Insulated Stainless Steel Water Bottles from Vietnam

TARIFF CODE RESEARCH RESULTS: Insulated Stainless Steel Water Bottles
Destination: United States (HTS)
Origin: Vietnam

⚠️ MANDATORY PROFESSIONAL REVIEW REQUIRED

This is research assistance only—NOT a legal customs classification. A licensed
customs broker must provide your final classification before importing.
Misclassification carries $500-5,000 fines plus storage fees ($50-200/day).

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CANDIDATE HS CODES (Preliminary Research):

1. HS Code 9617.00.10.00 ✓ PRIMARY CANDIDATE
   Description: “Vacuum flasks and other vacuum vessels, complete with cases,
   with capacity not over 1 liter”

   WHY THIS MAY FIT:
   ✓ Product is double-walled vacuum insulated (vacuum vessel)
   ✓ Primary material is stainless steel
   ✓ Complete product with rubber grip and silicone seals
   ✓ Designed for sports/outdoor use (portable beverage container)
   ✓ Vacuum insulation is the essential character of the product

   DECISION FACTORS FOR YOUR BROKER:
   → What is the exact capacity of your water bottles?

   • If ≤1 liter (≤33.8 oz): Use 9617.00.10.00
   • If >1 liter but ≤2 liters: Use 9617.00.30.00
     → Does the vacuum insulation feature qualify as “vacuum vessel”?
     → Are bottles sold complete with all components in retail packaging?

   US HTS DUTY RATE: 7.2% ad valorem

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2. HS Code 9617.00.30.00 ALTERNATIVE CANDIDATE (if capacity >1L)
   Description: “Vacuum flasks and other vacuum vessels, complete with cases,
   with capacity over 1 liter but not over 2 liters”

   DECISION FACTOR FOR YOUR BROKER:
   → Bottle capacity threshold determination

   • Most sports water bottles are 16-32 oz (0.47-0.95L) → 9617.00.10
   • Larger bottles 34-64 oz (1.0-1.9L) → 9617.00.30

   US HTS DUTY RATE: Verify current rate at hts.usitc.gov
   (Typically similar range to 9617.00.10 but must be confirmed)

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3. HS Code 7323.93.00.80 ⚠ LESS LIKELY (but possible classification)
   Description: “Table, kitchen or other household articles and parts thereof,
   of stainless steel: Other household articles and parts”

   WHY THIS MIGHT NOT FIT:
   ⚠ This code is for general stainless steel household articles
   ⚠ Does NOT specifically account for vacuum insulation feature
   ⚠ Typically applies to single-wall bottles or kitchen containers
   ⚠ Misclassification here could result in incorrect duty calculation

   DECISION FACTORS FOR YOUR BROKER:
   → Is vacuum insulation the “essential character” of the product? (likely YES)
   → If YES, then 9617 is more specific than 7323 under GRI 3(a)
   → Single-wall stainless steel bottles might classify here
   → Your double-walled vacuum insulated bottles likely do NOT

   US HTS DUTY RATE: 2.0% ad valorem

   NOTE: While this code has a lower duty rate (2% vs 7.2%), using an incorrect
   classification to reduce duties is illegal and results in penalties

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PRELIMINARY ASSESSMENT: 9617.00.10.00 appears most likely (if ≤1L capacity)

REASONING:

1. Product features double-wall vacuum insulation - Chapter 96 heading 9617 applies
2. “Vacuum vessels” is the most specific description (GRI 3a)
3. Complete product with rubber grip and silicone seals (complete vessel)
4. Retail packaging indicates consumer-ready product
5. Capacity determines subheading (.10 vs .30)

CLASSIFICATION LOGIC (General Rules of Interpretation):

• GRI 1: Product fits “vacuum flasks and other vacuum vessels” heading
• GRI 3(a): 9617 is more specific than 7323 (vacuum vessel vs general household)
• Essential character: Vacuum insulation for temperature retention
• Composite materials (stainless steel + rubber + silicone) do NOT change
  classification - vacuum insulation is the defining feature

ESTIMATED DUTY & TAXES (Preliminary - assuming 9617.00.10):

• Base Duty: 7.2% (on FOB value)
• Merchandise Processing Fee (MPF): 0.3464% (min $27.75, max $538.40)
• Harbor Maintenance Fee (HMF): 0.125% (if arriving by sea)
• Example: $10,000 FOB shipment = $720 duty + $34.64 MPF + $12.50 HMF = $767.14

CALCULATION EXAMPLE (Per Unit):

• If FOB value per bottle = $8.00
• Duty (7.2%) = $0.58 per bottle
• MPF and HMF calculated on shipment total
• CIF value (Cost + Insurance + Freight) used for customs valuation

POTENTIAL ISSUES TO VERIFY WITH BROKER:

⚠ Vietnam origin: Steel tariffs and Section 232 considerations

• Section 232 steel tariffs: 25% tariff on steel products was reinstated
  March 12, 2025, applying to “all countries without exception”
• Vietnam Trade Agreement: Reduced general tariffs from 46% to 20% (as of 2025)
• Transshipment scrutiny: 40% tariff applies if goods are Chinese-origin
  routed through Vietnam

⚠ Must verify actual country of origin:

• Where was steel melted and poured?
• Where was product manufactured/assembled?
• Are components Chinese-origin transshipped through Vietnam?

⚠ Section 232 Application to 9617 Products:

• Your broker MUST determine if Section 232 steel tariffs apply to finished
  stainless steel water bottles classified under 9617
• Section 232 typically targets steel articles; finished consumer products
  may have different treatment
• This is a CRITICAL decision point requiring professional evaluation

⚠ Capacity verification needed for proper subheading selection

⚠ Composite product considerations:

• Stainless steel body (primary material)
• Rubber grip (accessory)
• Silicone seals (accessory)
• Broker will confirm accessories don’t alter primary classification

MANDATORY NEXT STEPS:

1. ✅ REQUIRED: Consult licensed customs broker for final classification
2. ✅ REQUIRED: Confirm exact product capacity (in liters or ounces)
3. ✅ REQUIRED: Verify true country of origin and steel sourcing to avoid
   transshipment penalties (40% tariff exposure)
4. ✅ REQUIRED: Determine if Section 232 steel tariffs apply to your finished
   products (additional 25-50% possible)
5. ✅ Share this research with your broker (saves 8-12 hours of research time)
6. ✅ For high-value/recurring shipments: Request CBP binding ruling (free,
   30-90 days, legally binding)
7. ✅ Verify current tariff rates at import time at hts.usitc.gov

BROKER CONSULTATION COSTS (Required Investment):

• Classification research: $50-150 per product
• Entry filing: $150-300 per shipment
• This is not optional—it’s a required cost of importing legally

COMPLEXITY LEVEL: MODERATE

This product requires professional evaluation due to:

• Vietnam origin and current steel tariff environment (Section 232)
• Potential transshipment scrutiny (Chinese steel routed through Vietnam)
• Capacity-based subheading selection
• Section 232 applicability to finished consumer products unclear

RESEARCH SOURCES:

• USITC HTS Database (hts.usitc.gov)
• CBP Beverage Containers Guidance
• Tariff Number Database - HS 96170000
• CBP Ruling Database (rulings.cbp.gov)

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⚠️ FINAL REMINDER:

This research identifies 9617.00.10 as the most likely classification for
double-walled insulated stainless steel water bottles ≤1 liter capacity from
Vietnam. However, given:

1. The complex 2025 steel tariff environment (Section 232)
2. Vietnam transshipment scrutiny (40% penalty risk)
3. Potential additional duties beyond base 7.2% rate
4. Capacity-based subheading determination needed

Professional customs broker review is MANDATORY before importing. Do not use
these codes for actual importation without licensed customs broker approval.

The broker will:
✓ Verify Section 232 steel tariff applicability to finished bottles
✓ Confirm true country of origin (avoid transshipment penalties)
✓ Determine exact HTS subheading based on capacity
✓ Calculate total landed cost including all applicable duties
✓ File proper entry documentation to avoid delays and penalties