"Optical" Reflections Triggered by a Tax Bill

During my visit to our long-term client, Company A, last week, their Procurement Director, Ms. Wang, was troubled by a customs duty reassessment notice. This professional optical lens manufacturer had imported glass lenses from Taiwan for the first time, originally declared under the tariff code "9001909090" with zero duty, but customs required them to reclassify it under "7014001000" and pay an additional 10% tariff. "We've been in the coating business for over a decade, but never expected to stumble over a tariff code issue," she said with a wry smile, showing me those semi-transparent round glass pieces.

"Optical cipher" in the Customs Tariff

Opening the thick Tariff Notes, the difference between these two HS codes is actually very clear:

• 7014001000It is a "blank for optical elements used in optical instruments," just like uncut jade awaiting carving.
• 9001909090It refers to "optically processed optical components," equivalent to a polished and formed work of art.

The key dividing line lies in whether it has completedOptical processing——This professional term includes two necessary processes:

• Surface shaping (making curved surfaces, inclined surfaces, etc.)
• Surface polishing (rough grinding → fine finishing → flattening → polishing)

On-site "bare-faced" inspection of goods

Carefully check the imported lenses of Company A:

• Appear as semi - transparent circular flakes
• No traces of grinding and polishing are visible on the surface
• The edges have not been edged
• Subsequent processing such as coating is still required

This is completely in line withBlank partsIts characteristics. As the customs officer said, "You can't declare it as a lens now just because it will be made into a lens in the future."

Three - step Classification Method for Optical Elements

Combining 20 years of practical experience, I have summarized thethree - step classification method for glass optical components:

1. Look at the state: Has the two - step optical processing been completed?
2. Look at the use: Is it specifically used for optical instruments?
3. Look at the assembly: Has it been fixedly assembled (involving item 9002)?

Judging by this standard, the lenses of Company A should followthe path of 7014→7014001000To avoid similar problems, it is recommended that enterprises:

Classification Pit - avoiding Guide Worth Collecting

Establish product files

• : Record processing procedures and technical parameters in detailMake good use of pre - rulings
• : For uncertain commodities, an application for classification confirmation can be made 3 months in advancePay attention to process changes
• : Different processing stages of the same product may correspond to different HS codesRemember that last year, a company misdeclared polished but uncoated lenses as blanks, and was inspected by the customs. Later, we helped them establish a

I remember last year when a company mistakenly declared "polished but uncoated" lenses as blanks, which led to a customs inspection. Later, we helped them establishand the problem was solved easily., the problem will be solved easily.

Tips for Import and Export Enterprises

When we were parting, I gave Ms. Wang three suggestions:

• Keep completeProcess flowchartandsample photos
• For newly developed products, be sure to dopre - classification
• Regularly participate in theclassification training held by the customs

Looking at her notebook filled with detailed notes, I am confident that Company A will surely "find the right match" accurately during the next declaration. After all, in the field of import and export,Details determine costs, professionalism creates value.