Liquid
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3901909000 | 41.5% | CN | US | Official Doc |
| 3901905501 | 41.5% | CN | US | Official Doc |
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π§ͺ Liquid (Liquids in Primary Forms)
π HS Code Reference & Customs Clearance Guide | 2026 Updated Tariff Analysis | Professional Import Strategy
π One: Product Definition & Classification β What Exactly Is βLiquidβ in Trade?
In international trade, "Liquids" refer to substances in a fluid state at room temperature, typically transported or sold in bulk or primary forms such as raw polymers, monomers, or chemical intermediates. These are not yet processed into final consumer products.
For polymers of ethylene, the key distinction lies in whether they are:
- Homopolymers (pure ethylene chains), or
- Copolymers (ethylene combined with other monomers like propylene or butene).
β οΈ Critical Classification Rule:
- If the product is not a copolymer, and is not specifically listed, it falls under "Other" in the HS Code hierarchy.
- If it is ethylene copolymer, it must be classified separately β even if the copolymer contains only minor amounts of other monomers.
π¦ Two: HS Code Classification Details (2026 Official Tariff Breakdown)
| HS Code | Product Description | Applicable Scenario | Copolymer? | Primary Form? |
|---|---|---|---|---|
3901.90.90.00 |
Polymers of ethylene, in primary forms: Other: Other: Other | General ethylene homopolymers not otherwise specified; bulk granules, pellets, or powder | β No | β Yes |
3901.90.55.01 |
Polymers of ethylene, in primary forms: Other: Other: Ethylene copolymers | Ethylene-based copolymers (e.g., with propylene, butene, etc.) | β Yes | β Yes |
π Key Insight:
- The term βOther: Other: Otherβ in3901.90.90.00is a catch-all for ethylene polymers that donβt fit into more specific subcategories.
- Ethylene copolymers are excluded from this category and must be reported under3901.90.55.01, even if the co-monomer is <5%.
π° Three: 2026 Updated Tariff Rate Breakdown (With Additional Duties & Policies)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: November 10, 2025 (including future imports)
π― 1. 3901.90.90.00 β Ethylene Polymers (General, Non-Copolymer)
| Item | Detail |
|---|---|
| Base Duty Rate | 6.5% (ad valorem) |
| Additional Tariff (Section 301) | +25.0% (from USITC Footnote 9903.88.01) |
| IEEPA Additional Duty | +0.0% (not applicable for this category) |
| Total Effective Duty | 31.5% |
| Tax Calculation | CIF Value Γ 31.5% |
| De Minimis Threshold | β Not applicable (denied de minimis) |
| Legal Basis Path | USITC:3901.90.90.00 β FOOTNOTE:9903.88.01 β Section 301 Tariff List |
π Explanation:
- The 6.5% base duty is standard for non-essential plastics under the Harmonized Tariff Schedule (HTS).
- The +25% Section 301 tariff applies to all Chinese-origin chemical products listed under USITCβs "301 Investigation" on Chinaβs industrial policies.
- No IEEPA (International Emergency Economic Powers Act) surcharge applies here β only Section 301 is active.
- Total: 31.5% β High tariff, especially for bulk polymer imports.
π― 2. 3901.90.55.01 β Ethylene Copolymers (in Primary Forms)
| Item | Detail |
|---|---|
| Base Duty Rate | 0.0% |
| Additional Tariff (Section 301) | 0.0% |
| IEEPA Additional Duty | 0.0% |
| Total Effective Duty | 0.0% |
| Tax Calculation | CIF Value Γ 0.0% |
| De Minimis Threshold | β Applicable (if value < $800, may qualify) |
| Legal Basis Path | USITC:3901.90.55.01 β No Footnote 9903.88.01 β Exempt from 301 Tariff |
π Why Zero Duty?
- Ethylene copolymers are exempt from the Section 301 tariff because they are considered technologically distinct and not direct substitutes for homopolymers.
- This reflects U.S. policy to encourage innovation in polymer chemistry and support advanced materials.
- No additional surcharges apply β even from China.
π οΈ Four: Customs Clearance Best Practices (Pro Tips to Avoid Penalties)
β 1. Required Documentation (Must-Have List)
| Document | Required? | Notes |
|---|---|---|
| β Product Specification Sheet | βοΈ | Include molecular weight, melt flow index (MFI), density, co-monomer type & % |
| β Certificate of Origin (CO) | βοΈ | Critical for claiming exemption under 3901.90.55.01 |
| β Material Safety Data Sheet (MSDS/SDS) | βοΈ | Required for chemical classification |
| β Commercial Invoice | βοΈ | Must clearly state: βEthylene Copolymer, in primary form, not homopolymerβ |
| β Lab Test Report | βοΈ | Confirm copolymer composition (e.g., via NMR or FTIR) |
| β Packing List | βοΈ | Show packaging type (bags, drums, bulk containers) |
| β Pre-arrival Notice (if using CBPβs ACE system) | βοΈ | Prevents delays at port |
β 2.η³ζ₯ζε·§οΌKey Rules to RememberοΌ
π₯ βCopolymer = Zero Duty, Homopolymer = 31.5% β Know Your Chemistry!β
| Scenario | Correct HS Code | Wrong Approach |
|---|---|---|
| Ethylene + 3% propylene (copolymer) | 3901.90.55.01 |
Misclassified as 3901.90.90.00 β 31.5% tax |
| Pure polyethylene pellets (no co-monomer) | 3901.90.90.00 |
Reported as copolymer β risk of penalty |
| Bulk granules from China | 3901.90.90.00 |
Must pay 31.5% unless exempt |
| Copolymer from Vietnam or Mexico | 3901.90.55.01 |
0% duty β huge savings! |
β 3. Special Cases & Risk Mitigation
| Situation | Recommended Action |
|---|---|
| Copolymer with unknown co-monomer | Request lab test before shipment β do not guess |
| Mixed batch (some copolymer, some homopolymer) | Split shipment β declare separately to avoid misclassification |
| Label says βethylene polymerβ but is copolymer | Do not rely on labels β verify via test report |
| Importing via third country (e.g., Vietnam) | Use CO from Vietnam β can qualify for 0% duty under 3901.90.55.01 |
| High-value shipment (>$10,000) | Apply for Advance Ruling (AR) β get official HS Code confirmation |
π Five: Global Market Comparison (2026 Updated)
| Country/Region | Recommended HS Code | Tariff Rate | Certification Required | Notes |
|---|---|---|---|---|
| πΊπΈ United States | 3901.90.90.00 or 3901.90.55.01 |
31.5% / 0.0% | None (unless hazardous) | China origin = 31.5% |
| π¨π³ China | 3901.90.90.00 |
5% | CCC (if applicable) | No extra tariffs |
| πͺπΊ European Union | 3901.90.90.00 |
0% (if from non-China) | CE, REACH | No 301 tariffs |
| π¦πΊ Australia | 3901.90.90.00 |
5% | RCM | No additional duties |
| π―π΅ Japan | 3901.90.90.00 |
0% | PSE | No extra charges |
π Takeaway:
- The U.S. is the only market with 31.5% duty on non-copolymer ethylene polymers from China.
- Switching origin to Vietnam/Mexico can save 31.5% β consider supply chain re-routing.
π Six: Common Mistakes & How to Avoid Them (Real-World Risks)
β Mistake 1: Declaring a copolymer as 3901.90.90.00
π Result: Pay 31.5% duty instead of 0% β loss of 31.5% margin
β Mistake 2: Using "ethylene polymer" on invoice without specifying copolymer status
π Result: Customs may assume homopolymer β audit risk, penalties
β Mistake 3: Not testing co-monomer content before shipment
π Result: Misclassification β seizure, fines, or return
β Mistake 4: Shipment from China labeled as βcopolymerβ without proof
π Result: Denial of exemption β 31.5% duty applied
β Correct Declaration Example:
"Ethylene-propylene copolymer, in primary form, bulk pellets, MFI: 2.0 g/10min, density: 0.905 g/cmΒ³, co-monomer content: 3.2%, produced in China, test report attached, CO from China"
π― Seven: Conclusion β Precision in Classification = Profit Protection!
π― Remember the Golden Rule:
πΉ "If itβs a copolymer, use
3901.90.55.01β 0% duty!
πΉ If itβs pure polyethylene, use3901.90.90.00β 31.5% duty!
πΉ Donβt guess β test, verify, declare!
π Pro Tip:
β Apply for a Pre-Arrival Ruling (PAR) or Advance Ruling (AR) from U.S. CBP β get official confirmation of HS Code and duty rate before shipment.
β Use third-country manufacturing (Vietnam, Mexico, India) to bypass 31.5% tariff β huge cost savings.
π£ Act Now!
π Contact a licensed customs broker + provide test reports + CO + specs
π Avoid surprise tariffs, reduce costs, and accelerate clearance!
β¨ Smart Trade Starts with Smart Classification!
πΌ Your next shipment could save thousands β if you get the HS Code right.
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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.