Ethylene Polymer Powder Coating Modifier
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3901905501 | 41.5% | CN | US | Official Doc |
| 3904400000 | 40.3% | CN | US | Official Doc |
| 3901909000 | 41.5% | CN | US | Official Doc |
| 3904905000 | 41.5% | CN | US | Official Doc |
| 3208200000 | 38.6% | CN | US | Official Doc |
AI Analysis
π§ͺ Ethylene Polymer Powder Coating Modifier
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Entry Strategy
π I. Product Definition & Classification: What Exactly is an "Ethylene Polymer Powder Coating Modifier"?
In the world of industrial coatings and materials science, an Ethylene Polymer Powder Coating Modifier is not a finished product you spray directly. It is a raw material or additive used to modify the properties (such as gloss, durability, chemical resistance, or application smoothness) of powder coatings.
Internationally, it is classified not by its end-use (coating), but by its chemical composition and physical form (primary shape, powder, or resin).
β οΈ Key Classification Distinction:
- If it is a polymer of ethylene (polyethylene or ethylene copolymers) in primary shape (powder, flakes, granules) β It falls under Chapter 39 (Plastics and Articles Thereof).
- If it is a prepared paint or varnish (mixed with pigments, solvents, or specific resins ready for application) β It falls under Chapter 32 (Tanning or Dyeing Extracts; Tannins and Their Derivatives; Dyes, Pigments and Other Painting or Coloring Preparations).
- CRITICAL POINT: Most "modifiers" are sold as pure or semi-pure ethylene-based polymers (resins) in powder form. These are HS Code 3901/3904, NOT 3208. However, if sold as a "coating preparation," it is 3208.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authorityε―Ήη §)
Based on the provided data, here are the exact HS Codes, their summaries, and the rationale for classification.
| HS Code | Product Description | Tax Rate | Tax Detail | Classification Logic |
|---|---|---|---|---|
| 3901.90.55.01 | Ethylene Polymer Raw Material, Primary Shape | 41.5% | Base: 6.5%, Section 301: 25%, Section 122: 10% | β Correct for Pure Ethylene Polymers in primary shape (powder/granules). This is the most common classification for ethylene-based resin powders used as modifiers. |
| 3904.40.00.00 | Vinyl Chloride Copolymer Raw Material, Primary Shape | 40.3% | Base: 5.3%, Section 301: 25%, Section 122: 10% | β οΈ Only if it contains Vinyl Chloride. If the "modifier" is an ethylene-vinyl chloride copolymer, it may be classified here. Check chemical composition! |
| 3901.90.90.00 | Ethylene Polymer Raw Material, Other Primary Forms | 41.5% | Base: 6.5%, Section 301: 25%, Section 122: 10% | β Alternative for Ethylene Polymers not meeting the specific subheading 3901.90.55.01. Use if the product form doesn't match 55.01 but is still ethylene-based. |
| 3904.90.50.00 | Vinyl or Other Halogenated Olefin Polymer Raw Material, Primary Form | 41.5% | Base: 6.5%, Section 301: 25%, Section 122: 10% | β οΈ For Halogenated Polymers. If the modifier contains chlorine, fluorine, etc. (halogenated), use this. Not for pure ethylene. |
| 3208.20.00.00 | Ethylene Polymer Powder Packaging Coating, Paint Type | 38.6% | Base: 3.6%, Section 301: 25%, Section 122: 10% | β ONLY if it is a "Prepared Coating". If the product is already mixed with pigments, binders, and additives for direct application as a paint/coating, it is Chapter 32. Pure ethylene powder is NOT Chapter 32. |
π Critical Note on 3208.20.00.00:
The description says "Ethylene Polymer Powder Packaging Coating, Paint Type." This implies a finished or semi-finished coating product, not a raw polymer modifier. If you are importing a raw ethylene polymer powder to be used as a modifier, 3901.90.55.01 is likely more accurate. If you are importing a ready-to-use powder coating that happens to contain ethylene polymers, use 3208.20.00.00.
π° III. 2026 Latest Tariff Rate Breakdown (Including Surcharges, Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: From November 10, 2025 (including subsequent imports)
π― 1. 3901.90.55.01 β Ethylene Polymer Raw Material, Primary Shape
| Item | Content |
|---|---|
| Base Tariff Rate | 6.5% (ad valorem) |
| USITC Additional Tariff (Section 301) | +25% |
| IEEPA Additional Tariff (Section 122) | +10% |
| Total Tariff Rate | 41.5% |
| Tax Calculation | CIF Value Γ 41.5% |
| De Minimis Exemption Eligible? | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.24 β USITC:3901.90.55.01 β FOOTNOTE:9903.88.01 |
π Explanation:
- The 6.5% base rate is the standard MFN rate for ethylene polymers.
- The 25% Section 301 tariff applies to all Chinese-origin goods in this category.
- The 10% Section 122 tariff is a specific additional duty on certain Chinese products.
- Total 41.5% is high. This is a raw material, so you cannot claim exemptions easily.
π― 2. 3904.40.00.00 β Vinyl Chloride Copolymer Raw Material, Primary Shape
| Item | Content |
|---|---|
| Base Tariff Rate | 5.3% |
| USITC Additional Tariff | +25% |
| IEEPA Additional Tariff | +10% |
| Total Tariff Rate | 40.3% |
| Tax Calculation | CIF Γ 40.3% |
| De Minimis Exemption Eligible? | β No |
| Legal Basis Path | IEEPA:9903.01.24 β USITC:3904.40.00.00 β FOOTNOTE:9903.88.01 |
π Note:
- Slightly lower total rate (40.3%) than ethylene polymers (41.5%) due to lower base rate.
- Only use if vinyl chloride is a key component. Misclassification can lead to penalties.
π― 3. 3208.20.00.00 β Ethylene Polymer Powder Coating, Paint Type
| Item | Content |
|---|---|
| Base Tariff Rate | 3.6% |
| USITC Additional Tariff | +25% |
| IEEPA Additional Tariff | +10% |
| Total Tariff Rate | 38.6% |
| Tax Calculation | CIF Γ 38.6% |
| De Minimis Exemption Eligible? | β No |
| Legal Basis Path | IEEPA:9903.01.24 β USITC:3208.20.00.00 β FOOTNOTE:9903.88.01 |
π Note:
- Lowest total rate (38.6%) among the options.
- ONLY applies if the product is a "Paint Type" or "Coating Preparation."
- If you import pure ethylene polymer powder and classify it as 3208, you risk customs rejection, fines, and back-taxes (difference between 38.6% and 41.5% is small, but classification error is serious).
π οΈ IV. Customs Clearance Practical Advice (Practical Pitfall Avoidance Guide)
β 1. Preparation Checklist (All Required)
| Document | Required | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must clearly state: "Ethylene Polymer," "Primary Shape," "Not Ready for Application" OR "Prepared Coating" |
| β Chemical Composition Report | βοΈ | Lab test showing % of ethylene, vinyl chloride, other additives. Crucial for 3901 vs 3904 vs 3208. |
| β Product Photos (Raw Form) | βοΈ | Show powder/granules in bags, NOT packaged as a finished paint can. |
| β Commercial Invoice | βοΈ | Describe as "Ethylene Polymer Powder, Raw Material for Coating Modification" OR "Ethylene-Based Powder Coating, Ready to Use" |
| β Certificate of Origin (CO) | βοΈ | Required for Section 301/122 tariff calculation. |
| β Packaging List | βοΈ | Net weight, gross weight, number of packages. |
β 2. Declaration Tips (Key Mnemonic)
π₯ "Pure Polymer β 3901/3904; Ready Coating β 3208; Mix It Up β Penalty!"
| Scenario | Correct HS Code | Wrong Action | Consequence |
|---|---|---|---|
| Pure ethylene powder (raw resin) | 3901.90.55.01 or 3901.90.90.00 |
Claim it's a "paint" β 3208 | Misclassification, audit, back-taxes |
| Ethylene-Vinyl Chloride Copolymer | 3904.40.00.00 |
Claim it's "pure ethylene" β 3901 | Possible penalty, though tax rate similar |
| Ready-to-use powder coating | 3208.20.00.00 |
Claim it's "raw material" β 3901 | Overpayment? No, underpayment risk if 3901 is 41.5% vs 3208 38.6%. But wrong category. |
| Halogenated Ethylene Polymer | 3904.90.50.00 |
Claim it's "ethylene only" β 3901 | Misclassification |
β 3. Special Cases
| Situation | Handling Advice |
|---|---|
| Custom Blend | If you mix ethylene powder with pigments, it becomes a "coating preparation" β 3208. If you just buy pure polymer β 3901. |
| OEM Private Label | Ensure the supplier provides a Certificate of Analysis (COA) proving it's a raw polymer, not a pre-mixed coating. |
| Small Sample Imports | Even samples are subject to tariffs if declared as commercial goods. Use Section 321 if eligible (but usually denied for Chinese goods). |
| Packaging as "Paint" | If the product is shipped in paint cans, customs may assume it's 3208. Ensure documentation clearly states "Raw Material, Not for Direct Application." |
π V. Global Market Customs Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3901.90.55.01 |
41.5% | No specific | High tariff, strict classification. |
| π¨π³ China | 3901.90.55.01 |
6.5% | No | Low tariff for domestic import. |
| πͺπΊ EU | 3901.90.90 |
6.5% | REACH | No Section 301/122 tariffs. |
| π¬π§ UK | 3901.90.90 |
6.5% | UKCA | Post-Brexit, similar to EU. |
| π¦πΊ Australia | 3901.90.90 |
5.0% | AICIS | Low tariff, no US-style surcharges. |
| π―π΅ Japan | 3901.90.90 |
5.0% | JIS | Low tariff, no surcharges. |
π Conclusion:
- USA is the most expensive market due to Section 301 and Section 122 tariffs.
- China, EU, UK, AU, JP have much lower base tariffs (5-6.5%).
- If your final market is not the USA, consider shipping directly to avoid US tariffs.
π VI. Common Errors & Pitfall Guide (Lessons from Experience)
β Error 1: Calling a raw ethylene polymer a "Paint" to get 3208 (38.6%) instead of 3901 (41.5%).
π Consequence: Customs will reject it for misclassification, demand proper HS code, and charge penalties. The savings are minimal (2.9%), but the risk is high.
β Error 2: Not distinguishing between Ethylene (3901) and Vinyl Chloride (3904).
π Consequence: If the product contains vinyl chloride, classifying as 3901 is wrong. 3904 has different chemical regulations (REACH, TSCA).
β Error 3: Assuming Powder Form = Chapter 32.
π Consequence: Powder coatings can be raw materials (Chapter 39) or prepared paints (Chapter 32). Use COA to prove composition.
β Error 4: Ignoring Section 122 Tariff.
π Consequence: Forgetting the 10% surcharge leads to underpayment and interest fees.
β Correct Action:
"Ethylene Polymer Powder, Raw Material, For Coating Modification, Not Ready for Application, CAS No. XXXXX"
π― VII. Conclusion: Precision Classification Saves Money and Time!
π― Remember the Mantra:
πΉ "Raw Polymer β 3901/3904; Ready Coating β 3208; Pure Ethylene β 41.5%; Vinyl Copolymer β 40.3%; Paint Type β 38.6%."
πΉ "HS Code is Law; Tax Rate is Consequence; Documentation is Your Shield!"
π Pro Tip:
If your product is pure ethylene polymer, 3901.90.55.01 is the safest and most accurate code. If you are mixing it with pigments, it becomes 3208.20.00.00. Always provide a Certificate of Analysis (COA) to customs.
π£ Immediate Action:
π Contact your customs broker + Provide COA + Confirm "Raw Material" status
π Ensure smooth clearance, avoid penalties, and optimize costs!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every cent counts in global trade!
Customer Reviews
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.