Chlorinated Adhesive Release Agent
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3824995000 | 41.5% | CN | US | Official Doc |
| 3824995500 | 38.7% | CN | US | Official Doc |
| 3824890000 | 41.5% | CN | US | Official Doc |
| 3824999397 | 40.0% | CN | US | Official Doc |
| 3824995000 | 41.5% | CN | US | Official Doc |
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π§ͺ Chlorinated Adhesive Release Agent
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Entry Strategy
π I. Product Definition & Classification: Do You Truly Understand "Chlorinated Release Agents"?
Chlorinated Adhesive Release Agents (often polymeric release coatings containing chlorinated polyolefins like CPO or chlorinated polyethylene) are critical chemical additives used in the manufacture of pressure-sensitive adhesives, self-adhesive labels, medical tapes, and industrial films. They prevent adhesives from bonding permanently to the backing liner until intended.
In international trade, they are generally categorized based on their chemical composition and state. The most common classification falls under Chapter 39 (Plastics) or Chapter 29 (Organic Chemicals), depending on whether it is a bulk chemical or a formulated plastic resin.
β οΈ Key Distinction Point:
- If the product is a pure chemical substance (e.g., chlorinated polyethylene resin) β Often falls under Chapter 29.
- If the product is a pre-formulated plastic resin or masterbatch intended for processing into films/fibers β Typically falls under Chapter 39.
- Most commercial "Release Agents" in granular/pellet form are classified as plastics (Chapter 39) unless they are raw chemicals sold for further chemical synthesis.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Cross-Reference)
| HS Code | Product Description | Application Scenario | Chemical Nature |
|---|---|---|---|
3901.10.00.00 |
Polyethylene, primary form | If the agent is a modified polyethylene (CPO is a chlorinated polyolefin derivative) | β Chlorinated Polyolefin |
3907.91.00.00 |
Other polyacetals, other polyethers, and their derivatives; polycarbonates... | If classified as a specialized polyester or polycarbonate derivative containing chlorine | β Specific Polymer |
3916.20.90.00 |
Monofilament, strip, etc., of plastics... | If sold as fibers or specific shaped plastics | β Processed Plastic |
3926.90.97.00 |
Other articles of plastics and articles of other materials of heading 3901 to 3914 | Most Common: For formulated release agent pellets/granules not elsewhere specified | β Formulated Resin |
2904.20.00.00 |
Sulphonated hydrocarbons; salts thereof; esters and other derivatives | If specifically a sulfonated chlorinated compound (rare for general release agents) | β Unlikely for standard CPO |
3824.99.92.00 |
Prepared binders for foundry molds...; chemical products... | If it is a liquid formulation or mixture not fitting plastic resin definitions | β Mixture/Additive |
π Critical Reminder:
- Most "Chlorinated Release Agents" in solid/pellet form are classified under3926.90.97.00(Other articles of plastics) or3901.10.00.00(if specifically Polyethylene-based).
- Liquid release agents may fall under3824.99.92.00(Prepared chemical products).
- Do not classify under adhesives (Chapter 35); release agents are anti-adhesive, not adhesives.
- If the product is a mixture of chlorinated polymers and other additives, and cannot be identified by the basic polymer, it often defaults to3926.90.97.00(Other plastics articles).
π° III. 2026 Latest Tariff Rate Details (Including Surtaxes & Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: November 10, 2025 (and onwards)
π― 1. 3926.90.97.00 ββ Other Articles of Plastics (Most Common for Formulated Release Agents)
| Item | Content |
|---|---|
| Base Rate | 5.3% (ad valorem) |
| USITC Surcharge | +25% (under USITC Footnote 83, Section 301) |
| IEEPA Surcharge | +10% (ιε―ΉδΈε½/ι¦ζΈ―δΊ§εοΌθͺ2025εΉ΄11ζ10ζ₯θ΅·) |
| Total Rate | 40.3% |
| Tax Calculation | CIF Value Γ 40.3% |
| De Minimis Exemption | β Not Eligible (deny_de_minimis) |
| Legal Path | IEEPA:9903.01.24 β USITC:3926.90.97.00 β FOOTNOTE:83 |
π Explanation:
- "USITC 25%" comes from the Section 301 tariffs on specific plastic articles and chemical products.
- "IEEPA 10%" is the new additional tariff under the International Emergency Economic Powers Act for Chinese-origin plastics.
- Total 40.3% is a high tariff, significantly impacting cost.
- No de minimis exemption: Small shipments still pay the full tariff.
π― 2. 3901.10.00.00 ββ Polyethylene, Primary Form (If Classified as Raw PE)
| Item | Content |
|---|---|
| Base Rate | 0% |
| USITC Surcharge | +25% (Section 301 applies to many plastics) |
| IEEPA Surcharge | +10% |
| Total Rate | 35% |
| Tax Calculation | CIF Γ 35% |
| De Minimis Exemption | β Not Eligible |
| Legal Path | IEEPA:9901.25 β USITC:3901.10.00.00 β FOOTNOTE:83 |
π Note:
- Even if base rate is 0%, the 35% effective rate is still very high.
- Chlorinated polyethylene (CPE) is often subclassified here or under3901.90. Check specific chemical structure.
π― 3. 3824.99.92.00 ββ Prepared Chemical Products (For Liquid/Formulated Mixtures)
| Item | Content |
|---|---|
| Base Rate | 5.3% |
| USITC Surcharge | +25% |
| IEEPA Surcharge | +10% |
| Total Rate | 40.3% |
| Tax Calculation | CIF Γ 40.3% |
| De Minimis Exemption | β Not Eligible |
π οΈ IV. Customs Clearance Practical Advice (Combat Pitfalls Guide)
β 1. Required Documentation Checklist (Missing = Delay)
| Document | Must Provide | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must include: Chemical name (e.g., Chlorinated Polyolefin), CAS number, % composition, physical form (pellet/liquid). |
| β Safety Data Sheet (SDS) | βοΈ | Must comply with GHS/OSHA standards. Classify hazards correctly. |
| β Composition Declaration | βοΈ | Detailed breakdown of ingredients. Essential for HS Code determination. |
| β Commercial Invoice | βοΈ | Must state: "Chlorinated Polyolefin Release Agent, Granular, Model XYZ". Avoid vague terms like "Chemical". |
| β Certificate of Origin (CO) | βοΈ | To verify Country of Origin (CN). |
| β Non-Pressurized Container Declaration | βοΈ | If liquid, confirm itβs not hazardous goods unless declared. |
| β Test Report | βοΈ | FCC/REACH if applicable. For plastics, may need RoHS compliance. |
β 2. Declaration Tips (Key Mantra)
π₯ "Specify the Polymer, Not the Function! Name is Key, Tax is Clear!"
| Scenario | Correct Declaration | Wrong Approach |
|---|---|---|
| Pellet/Formulated Resin | "Chlorinated Polyolefin Plastic Resin for Release Coatings" | "Release Agent" β May be questioned for classification |
| Liquid Mixture | "Prepared Chemical Release Agent, Non-Hazardous" | "Adhesive Additive" β May mislead to Chapter 35 |
| Raw Chemical | "Chlorinated Polyethylene, Primary Form" | "Plastic Granules" β Too vague |
| Mixture with Other Polymers | "Polymer Blend for Release Agent, Not Elsewhere Specified" | "Other Plastics" β Must specify "Other" (3926) |
π Crucial Advice:
- Do NOT declare as "Adhesive" (Chapter 35). Release agents are anti-adhesives.
- If the product is a blend, and the primary function cannot be determined by the basic polymer, use3926.90.97.00.
- Provide CAS numbers to prove chemical identity.
β 3. Special Cases Handling
| Case | Handling Suggestion |
|---|---|
| Liquid vs. Solid | Solid β Chapter 39; Liquid β Chapter 38 or 39 depending on formulation. |
| Hazardous Goods | If classified as hazardous (e.g., flammable), additional IMDG/IATA rules apply. Check SDS Class. |
| OEM Custom Product | Provide customer PO + technical data sheet to prove itβs a specialized plastic. |
| Samples | Declare as "Sample for Testing", but still subject to tariff if value exceeds threshold. |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification | Note |
|---|---|---|---|---|
| πΊπΈ USA | 3926.90.97.00 |
40.3% (CN) | FDA/REACH (if contact) | High tariff due to Section 301 + IEEPA |
| π¨π³ China | 3926.90.97.00 |
6.5% | CCC (if applicable) | No surcharges |
| πͺπΊ EU | 3926.90.97.00 |
6.5% | REACH Registration | No anti-dumping |
| π¦πΊ Australia | 3926.90.97.00 |
5% | AICIS | Low tariff |
| π―π΅ Japan | 3926.90.97.00 |
7.3% | PSE (if electrical) | Moderate tariff |
π Conclusion:
- USA is the highest cost market for Chinese-origin release agents due to 40.3% effective tariff.
- EU and Japan have stable, lower tariffs but strict REACH/PSE chemical regulations.
- Consider supply chain diversification (e.g., Vietnam, Thailand) to mitigate US tariffs if volume is large.
π VI. Common Errors & Pitfalls (Blood & Tears Lessons)
β Error 1: Declaring as "Adhesive" (HS 3506)
π Consequence: Customs may reclassify to 3926/3824 + penalty for misdeclaration. Release agents are not adhesives.
β Error 2: Vague Description "Chemical Agent"
π Consequence: Customs request additional info, delay clearance, or impose highest duty rate.
β Error 3: Ignoring IEEPA 10% Surtax
π Consequence: Unexpected 40.3% tax bill instead of expected 25-30%. Budget accordingly!
β Error 4: Failing to Provide CAS Number
π Consequence: Customs cannot determine if itβs a basic chemical (Ch 29) or plastic (Ch 39), leading to audit.
β Correct Practice:
"Chlorinated Polyolefin (CPO) Release Agent Pellets, Non-Hazardous, Model XYZ, CAS No. 9007-XXXX-X, For Self-Adhesive Liners"
π― VII. Conclusion: Precise Declaration Saves Thousands!
π― Remember the Mantra:
πΉ "Not an Adhesive, Itβs a Release Agent!"
πΉ "Solid = Chapter 39, Liquid = Chapter 38/39"
πΉ "Total Tax 40.3% in US, Plan Ahead!"
π Pro Tip:
If your release agents are originating from Vietnam, Mexico, or Thailand, you may qualify for IEEPA Exemption, reducing tax to 0-5%.
Recommendation: Apply for Advance Ruling with US CBP if unsure about classification.
π£ Immediate Action:
π Contact Professional Customs Broker + Provide SDS + Apply for HS Code Advance Ruling
π Ensure smooth customs clearance, minimize costs, and maximize profit margins!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every Dollar Saved is a Dollar Earned!
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About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) β Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) β More specific grouping within the chapter
- Subheading (6 digits) β Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) β Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate β The standard duty rate applied to WTO members
- General rate β Applied to countries without trade agreements
- Trade remedy duties β Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.