This article outlines the important classification criteria and export control measures for ceramic tableware, urging entities to focus on the following key considerations when preparing export declarations for such products.
I. Important Classification Criteria for Ceramic Tableware
The Customs categorizes ceramic tableware based on material composition and usage. When declaring exports, entities should first determine whether the items are pottery or porcelain as per the following guidelines.
As specified by the Explanatory Notes to the Commodities and Headings of the Customs Import and Export Tariff Schedule (2022), porcelain encompasses hard porcelain, soft porcelain, plain porcelain (including white porcelain), and bone china. Porcelain is almost entirely vitrified, possessing a hard texture. It remains impermeable even without glazing, is either white or can be artificially colored, and exhibits translucency (except very thick pieces). When tapped, it emits a crisp sound.
Hard porcelain is crafted from materials such as kaolin (or kaolin-like clay), quartz, feldspar (or dense feldspar), or calcium carbonate. The product is coated with a colorless, transparent glaze, which is fired simultaneously with the porcelain body and fused.
Soft porcelain contains a lower content of alumina but has a higher presence of silica and fluxes, such as feldspar.
Plain porcelain refers to unglazed porcelain, with Barlos porcelain (also known as Carrara porcelain) being a distinct type of fine-grained yellowish porcelain that has a higher feldspar content.
Bone china contains lesser amounts of alumina and mainly consists of calcium phosphate, typically derived from bone ash. It achieves translucency when fired at temperatures lower than those used for hard porcelain. The glaze is typically subjected to additional firing at reduced temperatures, permitting a broader scope for underglaze decorations.
Beyond porcelain, ceramic products encompass a variety of items such as porous ceramics, stoneware, and what is termed "semi-porcelain" or "imitation porcelain".
Distinct from porcelain, porous ceramics allow liquid penetration and can easily be scratched by iron due to their opacity.
Unlike porcelain, stoneware can be glazed (impermeable) or semi-glazed because it is compact in texture and high in hardness, not afraid of being scratched by steel tips. The clay used is grey or light brown in color due to impurities contained therein. Stoneware typically comes with a glaze.
"Semi-porcelain" or "imitation porcelain": Certain products known as "semi-porcelain" or "imitation porcelain", some of which have been blended, dressed, and glazed to give them the commercial appearance of porcelain. These products are neither as entirely opaque as pottery nor as truly translucent as porcelain. They exhibit slight translucence at their thinner parts, such as the bottoms of cups, and can be distinguished from true porcelain by their coarse, matte, non-vitrified fracture surfaces. The glaze of these products conceals a porous body that is easily scratched by a steel knife. The aforementioned "imitation porcelain" products should not be classified as porcelain but as pottery.
According to the stated regulations, porcelain ceramic tableware should fall under Heading No. 69.11. In contrast, earthenware types, including stoneware, fine pottery, and imitation porcelain, should be classified under Heading No. 69.12. In specific scenarios, where ceramic tableware is valued more for its decorative appeal than its practical use and performs worse than its undecorated counterparts, it should be categorized under Heading No. 69.13. Antique porcelain tableware older than a century should be classified under Heading No. 97.06, potentially involving special cultural heritage protection regulations.
II. Regulations Governing the Export of Ceramic Tableware
China imposes no statutory inspection requirements on the export of ceramic tableware categorized under Heading No. 69.11 and Heading No. 69.12, meaning export duties are not charged. Additionally, a 13% export tax rebate is available for these headings. Nonetheless, when exporting ceramic products to various countries and regions, compliance with the respective importing state's import certification standards is necessary. For instance, the U.S. mandates that food contact ceramics, such as tableware and cookware, obtain FDA certification and undergo FDA food-grade testing to confirm material safety and adherence to the stipulated standards.
III. Considerations for Standardized Declaration Elements
As per the Customs Import and Export Commodity Specification Declaration Catalogue of the People's Republic of China (2024 Edition), entities should ensure standardized and precise reporting of certain elements when making export declarations for ceramic tableware. These elements include the product name, the material (either porcelain or pottery), the type (such as tableware or kitchen utensils), whether it is bone china, and the brand (either in Chinese or a foreign language).
The Customs advises that entities involved in the export of ceramic tableware should thoroughly understand if their products comply with the importing state's regulations on materials that come into contact with food. It's crucial to declare all relevant items truthfully and accurately, alongside the proper customs codes, to ensure a smooth customs clearance process.
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