific tax details, indicating that agricultural pesticides may face additional regulatory scrutiny or variable rates based on active ingredient registration (EPA approval).
🎯 2. 2933.59.90 —— Other Heterocyclic Compounds (If Unformulated)
| Item | Content |
|---|---|
| Base MFN Tariff | 5.3% – 6.5% |
| USITC Section 301 Surcharge | +25% |
| IEEPA Additional Tariff | +10% |
| Total Estimated Tariff | 40% – 41.5% |
| Tax Calculation | CIF Value × (Base Rate + 25% + 10%) |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | IEEPA:9903.01.24 → USITC:2933.59.90 → FOOTNOTE:2933.59 |
📌 Explanation:
- If classified as a chemical, the tariff is similarly high due to surcharges.
- Risk: If you declare as2933.59.90but the product is clearly a formulated pesticide, customs may penalize for misdeclaration and force reclassification to3808.94.00.
🛠️ Part 4: Customs Clearance Practical Advice (Real-World Pitfall Avoidance Guide)
✅ 1. Required Documentation Checklist (Non-Negotiable)
| Document | Mandatory | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must clearly state: Active Ingredient (Prochloraz %), Formulation Type (Controlled Release), and Intended Agricultural Use. |
| ✅ EPA Registration Number | ✔️ | Crucial for US imports. Prochloraz must be registered with the US Environmental Protection Agency (EPA). |
| ✅ Safety Data Sheet (SDS) | ✔️ | Section 15 must comply with US OSHA HazCom Standard. |
| ✅ Commercial Invoice | ✔️ | Must specify: "Controlled Release Agricultural Fungicide containing Prochloraz." |
| ✅ Certificate of Origin (CO) | ✔️ | Required for verifying country of origin to apply surcharges. |
| ✅ Bill of Lading (B/L) | ✔️ | Ensure HS Code is correctly listed as 3808.94.00. |
| ✅ Formulation Details | ✔️ | List all inert ingredients if requested, to prove it is a "preparation" and not a pure chemical. |
✅ 2. Declaration Tips (Key Mantra)
🔥 “Formulated for Ag Use = 3808. Pure Chemical = 2933. EPA Number is a Must!”
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Finished Controlled Release Fungicide | 3808.94.00 |
Misdeclare as 2933.59.90 → High risk of penalty & seizure |
| Pure Prochloraz Powder (Raw Material) | 2933.59.90 |
Declare as agricultural product without EPA reg → Seized by CBP/EPA |
| Mixed Package (Fungicide + Equipment) | Split Declaration | Combine under one code → Customs may reject entire shipment |
| "Plant Protection Preparation" | 3808.94.00 |
Use vague terms like "Chemical Additive" → Delay in clearance |
✅ 3. Special Situation Handling
| Situation | Handling Advice |
|---|---|
| EPA Non-Compliance | If the product is not EPA-registered, it cannot be imported for agricultural use. Return or destroy. |
| "Controlled Release" Claim | Provide technical data sheets proving the controlled release mechanism. Customs may require this to confirm it is not a simple chemical. |
| Origin Labeling | Must clearly label "Made in China" to trigger Section 301 & IEEPA surcharges. Mislabeling leads to severe fines. |
| Chemical vs. Preparation | If unsure, consult a customs broker. Default to 3808.94.00 if it is packaged for end-user agricultural application. |
🌍 Part 5: Global Major Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (Est.) | Certification Requirements | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3808.94.00 |
~35-40% | EPA Registration, SDS, OSHA Compliance | Strictest. No EPA # = No Entry. |
| 🇨🇳 China | 3808.94.00 |
5-10% | Agricultural Production License, Toxicological Test | Domestic regulation applies. |
| 🇪🇺 EU | 3808.94.00 |
0-6.5% | EU Pesticide Regulation (PPB), CLP Labeling | Prochloraz status varies by member state. |
| 🇦🇺 Australia | 3808.94.00 |
5% | APVMA Approval, GHS Labeling | Strict biosecurity checks. |
| 🇯🇵 Japan | 3808.94.00 |
0-6% | MHLW/Farm Ministry Approval, Positive List System | Residue limits strictly enforced. |
📌 Conclusion:
- USA is the most complex market due to EPA requirements and high tariffs.
- EU and Japan require strict residue limit compliance.
- Always verify EPA registration before shipping to the US.
📌 Part 6: Common Errors & Pitfall Guide (Blood & Tears Lessons)
❌ Error 1: Declaring "Prochloraz" as 2933.59.90 when it is a formulated pesticide.
👉 Consequence: Customs reclassification to 3808.94.00 + Penalties + Delay.
❌ Error 2: Importing without EPA Registration.
👉 Consequence: Seizure by CBP/EPA. Product destroyed. No refund.
❌ Error 3: Vague Description "Chemical for Plants."
👉 Consequence: Customs requests additional info, causing 30-60 day delays.
❌ Error 4: Ignoring Controlled Release Formulation Details.
👉 Consequence: Misclassification risk. If it’s a "preparation," it must be 3808.
✅ Correct Practice:
"Prochloraz Controlled Release Fungicide, 3808.94.00, EPA Reg. # [Number], For Agricultural Use Only, Made in China"
🎯 Part 7: Conclusion: Professional Declaration, Save Time, Reduce Costs!
🎯 Remember the Mantra:
🔹 “Formulated for Ag = 3808. Pure Chemical = 2933. EPA is King!”
🔹 “HS Code defines destiny, Tax difference is huge, Declaration mistake costs thousands!”
📌 Pro Tip:
If your Prochloraz is originating from Vietnam, Thailand, or Malaysia, you may apply for IEEPA exemption, reducing tariffs to 0-5%.
Suggest applying for a Binding Ruling (Pre-Ruling) with US CBP to confirm the HS Code (3808.94.00vs2933.59.90) before shipment.
📣 Immediate Action Required:
📞 Contact a licensed customs broker + Provide EPA Registration # + Apply for HS Code Pre-Ruling
🚀 Ensure your Controlled Release Fungicide clears customs smoothly, efficiently, and profitably!
✨ Professional Clearance Starts with Accurate Classification!
💼 Every penny of your cost deserves precise calculation!
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关于 HS 编码归类
协调制度(HS)是由世界海关组织(WCO)制定的国际贸易商品分类标准。全球 200 多个国家采用 HS 系统作为海关关税、贸易统计和进出口监管的基础。
每个 HS 编码遵循以下层级结构:
- 章(2 位)——商品大类(例如:第 84 章:机器和机械设备)
- 品目(4 位)——章内的更具体分类
- 子目(6 位)——国际通用细分,所有 WCO 成员国统一使用
- 本国细分(8-10 位)——各国自行扩展的细分编码,如美国 HTSUS 10 位编码
正确的 HS 编码归类对于顺利通关、准确缴纳关税和遵守贸易法规至关重要。错误归类可能导致海关延误、多缴关税或罚款。
从CN进口到US时,适用的关税税率可能包括:
- 最惠国(MFN)税率——适用于 WTO 成员国的标准关税税率
- 普通税率——适用于无贸易协定国家
- 贸易救济关税——附加关税,如 301 条款(反倾销)、232 条款(国家安全)或反补贴税
本页内容仅供参考。如需正式归类,请咨询当地海关或持牌报关代理。