Epoxy Mortar
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 6810990080 | 35.0% | CN | US | Official Doc |
| 3824500010 | 35.0% | CN | US | Official Doc |
| 3824500050 | 35.0% | CN | US | Official Doc |
| 6810195000 | 38.9% | CN | US | Official Doc |
| 3907300000 | 41.1% | CN | US | Official Doc |
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AI Analysis
𧱠Epoxy Mortar: The High-Performance Construction Adhesive
π HS Code Classification & US Customs Clearance Guide | 2024-2026 Tax Analysis | Expert Compliance Strategy
π I. Product Definition: What is "Epoxy Mortar"?
Epoxy mortar is a high-performance, two-component (resin + hardener) or pre-mixed construction material used for industrial flooring, structural repairs, and chemical-resistant coatings. It consists of epoxy resin combined with graded aggregates (sand, quartz, etc.).
In international trade, its classification is highly disputed because it straddles the line between a chemical resin and a construction stone product. The correct HS Code depends on whether customs views the epoxy as the "binder" of a composite stone or as a "chemical preparation."
β οΈ Critical Distinction:
- If classified as Resin/Chemical: Treated as a raw material β Higher base duties in some contexts, but specific Section 301 exemptions may apply differently.
- If classified as Stone/Ceramic: Treated as a finished construction good β Different duty structures.
- US Import Reality: For goods originating from China, most classifications attract Section 301 (25%) + Section 122 (10%) additional tariffs, resulting in total tax rates of 35%-41.1%.
π¦ II. HS Code Classification Details (Based on Provided Data)
The following 5 HS Codes are the most common classifications for Epoxy Mortar. All are subject to significant additional tariffs if imported from China to the US.
| HS Code | Product Description (Summary) | Tax Category | Total Tax Rate* | Key Classification Logic |
|---|---|---|---|---|
6810.99.00.80 |
Other Articles of Artificial Stone | Man-made stone products | 35.0% | Viewed as a finished article of artificial stone, where epoxy acts as the binder. |
3824.50.00.10 |
Non-refractory mortars and concretes | Chemical preparations | 35.0% | Viewed as a chemical mortar mix, excluding refractory types. |
3824.50.00.50 |
Other Non-refractory mortars and concretes | Chemical preparations (Other) | 35.0% | Similar to above, but under a different "other" sub-category for non-refractory mixes. |
6810.19.50.00 |
Other articles of artificial stone | Man-made stone products | 38.9% | Base duty of 3.9% applies here, plus additional tariffs. |
3907.30.00.00 |
Epoxy Resins in Primary Forms | Primary Resins | 41.1% | Viewed primarily as the resin component itself, with sand considered incidental. |
π Key Insight:
- Lowest Duty Option:3824.50.00.10and3824.50.00.50offer the 35.0% total rate (0% base + 25% Sec 301 + 10% Sec 122).
- Highest Duty Option:3907.30.00.00incurs the 41.1% total rate (6.1% base + 25% Sec 301 + 10% Sec 122).
- Risk Factor: Classifying as "Primary Epoxy Resin" (3907.30.00.00) is risky because epoxy mortar contains aggregates/sand. Customs may argue it is a prepared mixture (3824), not a primary resin.
π° III. 2024-2026 Detailed Tax Breakdown & Legal Basis
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Period: 2025-2026 (Current Enforcement)
π― 1. The "35% Tier" (3824.50.00.10 & .50)
Scenario: Classified as a chemical mortar/concrete mixture.
| Item | Detail |
|---|---|
| Base Tariff (MFN) | 0.0% |
| Section 301 Tariff | +25.0% (China-specific, USITC Footnote) |
| Section 122 Tariff | +10.0% (Specific additional duty on certain Chinese goods) |
| Total Effective Rate | 35.0% |
| Calculation | CIF Value Γ 35.0% |
| De Minimis Exemption? | β NO (Valuation > $800 triggers full duty) |
| Legal Path | HTSUS:3824.50 β USITC:301 β IEEPA:122 |
π Explanation:
- These codes are preferred by importers because the base duty is 0%.
- However, the 35% total is still high due to trade war tariffs.
π― 2. The "38.9% Tier" (6810.19.50.00)
Scenario: Classified as an article of artificial stone (construction material).
| Item | Detail |
|---|---|
| Base Tariff (MFN) | 3.9% |
| Section 301 Tariff | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Effective Rate | 38.9% |
| Calculation | CIF Value Γ 38.9% |
| De Minimis Exemption? | β NO |
π― 3. The "41.1% Tier" (3907.30.00.00)
Scenario: Classified as primary epoxy resin (ignoring aggregates).
| Item | Detail |
|---|---|
| Base Tariff (MFN) | 6.1% |
| Section 301 Tariff | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Effective Rate | 41.1% |
| Calculation | CIF Value Γ 41.1% |
| De Minimis Exemption? | β NO |
π Warning:
- This is the most expensive classification.
- Customs may reject this if the product contains >10% aggregates, as it is no longer a "primary form" of resin.
π οΈ IV. Customs Clearance & Compliance Advice
β 1. Documentation Checklist (Must-Haves)
| Document | Requirement | Purpose |
|---|---|---|
| Safety Data Sheet (SDS) | βοΈ Mandatory | Must specify it is a "Mortar" or "Composite," not pure resin. Proves chemical nature. |
| Product Specification | βοΈ Mandatory | Clearly state: "Epoxy Resin + Sand/Aggregate." |
| Commercial Invoice | βοΈ Mandatory | Describe as "Epoxy Mortar for Floor Repair" β Avoid vague terms like "Glue" or "Resin." |
| Bill of Lading | βοΈ Mandatory | Ensure weight/volume matches invoice. |
| Certificate of Origin | βοΈ Recommended | To prove CN origin (triggering tariffs) or other origin (if applicable). |
β 2. Classification Strategy (The "Goldilocks" Zone)
| Strategy | HS Code Choice | Pros | Cons |
|---|---|---|---|
| Safest | 3824.50.00.10 |
Low base duty (0%), clear "mortar" definition. | Must provide SDS proving it's a mixture, not pure resin. |
| Risky | 3907.30.00.00 |
Simple to describe as "Resin." | High base duty (6.1%), high total tax (41.1%), high audit risk. |
| Alternative | 6810.99.00.80 |
Fits "Artificial Stone" narrative. | Slightly higher total tax (35% vs 35%, but base is higher). |
π‘ Pro Tip:
Always classify under3824.50if possible. It aligns with the physical reality (a mortar mix) and offers the lowest base duty. Avoid3907.30unless you are importing pure epoxy resin without aggregates.
β 3. Common Pitfalls to Avoid
| Mistake | Consequence | Solution |
|---|---|---|
| Mislabeling as "Pure Epoxy" | Customs assesses higher base duty + penalties. | Label clearly as "Epoxy Mortar" or "Epoxy Concrete." |
| Ignoring Section 122 | Underpayment of duties, holds at border. | Ensure your broker includes the 10% Sec 122 in calculation. |
| Using De Minimis (Section 321) | Small shipments (<$800) may be seized for missing data. | For >$800, full formal entry is required. |
| Vague Description | "Construction Adhesive" β Ambiguous classification. | Use specific terms: "Two-component epoxy mortar with quartz aggregate." |
π V. Global Market Comparison (2026 Outlook)
| Region | HS Code | Total Duty (China Origin) | Notes |
|---|---|---|---|
| πΊπΈ USA | 3824.50.00.10 |
35.0% | Includes 25% Sec 301 + 10% Sec 122. |
| π¨π³ China (Import) | 3824.50.00.10 |
~5-10% | No Sec 301/122. MFN duty is low. |
| πͺπΊ EU | 3907.30 or 3824 |
6-14% | No Section 301. Varies by country. |
| π¬π§ UK | 3824.50 |
6% | Post-Brexit tariffs. |
| π¨π¦ Canada | 3824.50 |
0-5% | CUSMA benefits may apply. |
π Conclusion:
The US market is the most expensive due to layered tariffs. Importers should consider:
1. Supply Chain Diversification: Source from Vietnam/Mexico to avoid Sec 301.
2. Pre-Ruling: Apply for a CBP Binding Ruling to secure the3824.50classification.
3. Cost-Benefit Analysis: With 35% tax, ensure margins can absorb the cost or pass it to consumers.
π VI. Final Clearance Checklist
- [ ] Product Description: "Epoxy Mortar" (Not "Resin")
- [ ] HS Code:
3824.50.00.10(Preferred) - [ ] Tax Rate: 35% (0% Base + 25% Sec 301 + 10% Sec 122)
- [ ] SDS Provided: Yes
- [ ] Origin: China (CN) β Tariffs Apply
π― Expert Advice:
"Don't let the 'Resin' label fool you. If it has sand, it's mortar. Classify as
3824.50to save 6% in base duties. Prepare for 35% total tax. Always get a Binding Ruling if your shipment volume is high."
β¨ Disclaimer:
This guide is for informational purposes only. Tariff rates and HS Code classifications are subject to change. Always consult a licensed customs broker or legal expert for specific import shipments.
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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.