Ethylene Vinyl Acetate Lauroyl Copolymer Emulsion
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3901905501 | 41.5% | CN | US | Official Doc |
| 3209100000 | 40.1% | CN | US | Official Doc |
| 3209900000 | 40.9% | CN | US | Official Doc |
| 3901306000 | 40.3% | CN | US | Official Doc |
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AI Analysis
π§ͺ Ethylene Vinyl Acetate Lauroyl Copolymer Emulsion
π HS Code Reference & Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Understand "EVA Lauroyl Emulsion"?
Ethylene Vinyl Acetate Lauroyl Copolymer Emulsion is a specialized chemical intermediate. It consists of a copolymer backbone (Ethylene-Vinyl Acetate, EVA) modified with lauroyl groups, dispersed in an aqueous or liquid medium as an emulsion.
In international trade, this product sits at a critical crossroads: 1. Is it a Plastic Polymer (Chapter 39)? If considered a primary plastic form (emulsion counts as primary form), it falls under Ethylene Copolymers. 2. Is it a Paint/Varnish/Coating (Chapter 32)? If considered a preparation based on synthetic polymers dispersed in water (latex/paint base), it falls under Paints/Varnishes.
β οΈ Key Distinction Point:
- Chapter 39 (3901): Focuses on the material nature (Ethylene Copolymer) in primary forms (including emulsions/polymers). - Chapter 32 (3209): Focuses on the functional application (Paints/Varnishes) based on synthetic polymers dispersed in water.
π¦ II. HS Code Classification Details (2026 Latest Authoritative Comparison)
Based on the provided data, here are the four most likely HS Code matches and their corresponding tax implications.
| HS Code | Product Description | Matching Logic & Summary | Total Tax Rate* |
|---|---|---|---|
| 3901.90.55.01 | Other Ethylene Copolymers (Primary Form) | β Match Success: "Copolymer Emulsion" fits "Ethylene Copolymer" material traits; Emulsion state belongs to primary forms, consistent with "Other" category. | 41.5% |
| 3209.10.00.00 | Paints/Varnishes based on Polymerized Synth. Polymers | β Match Success: "EVA-Lauroyl Copolymer" is an ethylene-based polymer; "Emulsion" is a dispersed form. Fits definition of paints/varnishes based on ethylene-based polymers. | 40.1% |
| 3209.90.00.00 | Other Paints/Varnishes based on Synth. Polymers | β Match Basis: Product is EVA-Lauroyl Copolymer Emulsion. Fits "Synthetic Polymer-based, dispersed in aqueous medium" material/form traits (General Category). | 40.9% |
| 3901.30.60.00 | Ethylene-Vinyl Acetate Copolymers (Primary Form) | β Match Success: Name explicitly contains "Ethylene" and "Vinyl Acetate". Belongs to EVA Copolymer category, fitting material traits perfectly. | 40.3% |
*Note on Tax Rate: The total tax rates listed above include Base Tariff + Additional Tariffs (Section 301) + Section 122 Tariffs, applicable to goods originating from China entering the US.
π° III. 2026 Latest Tariff Rate Breakdown (Detailed Tax Clauses)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Time: 2025/2026 (Current Trade Policy Era)
π― 1. 3901.90.55.01 β Other Ethylene Copolymers
| Item | Content |
|---|---|
| Base Tariff | 6.5% |
| Additional Tariff (Section 301) | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Rate | 41.5% |
| Tax Calculation | CIF Value Γ 41.5% |
| De Minimis Exemption | β Not Applicable (High-value chemical imports are generally subject to full duties; de minimis thresholds are often scrutinized for chemical commodities). |
| Legal Basis | HTSUS 3901.90.55.01 + USITC Footnotes for Section 301. |
π Explanation:
- This classification treats the emulsion as a raw polymer material. - The high total rate (41.5%) is driven by the combination of the base duty and multiple layers of trade remedy tariffs.
π― 2. 3209.10.00.00 β Paints/Varnishes (Polymerized Synth. Polymers)
| Item | Content |
|---|---|
| Base Tariff | 5.1% |
| Additional Tariff (Section 301) | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Rate | 40.1% |
| Tax Calculation | CIF Value Γ 40.1% |
| De Minimis Exemption | β Not Applicable |
| Legal Basis | HTSUS 3209.10.00.00 + USITC Footnotes. |
π Explanation:
- This classification views the product as a coating component. - The base tariff is slightly lower (5.1%) compared to 3901, but the additional tariffs bring the total close to the polymer classification.
π― 3. 3209.90.00.00 β Other Paints/Varnishes (Synth. Polymers)
| Item | Content |
|---|---|
| Base Tariff | 5.9% |
| Additional Tariff (Section 301) | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Rate | 40.9% |
| Tax Calculation | CIF Value Γ 40.9% |
| De Minimis Exemption | β Not Applicable |
| Legal Basis | HTSUS 3209.90.00.00 + USITC Footnotes. |
π Explanation:
- This is the "Other" category within Chapter 32. - The base tariff (5.9%) is slightly higher than 3209.10, resulting in a total of 40.9%.
π― 4. 3901.30.60.00 β Ethylene-Vinyl Acetate Copolymers
| Item | Content |
|---|---|
| Base Tariff | 5.3% |
| Additional Tariff (Section 301) | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Rate | 40.3% |
| Tax Calculation | CIF Value Γ 40.3% |
| De Minimis Exemption | β Not Applicable |
| Legal Basis | HTSUS 3901.30.60.00 + USITC Footnotes. |
π Explanation:
- This is the most precise material match for "Ethylene Vinyl Acetate" (EVA) copolymers. - It has the lowest base tariff (5.3%) among the Chapter 39 options, but the additional tariffs remain fixed at 35%.
π οΈ IV. Clearance Practical Advice (Battle-Tested Pitfall Avoidance)
β 1. Preparation Checklist (Missing Items = Delays)
| Document | Required? | Notes |
|---|---|---|
| β Technical Data Sheet (TDS) | YES | Must specify: Ethylene content, VA content, Lauroyl modification %, Solids content, Viscosity, pH. |
| β MSDS/SDS | YES | Crucial for customs and carrier approval. Classify as non-hazardous or hazardous per GHS. |
| β Certificate of Analysis (CoA) | YES | Proves the specific chemical composition to support the HS Code argument. |
| β Commercial Invoice | YES | Must clearly state "Ethylene Vinyl Acetate Lauroyl Copolymer Emulsion" β DO NOT use vague terms like "Chemical Mix". |
| β Packing List | YES | Detail net/gross weight and packaging type (drums, totes, etc.). |
| β Prior Ruling (if available) | RECOMMENDED | If you have an existing CBP ruling for this product, cite it. |
β 2. Declaration Strategy (Key Tips)
π₯ βMaterial Specific, Form Clear, Tax Justified!β
| Scenario | Correct Declaration | Risk of Wrong Declaration |
|---|---|---|
| Raw Polymer Material | 3901.30.60.00 or 3901.90.55.01 |
If declared as 3209, customs may challenge the "Paint" intent. |
| Coating Base/Paint | 3209.10.00.00 or 3209.90.00.00 |
If declared as 3901, customs may question why it's not a "preparation". |
| Vague Name ("Chemical") | REJECTED | Leads to manual examination, delays, and potential misclassification penalties. |
π Critical Note:
The distinction between Chapter 39 and Chapter 32 often hinges on the principal use and commercial expectation.
- If sold as a raw chemical intermediate for further polymerization β Chapter 39.
- If sold as a direct component for paint/adhesive formulation β Chapter 32 is often preferred by industry, but customs may still view it as a polymer if it requires further processing.
Recommendation: Provide technical data showing if it is used directly in coating formulations or as a precursor.
β 3. Special Circumptions
| Situation | Handling Advice |
|---|---|
| Is it a "Paint" or a "Polymer"? | Check the GTSUS Explanatory Notes. Emulsions of polymers are generally Chapter 39. However, if it is a preparation (e.g., with additives like pigments, dryers), it moves to Chapter 32. Pure emulsion usually stays in 3901. |
| Section 122 Tariff | Ensure the product is not on any specific exclusion list. Current data indicates it is subject to the +10% Section 122 tariff. |
| Anti-Dumping/Countervailing Duty (AD/CVD) | CHECK! EVA copolymers from China are subject to AD/CVD proceedings. Verify if this specific modified emulsion is excluded or included in existing AD/CVD orders. This can double the tax burden. |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Estimated Tax (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3901.30.60.00 / 3901.90.55.01 |
40.3% - 41.5% | N/A (Chemical) | High tariffs due to 301/122. |
| π¨π³ China | 3901.30.60.00 |
5.3% | N/A | Base rate only. |
| πͺπΊ EU | 3901.30.00 |
6.5% | REACH Registration | No Section 301/122. |
| π¬π§ UK | 3901.30.00 |
6.5% | UK REACH | Post-Brexit alignment. |
| π―π΅ Japan | 3901.30.00 |
6.0% | Fertilizer Law (if applicable) | Generally low duties. |
π Conclusion:
- USA is the most expensive market due to layered punitive tariffs.
- EU/UK/Japan have significantly lower base rates but require strict chemical compliance (REACH, etc.).
π VI. Common Errors & Pitfall Guide (Blood-Teaching Lessons)
β Error 1: Declaring as "General Chemical" or "Unknown"
π Consequence: Customs seizes shipment for lack of description β 100% seizure risk.
β Error 2: Ignoring AD/CVD on EVA Copolymers
π Consequence: If your product falls under existing AD/CVD orders for EVA, you may face additional duties of 100-300% on top of the 41.5%. Must verify AD/CVD status!
β Error 3: Misclassifying as Chapter 32 without justification
π Consequence: If it's a raw polymer emulsion, customs will reclassify to Chapter 39, leading to penalties and back taxes.
β Error 4: Not declaring Lauroyl Modification
π Consequence: Customs may treat it as standard EVA, potentially affecting the specific subheading (e.g., 3901.30 vs 3901.90).
β Correct Practice:
"Ethylene-Vinyl Acetate-Lauroyl Copolymer Emulsion, Synthetic Polymer, Primary Form, For Use in [Specific Application], MSDS Attached, TDS Attached."
π― VII. Conclusion: Professional Declaration, Cost Control!
π― Remember the Mantra:
πΉ "Chapter 39 for Raw Polymer, Chapter 32 for Paint Prep."
πΉ "Check AD/CVD first β itβs the silent killer of EVA imports."
πΉ "US Taxes are High (40%+), Plan for Cash Flow."
π Pro Tip:
- Apply for a Binding Ruling from CBP before the first shipment to lock in the HS Code.
- Verify AD/CVD Status specifically for "EVA Copolymers" from your manufacturing plant.
- Consider Supply Chain Shift if AD/CVD applies; sourcing from Vietnam/Mexico may offer tariff advantages (but verify Rules of Origin strictly).
π£ Immediate Action:
π Consult Customs Broker + Verify AD/CVD + Submit Pre-Ruling
π Clear Customs Smoothly, Protect Margins, Ensure Compliance!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every Dollar of Tax Saved is Pure Profit!
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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.