HS Codes for Refrigerants and Chlorinated Solvents in 2026: What Your Broker Actually Needs

Sun, 20 Sep 2026 · HARMONY TECHNOLOGY (ZHEJIANG) CO., LTD.

HS Codes for Refrigerants and Chlorinated Solvents in 2026: What Your Broker Actually Needs

The 6-digit HS code is a starting point, not an answer. Since HS 2022, single HFCs left the old “catch-all” line and blends moved to a new heading — and the code that finally decides your duty is set by the importing country, not by the exporter.

1. What changed in HS 2022 (and why quotes went wrong)

Until HS 2017 every HFC sat in one subheading, 2903.39 — HFC-134a, HFC-32, HFC-125 and HFC-23 all shared it. From HS 2022 the WCO created separate subheadings:

⇒ Consequence one: a quotation or an invoice still carrying 2903.39 for R-134a is a pre-2022 classification. In HS 2022 terms R-134a is 2903.45. (The United States introduced its own national line for R-134a earlier and long traded it under 2903.39.20 — see §5.)

⇒ Consequence two: the 6-digit number is only the first half of the code. Every country sets its own 8-, 10- or 12-digit line underneath it, and it is that national line which carries the duty rate, the licence requirement and the statistics. Ask for both.

2. Mixtures moved to a new heading — this is where money is lost

R-410A, R-407C, R-404A and the newer retrofit blends are not classified as their components. HS 2022 created heading 3827 for mixtures containing HFCs, with two limbs:

⇒ Read the test as a gate, not as a list. A blend whose HFC-32 or HFC-125 content is below 20 % does not qualify for 3827.65 however well known the product is — it falls to the second limb. Blends that also contain HFOs (R-1234yf / R-1234ze) still fall under 3827 as long as they contain the listed HFCs.

⇒ Practical check: ask the supplier for the mass composition (not just “R-448A”), apply the 20/20 test yourself, and have your broker confirm the national line. Composition, not the ASHRAE number, is what the tariff is written on.

3. The chlorinated solvents are a simpler story

Single-substance chlorinated solvents stayed where they were — the classification question is purity and packaging, not chemistry:

⇒ The real risk here is not the code but the identity: “chlorinated solvent” is not a classification. A drum described as “DCM” that contains methanol as a stabiliser, or a mixture sold as a solvent blend, is a different tariff line (and in some markets a different DG entry). The invoice should state the substance, its CAS and its purity.

4. The export side in China: quota, approval certificate, licence

For controlled substances — a list that, in Chinese practice, includes HFCs as its ninth category even though HFCs are not themselves ozone-depleting — China does not treat export as a plain commercial act. Under MEE / MOFCOM / GACC Order No. 38 (《消耗臭氧层物质进出口管理办法》, effective 2025-05-01):

In addition, the 2026 export licence catalogue (MOFCOM / GACC Announcement 2025 No. 89, effective 2026-01-01) lists ozone-depleting substances among the goods requiring an export licence — and expressly includes samples, advertising material, donations, returned goods and residual liquid.

⇒ The planning point for a buyer: the licence chain is per shipment and calendar-year bound. A year-end order cannot be licensed against next year’s quota at will, and a 90-day approval certificate does not extend with your delivery schedule. Build the licence lead time into the shipping window — not the other way round.

⇒ The procurement point: a supplier who can describe which quota and approval path applies to your product is describing a real operational capability. One who cannot is quoting a product it may not be able to move on schedule. The regimes these licences sit under — the Kigali phase-down, the EU F-gas quota, and the unit of account they share — are set out in HFC quotas and the EU F-gas Regulation.

5. Where the importing country changes the answer

Two facts that catch importers out:

• National lines differ from the 6-digit code. The United States, for example, has long traded R-134a under its own national line 2903.39.20, and assigns separate statistical suffixes under the HS 2022 subheadings. Europe, the UK, India and the GCC each publish their own. The duty rate hangs off the national line, not the HS 6.
• Classification carries more than duty. R-134a from China is subject to US antidumping and countervailing duty proceedings (USITC Investigation No. 731-TA-1313; administrative reviews have continued into 2026). Where AD/CVD applies, the declared classification and the country of origin are not paperwork — they are the difference between the tariff rate and the cash deposit rate.

⇒ The implication: the classification decision belongs to the importer of record, and it is reviewable years later. A supplier’s code is information; it is not the importer’s defence.

6. What to ask for, in one line each

⇒ What a purchase order should say: the substance, the CAS, the composition (for blends), the national tariff line you intend to declare, and the delivery window you can actually be licensed for. That is the difference between a quote and a shipment.

What we can provide

On request we can provide, per product: the HS 6-digit subheading we file under, the CAS number, the mass composition for blends, the UN number and transport class — and, for shipments governed by the ozone-depleting-substance regime, a statement of the export licence route and lead time that applies.

Contact us with: the product, the composition (for blends), the destination market, and the tariff line you intend to declare.

Prepared by Harmony Technology (Zhejiang) Co., Ltd. — a trading company (not a manufacturer). The classification and licence points above summarise publicly available instruments (WCO HS 2022; MEE/MOFCOM/GACC Order No. 38; MOFCOM/GACC Announcement 2025 No. 89); binding classification and licensing decisions rest with the customs and environmental authorities concerned, and with the importer of record.

Sources

• WCO, “The HS 2022 update — new HS codes for HFCs and HFC blends” (published with the UNEP Ozone Secretariat): individual HFC subheadings 2903.41–2903.49; new heading 3827 with subheadings 3827.65 / 3827.68.
• 生态环境部 / 商务部 / 海关总署 部令第 38 号《消耗臭氧层物质进出口管理办法》, effective 2025-05-01 (quota application by 31 October; decision by 20 December; approval certificate reviewed within 20 working days and valid up to 90 days; licence valid per declaration and per calendar year).
• 商务部 / 海关总署 公告 2025 年第 89 号《出口许可证管理货物目录（2026年）》, effective 2026-01-01 (ozone-depleting substances requiring an export licence, including samples and residual liquid).
• USITC, Harmonized Tariff Schedule, Chapter 29 (national and statistical lines under heading 2903); USITC Investigation No. 731-TA-1313, 1,1,1,2-Tetrafluoroethane (R-134a) from China.