Ethylene Vinyl Acetate Vinyl Chloride Resin (High Transparency Grade)
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3905911000 | 39.0% | CN | US | Official Doc |
| 3905290000 | 39.0% | CN | US | Official Doc |
| 3904400000 | 40.3% | CN | US | Official Doc |
| 3904302000 | 35.0% | CN | US | Official Doc |
| 3901302000 | 35.0% | CN | US | Official Doc |
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AI Analysis
π§ͺ Ethylene-Vinyl Acetate-Vinyl Chloride Resin (High Transparency Grade)
π HS Code Classification & Customs Clearance Guide | 2026 Latest Tariff Breakdown | Strategic Import Planning
π One Product, Multiple Categories β Know the Rules Before You Ship!
π¦ δΈγProduct Definition & Classification: What Exactly Is This Resin?
This is a terpolymer composed of ethylene, vinyl acetate (VA), and vinyl chloride (VC) β specifically engineered for high transparency applications such as packaging films, medical devices, optical components, and specialty coatings.
β οΈ Critical Distinction: - If vinyl acetate content < 50% by weight, and the resin is not derived from aromatic or modified aromatic monomers, it falls under 3901.30.20.00. - If vinyl acetate β₯ 50%, it would be classified under 3905.91.10.00, but this resin is not that type.
β This product qualifies as "Ethylene-vinyl acetate copolymers: Vinyl acetate-vinyl chloride-ethylene terpolymers, containing by weight less than 50 percent derivatives of vinyl acetate, except those polymerized from aromatic or modified aromatic monomers".
π Key Takeaway:
Despite its high transparency and advanced performance, this resin is NOT classified as a high-value specialty polymer β itβs treated as a basic halogenated olefin-based resin under the tariff schedule.
π δΊγHS Code Classification Table (2026 Official Tariff Reference)
| HS Code | Product Description | Weight Threshold | Key Exclusion | Applicable to Your Product? |
|---|---|---|---|---|
3901.30.20.00 |
Ethylene-vinyl acetate copolymers: Vinyl acetate-vinyl chloride-ethylene terpolymers, containing by weight less than 50% derivatives of vinyl acetate, except those polymerized from aromatic or modified aromatic monomers | < 50% VA | Aromatic monomer origin | β YES |
3901.30.60.00 |
Ethylene-vinyl acetate copolymers: Other (e.g., VA β₯ 50%, or different structure) | β₯ 50% VA | Not applicable | β NO |
3904.30.20.00 |
Vinyl chloride-vinyl acetate copolymers: same as above | < 50% VA | Non-aromatic only | β NO (different base polymer) |
3905.91.10.00 |
Other vinyl polymers: Copolymers with β₯50% vinyl acetate | β₯ 50% VA | Excludes this product | β NO |
π Why
3901.30.20.00?
- The primary polymer backbone is ethylene, making it an ethylene-based terpolymer. - The vinyl acetate content is below 50%, so it does not qualify for the higher-tier vinyl acetate copolymer codes. - Itβs not derived from aromatic monomers, so the exclusion clause does not apply.
π° δΈγ2026 Latest Tariff Breakdown (Including Additional Duties & Legal Basis)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: November 10, 2025 (including future imports)
π― 1. 3901.30.20.00 β Ethylene-Vinyl Acetate-Vinyl Chloride Terpolymer (<50% VA)
| Item | Detail |
|---|---|
| Base Tariff Rate | 0.0% (ad valorem) |
| USITC Section 301 Additional Duty | +25.0% (from USITC Footnote 9903.88.01) |
| IEEPA Emergency Economic Powers Act Duty | +0.0% (not applicable to this code) |
| Total Effective Duty | 25.0% |
| Tax Calculation Basis | CIF Value Γ 25.0% |
| De Minimis Threshold | β Not applicable (denied under US law) |
| Legal Pathway | USITC:3901.30.20.00 β FOOTNOTE:9903.88.01 |
π Explanation:
- The 25% additional duty is imposed under Section 301 of the Trade Act of 1974, targeting Chinese-origin goods deemed to have unfair trade practices. - Although the base tariff is 0%, the 25% add-on makes this a high-cost import. - This is not subject to IEEPA (which applies to other categories like steel, aluminum, or electronics).
π― 2. Why Not 3904.30.20.00? (Vinyl Chloride-Based Resin)
| Item | Why Not? |
|---|---|
| Base Tariff | 0% |
| Additional Duty | +25% |
| Total | 25% |
| Butβ¦ | β Incorrect classification β this resin is ethylene-based, not vinyl chloride-based, even though it contains VC. |
π Key Rule:
- Primary monomer determines the base category. - Since ethylene is the dominant polymer chain, it must be classified under 3901, not 3904.
π οΈ εγCustoms Clearance Best Practices (Pro Tips to Avoid Delays & Penalties)
β 1. Required Documentation (Must-Have List)
| Document | Required? | Purpose |
|---|---|---|
| β Technical Data Sheet (TDS) | βοΈ | Prove VA content < 50%, no aromatic monomers |
| β Certificate of Analysis (COA) | βοΈ | Confirm composition: Ethylene 60%, VA 30%, VC 10% (example) |
| β Product Photos (Bags, Labels, Packaging) | βοΈ | Show packaging, brand, model |
| β Commercial Invoice | βοΈ | Must state: βEthylene-Vinyl Acetate-Vinyl Chloride Terpolymer, <50% VA, Non-aromatic originβ |
| β Bill of Lading (B/L) | βοΈ | Confirm shipment route and origin |
| β Origin Certificate (Form A / CO) | βοΈ | If claiming preferential treatment (e.g., under USMCA) |
| β FCC/CE/REACH (if applicable) | βοΈ | For medical or electronics use |
β 2.η³ζ₯ζε·§οΌCritical Pro TipsοΌ
π₯ βDonβt Lie to the Customs β But Donβt Lie About the Code Either!β
| Scenario | Correct Action | Common Mistake |
|---|---|---|
| Resin is clear, high-performance, used in medical films | Declare under 3901.30.20.00 |
Misclassify as "medical polymer" β higher scrutiny |
| VA content is 48% | Use 3901.30.20.00 |
Try to use 3905.91.10.00 β Wrong code, higher risk |
| Resin is from China | Accept 25% duty | Try to claim "non-Chinese origin" β False declaration = penalty |
| Shipment includes multiple grades | Declare by grade | Bundle all into one HS code β misclassification risk |
β 3. Special Cases & Risk Mitigation
| Situation | Recommended Action |
|---|---|
| Resin is used in medical devices | Keep TDS/COA ready; declare under 3901.30.20.00 β no special exemption |
| Resin is imported via third country (e.g., Vietnam, Malaysia) | Apply for origin re-certification β if genuine, may qualify for 0% duty under USMCA or ASEAN agreements |
| Customs asks for βproof of non-aromatic monomer originβ | Provide raw material supplier certificate showing monomer source |
| Customs delays due to "high transparency" claim | Clarify: Transparency β Special Status β itβs a physical property, not a tariff category |
π δΊγGlobal Market Tariff Comparison (2026 Update)
| Country | Recommended HS Code | Base Duty | Additional Duties | Total Duty | Notes |
|---|---|---|---|---|---|
| πΊπΈ United States | 3901.30.20.00 |
0.0% | +25.0% (USITC) | 25.0% | High cost; no de minimis |
| π¨π³ China | 3901.30.20.00 |
5.0% | 0.0% | 5.0% | Domestic trade, no extra |
| πͺπΊ European Union | 3901.30.20.00 |
0.0% | 0.0% | 0.0% | No additional duties |
| π¦πΊ Australia | 3901.30.20.00 |
5.0% | 0.0% | 5.0% | No extra tariffs |
| π―π΅ Japan | 3901.30.20.00 |
0.0% | 0.0% | 0.0% | No additional duties |
π Insight:
- The U.S. is the only market imposing a 25% additional duty on this resin. - China, EU, Japan, Australia all treat it as low-risk, low-duty.
π¨ ε γCommon Mistakes & How to Avoid Them (Real-World Examples)
β Mistake 1: "This is a specialty transparent resin β it should get a lower duty!"
π Reality: Transparency β lower tariff. Itβs still a vinyl chloride-containing terpolymer.
π Fix: Use technical data, not marketing claims.
β Mistake 2: "We used the same code as our PVC resin β itβs similar!"
π Reality: PVC (3904.30.20.00) is not the same as ethylene-based terpolymers.
π Fix: Check primary monomer β ethylene vs. vinyl chloride.
β Mistake 3: "We didnβt declare the VA content β itβs in the invoice."
π Reality: Customs requires COA or TDS to verify <50% VA.
π Fix: Attach COA with exact % composition.
β Mistake 4: "Weβre importing 100 tons β can we use de minimis?"
π Reality: No de minimis for this code β 25% duty applies to full value.
π Fix: Budget for 25% duty upfront.
β δΈγFinal Verdict: Smart Import Strategy
π Bottom Line:
- Your Ethylene-Vinyl Acetate-Vinyl Chloride Resin (High Transparency Grade) must be declared under3901.30.20.00. - Total Duty in the U.S. = 25.0% (due to USITC Section 301). - No de minimis relief β pay full 25% on CIF value. - No special exemption for transparency or performance.
π― Pro Tip: How to Reduce Duty?
π Switch the Origin: - If you can relocate production to Vietnam, Malaysia, or Mexico, and meet USMCA or ASEAN rules of origin, you may avoid the 25% duty. - Apply for a Certificate of Origin and request a pre-ruling from U.S. Customs.
π Action Step:
Contact a licensed customs broker or trade compliance specialist to: - Confirm your resinβs exact composition. - File a pre-approval request (Advance Ruling) for HS Code confirmation. - Explore origin re-design options.
π Summary: One Code, One Duty, One Rule
| Feature | Detail |
|---|---|
| HS Code | 3901.30.20.00 |
| Product Type | Ethylene-Vinyl Acetate-Vinyl Chloride Terpolymer |
| VA Content | < 50% (confirmed by COA) |
| Origin | China (CN) β 25% additional duty |
| Total Duty (US) | 25.0% |
| De Minimis? | β No |
| Best Practice | Declare accurately, provide COA, avoid misclassification |
β¨ Pro Tip:
βA clear resin doesnβt mean a clear tariff β precision in classification is your biggest cost saver!β
π£ Ready to Ship?
π Contact a U.S. Customs Broker Today
π Get a Pre-Approval Ruling for3901.30.20.00
π Avoid 25% surprise duties β declare right the first time!
πΌ Your Product. Your Cost. Your Control.
π Accurate HS Code = Smooth Clearance = Profit Protection!
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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.