Air fryer liners HTS 4823.90.6700 & 3924.10.4000: paper vs silicone split
GRI 1CBP classified the paper air fryer liners under HTS 4823.90.6700 at a free base rate and the silicone liners under HTS 3924.10.4000 at 3.4%, splitting the two by their material rather than treating either as an appliance part.
The obvious temptation is to file both liners as parts or accessories of an air fryer under heading 8516 or 8509, since they are sold to go with the appliance. CBP did not do that. A liner isn't integral to how the air fryer works — it is a consumable or a separate reusable insert — so classification follows the material of the article itself under GRI 1. The 36 gsm silicone-oil-coated paper disk, cut to shape, lands squarely in Chapter 48 as an other article of coated paper (4823.90.6700). The reusable food-safe silicone insert is a plastic household/kitchen article, so it goes to 3924.10.4000. Same commercial use, two different chapters, two different base rates. Final classification depends on the importer's actual product and should be confirmed by a licensed customs broker.
- Separate the two SKUs on the commercial invoice — paper and silicone carry different HTS lines and different duty math.
- Confirm the paper weight and coating (gsm, silicone-oil both sides) so the coated-paper subheading holds up.
- Budget for the China add-ons: verify current 9903.01.24 status for both, plus 9903.88.03 on the paper line at entry.
| Path | Code | Base duty |
|---|---|---|
| Silicone liner as plastic kitchenware (CBP) | 3924.10.4000 | 3.4% |
| If instead filed as coated-paper article (paper liner path) illustrative | 4823.90.6700 | Free |
| On a $10,000 silicone-liner shipment, the 3.4% base duty is $340; the paper-liner line at a free base rate is $0 in base duty on the same value. That is base-rate math only. Both goods are China-origin, so the China add-ons apply on top: the 20% under 9903.01.24 (both lines) and 25% under 9903.88.03 (paper line) as stated in the ruling. Those Chapter 99 amounts are variables — this assumes the goods remain subject to those measures at entry, and current Chapter 99 status and any exclusions should be verified before filing. | ||
Illustrative comparison only. The alternative heading is one contrast possibility — the exact subheading for a different product configuration would need separate analysis (other Chapter 84/85 or specific provisions may apply). Any Section 301 / Chapter 99 figure assumes the goods remain subject to that measure at the time of entry; always verify the current Chapter 99 status and any applicable exclusions.
- Filing both liners under one HTS line to simplify entry — they legitimately split by material and the duty consequences differ.
- Overlooking the paper line's second Chapter 99 heading (9903.88.03, +25%) on top of the 9903.01.24 add-on.
- Treating the liners as air-fryer 'parts' under Chapter 85, which does not match how CBP handled them here.
- Paper liner arrives uncoated or below the coated-paper description → It may shift to a different Chapter 48 subheading and the free rate could change.
- Silicone liner is redesigned to lock into or form part of the basket assembly → It could arguably move toward an appliance-part heading in Chapter 85 rather than plastic kitchenware.
- Liner is made of aluminum foil instead of paper or silicone → Classification would move to the relevant Chapter 76 aluminum household-article heading with its own rate.
Accessories that ship alongside an appliance rarely follow the appliance's HTS. This ruling is a clean reminder that a liner is classified by what it's made of, and that two look-alike SKUs in one box can land in two chapters with two duty outcomes.
- List paper and silicone liners as separate invoice lines with quantities and unit values.
- Keep a spec sheet: paper gsm, both-side silicone-oil coating, cut-to-shape dimensions.
- Confirm the silicone item is food-contact plastic, reusable, with the side handles as described.
- State China origin and pull current 9903.01.24 and 9903.88.03 status before filing.
- Reference this ruling's control number with the entry if your product matches the facts.
- Have a licensed broker confirm the final codes against your actual goods.
Why are paper air fryer liners HTS 4823.90.6700 and silicone ones 3924.10.4000?
CBP classified each by its material rather than as an appliance part — coated paper cut to shape falls in Chapter 48, and food-safe silicone is plastic kitchenware in Chapter 39. Confirm your product with a licensed broker.
Are air fryer liners from China subject to Section 301 duties?
In this ruling both liners were products of China subject to the 20% add-on under 9903.01.24, and the paper line also carried 25% under 9903.88.03. Chapter 99 status changes, so verify current headings and exclusions before entry.
Can I classify air fryer liners as parts of the air fryer under Chapter 85?
CBP did not treat these liners as appliance parts. A consumable or removable insert isn't integral to the machine's operation, so classification followed the liner's material. Final treatment depends on your actual product.
What is the base duty rate on silicone air fryer liners under HTS 3924.10.4000?
The ruling states a 3.4% ad valorem base rate for the silicone liners. Any China Chapter 99 add-ons apply on top and should be verified at entry; confirm with a licensed customs broker.
Do paper air fryer liners really enter duty-free under HTS 4823.90.6700?
The base rate stated in this ruling for the coated-paper liners was free, but the goods were still subject to China Chapter 99 add-ons (9903.01.24 and 9903.88.03). Verify current status before relying on the free base rate.