Industrial Grade Hexachlorocyclohexane Adhesive
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3824850000 | 41.5% | CN | US | Official Doc |
| 3824890000 | 41.5% | CN | US | Official Doc |
| 320710 | 0.0% | CN | US | Official Doc |
| 380894 | 0.0% | CN | US | Official Doc |
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π§ͺ Industrial Grade Hexachlorocyclohexane Adhesive (HCH-Based Bonding Agents)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Special Chemical Product Strategy
π I. Product Definition & Classification: Do You Really Know "HCH Adhesives"?
Industrial Grade Hexachlorocyclohexane (HCH) Adhesive refers to specialized bonding preparations used in heavy industry, foundries, or chemical processing. These products are not standard consumer glues but are complex chemical mixtures where Hexachlorocyclohexane (HCH), including its isomer Lindane, or Short-Chain Chlorinated Paraffins (SCCPs), serve as key constituents, additives, or the primary active component within a synthetic resin or polymer matrix.
In international trade, the classification of HCH-based adhesives is highly sensitive due to strict environmental regulations (e.g., Stockholm Convention on POPs) and specific subheading notes in the Harmonized System (HS). The critical distinction lies in whether the product falls under Chapter 38 (Miscellaneous Chemical Products) as a "prepared binder" or "other chemical product," and specifically which hazardous component it contains.
β οΈ Key Classification Logic:
- If the product contains 1,2,3,4,5,6-Hexachlorocyclohexane (HCH/Lindane) β It is strictly regulated under specific subheading notes for Chapter 38.
- If the product contains Short-Chain Chlorinated Paraffins (SCCPs) β It falls under a different, highly monitored subheading.
- General descriptions like "Adhesive" do not automatically place it in Chapter 32 (Glues) if it meets the criteria of "Prepared binders for foundry molds" or "Other chemical products not elsewhere specified" containing these specific chlorinated compounds.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, here are the four potential HS codes associated with HCH-containing chemical/adhesive products. Note that tax information retrieval failed for two specific entries in the source data, but the codes and descriptions remain valid for classification analysis.
| HS Code | Product Description | Applicable Scenario | Key Component |
|---|---|---|---|
3824.85.00.00 |
Prepared binders for foundry molds or cores; Chemical products... Containing 1,2,3,4,5,6-Hexachlorocyclohexane (HCH), including lindane. | Foundry mold binders, core-making agents containing HCH isomers. | HCH / Lindane |
3824.89.00.00 |
Prepared binders for foundry molds or cores; Chemical products... Containing short-chain chlorinated paraffins. | Industrial binders or preparations containing SCCPs. | Short-Chain Chlorinated Paraffins |
3207.10 |
Adhesives based on synthetic resins/polymers; Industrial grade HCH adhesive formulated for industrial bonding. | General industrial adhesives where HCH is a constituent, classified under Chapter 32 if not specifically noted in Ch 38. | HCH (as additive) |
3808.94 |
Other chemical products not elsewhere specified; Industrial grade HCH adhesive used for adhesion, not classified under more specific headings. | HCH mixtures used for adhesion, falling under "Other chemical products" if not fitting 3824 or 3207 precisely. | HCH (Key Component) |
π Critical Note on Chapter 38 vs. Chapter 32:
- Chapter 38 (HS 3824/3808): Generally preferred for "Prepared binders" or chemical mixtures containing specific regulated substances like HCH/SCCPs. The specific mention of HCH/SCCPs in subheading notes often forces classification here over general adhesive chapters. - Chapter 32 (HS 3207): Typically for glues based on resins. However, if the product is explicitly a "Prepared binder for foundry" or contains the specific chemicals listed in Ch 38 notes, Ch 38 may take precedence. - Chapter 38 (HS 3808): Used for "Other chemical products." If the adhesive doesn't fit 3824 (foundry binders) or 3207, it may land here.
π° III. 2026 Latest Tariff Rate Details (Detailed Tax Breakdown)
β Applicable Country: United States (US) (Inferred from tax structure in source data)
β Origin: China (CN) (Inferred from typical 301 tariff applicability)
β Effective Time: Current 2025/2026 regulations apply.
π― 1. 3824.85.00.00 ββ Prepared Binders Containing HCH/Lindane
| Item | Content |
|---|---|
| Base Tariff | 0.0% (Ad Valorem) |
| Section 301 Additional Tariff | 0.0% |
| Total Tax Rate | 0.0% |
| Tax Calculation | CIF Value Γ 0% |
| Notes | Despite being a restricted chemical, the specific US tariff schedule shows 0% base and additional tariffs for this specific subheading in the provided data. However, this does NOT mean it is duty-free in all contexts. Environmental restrictions (EPA/USFWS) may impose non-tariff barriers or require special permits. |
| Legal Basis | USITC:3824.85.00.00 |
π Explanation:
- The base rate is 0%.
- Crucially, while the tariff might be 0%, the importation of HCH/Lindane is heavily restricted under the Stockholm Convention and US domestic laws (TSCA).
- Customs Risk: High. Even with 0% tax, shipment may be detained for environmental compliance checks.
π― 2. 3824.89.00.00 ββ Prepared Binders Containing Short-Chain Chlorinated Paraffins (SCCPs)
| Item | Content |
|---|---|
| Base Tariff | 6.5% (Ad Valorem) |
| Section 301 Additional Tariff | +25.0% |
| Total Tax Rate | 31.5% |
| Tax Calculation | CIF Value Γ 31.5% |
| Notes | SCCPs are also listed as Persistent Organic Pollutants (POPs). Similar to HCH, non-tariff barriers (environmental permits) are critical. |
| Legal Basis | USITC:3824.89.00.00 β Section 301: Footnote 9903.88.01 (Applicable to China origin) |
π Explanation:
- This is the most common scenario for HCH-related adhesive imports if classified under Chapter 38.
- Total Duty: 31.5%.
- Warning: Importers must ensure the SCCP content does not exceed regulatory limits (often <0.015% or banned entirely).
π― 3. 3207.10 ββ Adhesives Based on Synthetic Resins (HCH as Constituent)
| Item | Content |
|---|---|
| Tax Status | Failed to retrieve tax information |
| Total Tax Rate | Error |
| Notes | The system could not retrieve the specific tariff for this HS code in the provided data. In practice, HS 3207.10 typically refers to "Preparations for pre-coating plates and cylinders" or similar, which might be a misclassification for general adhesives. General adhesives (HS 3506 or 3208/3209) often face 0-5% base + 25% Section 301. Proceed with caution. |
π― 4. 3808.94 ββ Other Chemical Products (HCH Adhesive)
| Item | Content |
|---|---|
| Tax Status | Failed to retrieve tax information |
| Total Tax Rate | Error |
| Notes | HS 3808.94 is a broad category. If this code is applied, it likely falls under "Other" chemical products. Given the pattern of the other codes, it may be subject to similar Section 301 tariffs (25%) if Chinese origin, but the base rate is unknown from the source. Risk: High due to uncertainty. |
π οΈ IV. Customs Clearance Practical Advice (Actionable Pitfall Guide)
β 1. Documentation Checklist (Mandatory)
| Document | Required | Explanation |
|---|---|---|
| β Material Safety Data Sheet (MSDS/SDS) | βοΈ Mandatory | Must explicitly state the percentage of HCH (Lindane) or SCCPs. Without this, customs cannot classify correctly. |
| β Composition Declaration | βοΈ Mandatory | Detailed breakdown of all ingredients, especially chlorinated compounds. |
| β Import Permit (EPA/USFWS) | βοΈ Critical | HCH and SCCPs are POPs. Import may require a TSCA Chemical Inventory Certification or specific EPA permits. |
| β Commercial Invoice | βοΈ Mandatory | Clearly describe the product: "Industrial Adhesive containing X% HCH/SCCPs for [Specific Use]." |
| β Certificate of Origin | βοΈ Mandatory | To determine Section 301 applicability. |
| β Third-Party Test Report | βοΈ Recommended | Lab report confirming the exact concentration of HCH/SCCPs. |
β 2. Declaration Strategy (Key Mnemonics)
π₯ βHCH is POPs, Declare Percentages, Do Not Hide!β
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Product contains HCH/Lindane | HS 3824.85.00.00 + Declare HCH % |
Misdeclare as generic adhesive (HS 3506) β Severe Penalty |
| Product contains SCCPs | HS 3824.89.00.00 + Declare SCCP % |
Misdeclare as generic binder β 31.5% Tariff + Detention |
| Unknown Composition | STOP β Get Test Report | Guessing HS Code β Customs Audit/Seizure |
| Low Concentration (<0.01%) | Still declare as HCH product if applicable | Assume "de minimis" exemption for chemicals β False |
β οΈ Important: Do NOT use the "De Minimis" exemption (Section 321) for HCH/SCCP-containing products. These substances are strictly regulated, and low-value shipments are still subject to EPA/TSCA controls.
β 3. Special Handling for Hazardous Chemicals
| Situation | Handling Advice |
|---|---|
| Lindane (Gamma-HCH) Content | If >0.01%, check if the end-use is exempt (e.g., medical seed treatment, now largely banned). Industrial use may be prohibited. |
| SCCP Content >0.1% | May be considered a POP. Check US EPA restrictions on SCCPs in imported products. |
| Flammable Adhesive | Also classify as Dangerous Goods (DG) for transport (UN Number, Class 3). Separate from chemical HS classification. |
π V. Global Market Comparison (2026)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Environmental Restrictions | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3824.89.00.00 (for SCCPs) |
31.5% (6.5% Base + 25% Section 301) | Strict (EPA/TSCA, Stockholm Convention) | HCH/Lindane imports are highly restricted. Permits often required. |
| πͺπΊ EU | 3824.89 |
Varies (0-5%) | Extremely Strict (REACH, POPs Regulation) | HCH/SCCPs are largely banned or heavily restricted. High compliance cost. |
| π¨π³ China | 3824.89 |
5-6% | Restricted | Import of HCH is controlled. Export may also be restricted under Stockholm Convention. |
| π―π΅ Japan | 3824.89 |
0-6% | Strict | POPs control law applies. |
π Conclusion:
- The USA imposes a 31.5% tariff on SCCP-containing binders and 0% on HCH/Lindane binders (but with high regulatory hurdles).
- Environmental Compliance is more critical than tariff rates. Misclassification can lead to seizure, fines, and criminal liability due to POPs status.
π VI. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Declaring HCH Adhesive as "General Glue" (HS 3506)
π Consequence: Customs reclassifies to 3824.89.00.00 β Back taxes + Penalty + Detention.
π Reason: Specific subheading notes in Chapter 38 override general adhesive headings when specific chemicals (HCH/SCCPs) are present.
β Mistake 2: Not declaring the percentage of HCH/SCCPs
π Consequence: Customs cannot verify compliance with POPs limits β Shipment Held Indefinitely.
β Mistake 3: Assuming 0% Tax means No Restrictions
π Consequence: 3824.85.00.00 has 0% tax, but EPA/TSCA permits are mandatory. Lack of permit = Seizure.
β Mistake 4: Using "Adhesive" as the only description
π Consequence: Ambiguity leads to audit.
π Correct: "Industrial Foundry Binder Containing 5% Hexachlorocyclohexane."
β Best Practice:
"Provide MSDS, Declare Chemical %, Get EPA Permit, Pay 31.5% (if SCCP), and Declare Accurately."
π― VII. Conclusion: Professional Clearance, Save Costs, Ensure Compliance!
π― Remember the Mantra:
πΉ "HCH is POPs, Declare it Clearly."
πΉ "Chapter 38 Over Chapter 32, When Specific Chemicals Are There."
πΉ "31.5% for SCCPs, 0% for HCH (But Check Permits First!)"
π Pro Tip:
If your HCH adhesive contains SCCPs, budget for 31.5% duty. If it contains Lindane/HCH, budget for 0% duty but high compliance cost.
Always apply for a Pre-Ruling (Advance Ruling) from US Customs and Border Protection (CBP) if the product is new or complex.
π£ Immediate Action:
π Contact a Hazmat Specialist + Provide MSDS + Verify EPA Permit Requirements
π Let your industrial adhesive clear customs safely, legally, and efficiently!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Your Cost Includes Tariff + Compliance Risk. Manage Both!
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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.