Classification conclusion
U.S. LPG classification depends on propane, butane or mixture composition and purity. Review base duty, China Section 301, federal excise tax and PHMSA controls.
| Field | Conclusion |
|---|---|
| Proposed HTS code | 2711190020 — Other liquefied petroleum gases, other than ethane |
| Jurisdiction | United States |
| Tariff edition | HTSUS 2026 |
| Rules applied | GIR/GRI 1 and 6 |
| Confidence | High when the entered merchandise matches the stated facts |
| Condition | Liquefied propane, butanes or commercial propane/butane LPG blends imported as bulk gas or in approved containment. |
U.S. LPG classification and duty at a glance
Liquefied petroleum gas does not have one universal U.S. reporting number. Classification turns on the imported composition and, for propane and butanes, purity.
| Product as entered | HTSUS reporting number | Column 1 General | Column 2 |
|---|---|---|---|
| Propane, at least 90 liquid volume percent purity | 2711.12.0010 | Free | Free |
| Other propane | 2711.12.0020 | Free | Free |
| Butanes, 90% or more but below 95% purity | 2711.13.0010 | Free | Free |
| Other butanes | 2711.13.0020 | Free | Free |
| Other liquefied petroleum gas mixture, excluding ethane | 2711.19.0020 | Free | Free |
The table is not a substitute for a batch composition. Ethane is separately reported under 2711.19.0010, and products containing another named liquefied hydrocarbon may fall in 2711.14 rather than the residual LPG provision.
Classification analysis under the GRIs
Under GRI 1, heading 2711 covers petroleum gases and other gaseous hydrocarbons. Chapter 27 Note 1(a) expressly preserves pure methane and propane in heading 2711 even though separately defined organic compounds are generally excluded from Chapter 27.
Under GRI 6, propane falls in 2711.12, butanes in 2711.13, and residual liquefied petroleum gases in 2711.19. The U.S. statistical suffix then turns on liquid-volume purity or whether the product is ethane. Retain a certificate of analysis showing every material constituent, test method, purity, sulfur, vapor pressure and the physical condition at entry.
An invoice stating only “LPG” cannot establish a 10-digit number. A propane/butane commercial blend ordinarily points to 2711.19.0020, while a batch meeting the propane or butane subheading language must be reported there.
Base duty and China-origin Section 301
The 2026 HTSUS base duty for 2711.12.00, 2711.13.00 and 2711.19.00 is Free in both Column 1 General and Column 2. Origin-specific duties are separate:
- China-origin LPG under these three 8-digit provisions is within the legacy Section 301 List 3 action and generally carries 25% under 9903.88.03, subject to any valid exclusion and the Chapter 99 notes in force on the entry date.
- The 2026 forced-labor Section 301 action does not add its separate duty because 2711.12.00, 2711.13.00 and 2711.19.00 are expressly listed in U.S. note 52(b); the excepted treatment is reported under 9903.05.86 when required.
- No Section 232 or Section 201 safeguard was identified for LPG under these provisions as of the review date.
- No official AD/CVD order specifically covering LPG was identified in the official searches reviewed. Written scope, origin, producer and exporter control; an HTS match alone never resolves AD/CVD.
Formal entries are generally subject to the Merchandise Processing Fee at 0.3464%, within the FY 2026 minimum and maximum, unless exempt. Commercial vessel cargo may also incur the 0.125% Harbor Maintenance Fee.
Federal excise tax is use- and transaction-specific
IRS Publication 510 treats LPG as an “other fuel,” including propane, pentane or mixtures. The March 2026 Instructions for Form 720 state a rate of USD 0.183 per gasoline gallon equivalent, with one GGE equal to 5.75 pounds or 1.353 gallons of LPG.
This excise tax is not automatically a customs-duty line on every imported LPG shipment. Liability depends on the taxable sale or use, fuel-tank delivery, registration and any nontaxable-use rule. The importer should separately evaluate Form 637 and Form 720 obligations. Publication 510 also lists the section 4611 petroleum tax on imported petroleum products at USD 0.18 per barrel, subject to the statutory product and transaction rules.
PHMSA hazardous-material requirements
LPG is a Division 2.1 flammable gas under the Hazardous Materials Regulations, 49 CFR Parts 171-180. Common descriptions include UN1075, Petroleum gases, liquefied / Liquefied petroleum gas and, for propane, UN1978, Propane. The exact proper shipping name must match the composition and must be used consistently in shipping papers, package or cargo-tank markings and emergency-response information.
The shipper, carrier and importer should verify packaging or cargo-tank authorization, filling limits, valve and pressure-relief protection, marks, labels, placards, employee training, security plans and emergency telephone information. Ocean transport also requires IMDG Code compliance; port, Coast Guard, state fire-code, pipeline and storage rules may apply independently.
Customs and compliance checklist
- Obtain the batch COA and SDS before assigning the 10-digit HTSUS number.
- Establish substantial-transformation origin; do not use the country of shipment as a substitute.
- Screen Chapter 99, sanctions, AD/CVD scope and forced-labor admissibility before entry.
- Determine whether the LPG will be sold or used as motor-vehicle or motorboat fuel for federal excise purposes.
- Confirm PHMSA proper shipping name, UN number, Division 2.1 classification and authorized containment.
- Retain invoice, bill of lading, tank certificate, quantity conversion, origin evidence and emergency-response documents.
Suggested commercial description
Liquefied petroleum gas, propane ... liquid vol.% / butanes ...%, other constituents ...%, Division 2.1, UN1075, intended use ..., HTSUS 2711.19.0020, country of origin ..., net quantity ... kg.
Replace every ellipsis with batch-specific information. For substantially pure propane or butanes, revise both the description and HTSUS reporting number.
Official sources
- USITC - current Harmonized Tariff Schedule
- USTR - China Section 301 tariff actions
- ITA ACCESS - AD/CVD search
- IRS Publication 510
- IRS Instructions for Form 720, March 2026
- PHMSA interpretation 18-0154 on LPG and propane shipping descriptions
- PHMSA hazardous-material regulations
Conclusion
Commercial propane/butane LPG blends generally point to HTSUS 2711.19.0020, with a Free base duty. Propane and butanes use the separate 2711.12 and 2711.13 reporting numbers according to purity. China origin may add 25% Section 301 under 9903.88.03, while PHMSA Division 2.1 controls and any transaction-specific federal excise tax must be handled separately.
This publication is general information, not a binding CBP ruling or legal opinion. A final entry position requires the batch composition, purity, origin, producer, intended use, packaging and entry date.
Law and tariff reviewed through September 4, 2026.
2026 U.S. customs and import-law review
Legal review date: September 5, 2026. The USITC online HTSUS identified 2026 Revision 18 on this review date. Rates and Chapter 99 measures can change during the year, so the legally operative schedule is the edition in effect on the entry date.
1. Quick legal conclusion
The proposed reporting number is 2711190020 for Other liquefied petroleum gases, other than ethane, but only for merchandise that matches this defined scope: Liquefied propane, butanes or commercial propane/butane LPG blends imported as bulk gas or in approved containment. This is a fact-dependent classification opinion, not a CBP ruling and not a determination of admissibility, origin or AD/CVD scope.
2. Facts that must be verified before entry
- Propane/butane percentages and purity
- SDS, COA, vapor pressure and sulfur
- Origin, intended use and containment
Also obtain the complete bill of materials, technical drawings, model numbers, operating manual, condition and configuration as imported, transaction chain, manufacturer/producer, country of origin of material inputs and intended U.S. use. A material difference requires a new analysis.
3. HTSUS analysis and controlling authority
- GRI 1 places petroleum gases in heading 2711; GRI 6 separates propane, butanes and residual liquefied gases.
- The invoice term LPG is insufficient without a batch COA showing composition and purity.
The analysis must begin with GRI 1, the heading text and binding Section/Chapter Notes, then proceed to GRI 2–5 only if legally necessary and to GRI 6 for subheadings. U.S. Additional Rules of Interpretation and Additional U.S. Notes are controlling where applicable. WCO Explanatory Notes are persuasive interpretive material but are not U.S. statutory text. A CROSS ruling is binding only for the requester and merchandise covered by its facts; materially similar rulings may be persuasive. CIT and Federal Circuit decisions control within their jurisdiction.
Goods outside this opinion include:
- Ethane, separately named olefins, gaseous-state products, aerosols and LPG equipment require separate classification.
For recurring or high-value entries, request a prospective binding ruling from CBP under 19 CFR Part 177 and disclose all material facts. A ruling request is not a substitute for checking post-ruling HTSUS amendments or trade remedies.
4. Duty, fee and tax matrix
| Charge | Legal treatment for this article |
|---|---|
| HTSUS Column 1 General duty | Apply the rate printed beside 2711190020 in the HTSUS edition effective on the entry date. Any rate stated elsewhere in the article remains provisional until that check is completed. |
| Merchandise Processing Fee (MPF) | Formal entries generally incur 0.3464% of entered value, excluding duty, freight and insurance, subject for FY 2026 to the CBP minimum $33.58 and maximum $651.50; an applicable preference program can alter MPF treatment. |
| Harbor Maintenance Fee (HMF) | 0.125% of value when commercial cargo is unloaded from a vessel at a covered U.S. port; it ordinarily does not apply to air freight. See 26 U.S.C. 4461–4462 and 19 CFR 24.24. |
| Section 301 / other Chapter 99 duty | Determine from the exact 8-digit HTSUS provision, country of origin, effective date and any valid exclusion. Report the required Chapter 99 number; do not assume the base HTS rate is the total landed duty. |
| Section 232 | Check current Chapter 99 notes, product/derivative coverage, origin and any required steel/aluminum/copper content, melt-and-pour or smelt-and-cast data. It does not apply merely because the article contains some metal. |
| AD duty | Not determinable from an HTS number. The written scope of an AD order is dispositive; HTS references are for convenience. Review product, producer/exporter, origin and circumvention findings. Cash-deposit and final assessment rates can differ. |
| CVD duty | The same written-scope rule applies. Confirm the case-specific company or all-others cash-deposit rate and liquidation instructions in Commerce ACCESS and ACE. |
| Safeguard / quota | Check current Chapter 99, quota and safeguard measures as of entry. Product scope, origin, quantity and quota period control. |
| Federal excise tax | Federal excise treatment depends on whether propane, butane or a mixture is sold or used as taxable fuel and on any qualifying alternative-fuel rule or exemption. It cannot be determined from heading 2711 alone. |
| State sales/use and other state taxes | These are not CBP customs duties. They depend on destination, importer nexus, later sale/use and state/local law and require a separate domestic-tax review. |
This table does not calculate landed cost. The importer must also determine customs value under 19 U.S.C. 1401a, including assists, packing, royalties/license fees, proceeds and related-party acceptability. A “first sale” claim requires a bona fide sale for export to the United States, arm's-length evidence and a complete transaction trail.
5. AD/CVD and evasion review
Do not infer trade-remedy status from the HTS number alone. Screen the country of origin, producer and written scope of every active AD/CVD order, and test any applicable Chapter 99 provision as of the entry date.
The written scope description is dispositive; an HTSUS number in an order is only a convenience reference. If coverage is uncertain, obtain a Commerce scope ruling under 19 CFR 351.225 before relying on a non-covered position. Minor processing or assembly in a third country can trigger a circumvention analysis. False origin, undervaluation or evasion can lead to EAPA investigation under 19 U.S.C. 1517 and civil penalties under 19 U.S.C. 1592.
6. Partner Government Agency and product compliance
Composition and purity data are essential both for classification and regulation. LPG is hazardous material for transportation; verify PHMSA classification, cylinders/tanks, packaging, marks, shipping papers and emergency-response information, plus federal, state and local storage requirements.
PGA admissibility is independent of tariff classification. Transmit all required agency data and documents through ACE; a CBP release does not cure a violation of an FDA, CPSC, EPA, FCC, DOT, USDA or other agency rule.
7. Origin, marking and UFLPA
Determine nonpreferential origin under the substantial-transformation test and any product-specific rule; do not rely only on the shipping country, invoice origin or location of final packing. Mark the article and, when required, its container under 19 U.S.C. 1304 and 19 CFR Part 134, unless a documented exception applies. Section 301, AD/CVD, government procurement and a preference program may use distinct origin rules.
Under 19 U.S.C. 1307 and the UFLPA, goods mined, produced or manufactured wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are subject to a rebuttable presumption of exclusion. Maintain supplier identity, production, payment, logistics and input-tracing evidence; a generic supplier declaration is not enough for a high-risk supply chain.
8. Minimum entry file
- CBP entry/cargo release data and Form 7501 record, customs bond, commercial invoice, packing list and bill of lading/air waybill.
- Purchase orders, payment records, Incoterms, assists/royalties analysis and related-party or first-sale valuation support.
- Product specifications, drawings, photographs, manuals, composition/BOM, model cross-reference and condition as imported.
- Signed classification memorandum applying the GRIs, legal notes, current HTSUS text and relevant rulings, plus rejected alternatives.
- Origin and marking analysis; producer/supplier affidavits and traceability records; Chapter 99 and exclusion support.
- AD/CVD scope search, producer/exporter case numbers and cash-deposit instructions, even when the conclusion is “not covered.”
- All PGA registrations, certificates, laboratory reports, licenses, notices and ACE data required for this product.
Keep entry and supporting records for the statutory period, generally five years, under 19 U.S.C. 1508 and 19 CFR Part 163.
9. Principal legal risks
- Declaring a 10-digit number from the trade name without proving the imported condition and legally relevant characteristics.
- Omitting a Chapter 99 number or calculating only the Column 1 rate.
- Treating an AD/CVD HTS cross-reference as dispositive instead of reading the written scope.
- Using shipping country as origin without a substantial-transformation and marking analysis.
- Filing before PGA admissibility, certificates, laboratory evidence or supply-chain traceability are complete.
An incorrect entry can produce redelivery, exclusion/seizure, duty reassessment, interest, loss of liquidation defenses and penalties. If past entries contain a material error, promptly evaluate a post-summary correction, protest, prior disclosure under 19 CFR 162.74 or other corrective procedure with U.S. customs counsel; the correct route depends on entry and liquidation status.
10. Pre-entry action checklist
1. Lock the specifications and imported configuration for the exact SKU. 2. Re-run classification against the current HTSUS and record GRI/Note reasoning. 3. Determine customs value, nonpreferential origin and marking. 4. Screen Chapter 99, Section 301/232, quota/safeguard and every potentially relevant AD/CVD scope. 5. Complete the product-specific PGA review and obtain supporting certificates before shipment. 6. Calculate landed duties and fees, then have the importer and licensed customs broker validate ACE reporting. 7. For unresolved or commercially material classification issues, obtain a CBP Part 177 ruling before importation.
Official legal sources
- United States International Trade Commission; HTSUS 2026: Harmonized Tariff Schedule of the United States
- Pipeline and Hazardous Materials Safety Administration; 49 CFR Parts 171-180: Hazardous Materials Regulations
- Internal Revenue Service; Publication 510: Excise taxes on LPG and other fuels
- USITC — Current Harmonized Tariff Schedule of the United States
- CBP — User fee table: MPF rate and FY 2026 minimum/maximum
- CBP — Harbor Maintenance Fee
- CBP — ACE: filing customs and Partner Government Agency data
- USTR — Section 301 tariff actions and exclusion search
- BIS — Section 232 steel and aluminum measures
- Commerce — AD/CVD FAQs, scope and circumvention rules
- Commerce — ACCESS AD/CVD proceeding search
- CBP — UFLPA rebuttable presumption
- CPSC — Certificates and mandatory eFiling guidance
- FDA — Importing food products into the United States
- EPA — TSCA requirements for importing chemicals
- PHMSA — Lithium battery transportation requirements
- FCC — Equipment authorization
- eCFR — 19 CFR Part 177: administrative rulings
- eCFR — 19 CFR Part 134: country-of-origin marking
- eCFR — 19 CFR Part 163: recordkeeping
> Legal notice: This article provides general U.S. customs and trade-compliance information based on the stated facts as of September 5, 2026. It is not a CBP, Commerce or PGA ruling and is not legal advice for a specific transaction. Current HTSUS/Chapter 99 text, agency requirements and case-specific AD/CVD instructions must be rechecked at entry.
Editorial note
Prepared by the Global HS Code Checker Editorial Team for customs-classification, tariff and import-policy research. The correct code and applicable measures may change with the merchandise's actual characteristics, jurisdiction, entry date and supporting record. Verify the current tariff, governing measures and competent customs authority before filing an entry. A reviewer is identified only after a named expert has completed the review.
