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Phenolic Resin Powder for Adhesive

CN → US
HS Code Tariff Rate Origin Destination Doc
3506915000 37.1% CN US Official Doc
3506990000 37.1% CN US Official Doc
3909390000 41.5% CN US Official Doc
3909400000 41.5% CN US Official Doc
3824992900 41.5% CN US Official Doc

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AI Analysis

⚗️ Phenolic Resin Powder for Adhesive (酚醛树脂粉/胶粉)


🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition: What Exactly is "Phenolic Resin Powder"?

Phenolic resin is a synthetic polymer derived from the reaction of phenols and aldehydes (typically formaldehyde). When referred to as "Powder for Adhesive," it implies a specific physical state and intended use. However, in international trade, classification depends heavily on two critical factors: 1. State of Material: Is it a raw resin (unmodified) or a formulated adhesive? 2. Chemical Structure & Application: Does it behave as a primary polymer (Chapter 39) or a prepared adhesive/glue (Chapter 35/38)?

There is often a dispute between classifying it under Chapter 35 (Albuminoidal substances; Glues) or Chapter 39 (Plastics and articles thereof). The destination and specific formulation dictate the HS Code.


📦 II. HS Code Classification Details (2026 Latest Tariff Alignment)

Based on the provided data, there are five potential classifications. The choice depends on whether the powder is considered a raw resin or a prepared adhesive.

HS Code Product Description & Logic Tax Rate Breakdown Total Tax
3506.91.50.00 Phenolic Resin Adhesive
Classified as an adhesive based on polymers of headings 39.01–39.13. This is the standard classification for prepared phenolic adhesives.
Base: 2.1%
Additional: 25.0%
Section 301 (122): 10%
37.1%
3506.99.00.00 Other Prepared Adhesives
Classified as a "prepared adhesive" that does not fall specifically under 3506.91. Used for phenolic resin glues that fit general adhesive definitions.
Base: 2.1%
Additional: 25.0%
Section 301 (122): 10%
37.1%
3909.39.00.00 Phenolic Resin (Primary Form)
Classified as a raw resin in primary shape. Assumes the powder is the basic polymer before being formulated into an adhesive mix.
Base: 6.5%
Additional: 25.0%
Section 301 (122): 10%
41.5%
3909.40.00.00 Phenolic Resin (Intermediate)
Classified as phenolic resin in primary/intermediate forms. Similar to 3909.39, focused on the resin material itself rather than the final adhesive use.
Base: 6.5%
Additional: 25.0%
Section 301 (122): 10%
41.5%
3824.99.29.00 Chemical Preparations for Molding
Specifically for phenolic resin used as a binding agent in casting molds or cores (foundry applications).
Base: 6.5%
Additional: 25.0%
Section 301 (122): 10%
41.5%

🔍 Key Distinction Logic: * Chapter 35 (3506): If the powder is marketed and used specifically as a glue/adhesive (often mixed with water or activators for bonding wood, metal, etc.). Lower Base Rate (2.1%). * Chapter 39 (3909): If the powder is the raw chemical resin sold for further processing by manufacturers who will make their own adhesives. Higher Base Rate (6.5%). * Chapter 38 (3824): If the specific end-use is foundry/casting molds (sand binding agents). Specific Use Category.


💰 III. 2026 Latest Tariff Rate Detailed Explanation (US Imports from China)

Applicable Country: United States (US)
Origin: China (CN)
Effective Date: 2025/2026 Tariff Schedule
Total Impact: High Tariff Environment (41.5% - 47.1%)

🎯 1. Category A: Classified as Adhesive (HS 3506.91 / 3506.99)

Used when the product is sold as a "Prepared Adhesive"

Item Content
Base MFN Rate 2.1% (Ad valorem)
USITC Section 301 +25% (List 3/4 adjustments)
IEEPA (122 Provision) +10% (Specific punitive tariff on Chinese goods)
Total Effective Rate 37.1%
De Minimis Eligibility NO (Value > $800 or restricted commodities often excluded; check specific ruling)
Legal Path HTSUS:3506.91.50.00USITC:301-FootnoteIEEPA:122

📌 Explanation:
The "Adhesive" classification enjoys a lower base rate (2.1%) compared to raw resin. However, the 25% Section 301 and 10% IEEPA tariffs add up significantly. This is the most common classification for consumer or industrial glue products.

🎯 2. Category B: Classified as Raw Resin (HS 3909.39 / 3909.40)

Used when the product is sold as "Raw Material" or "Unprepared Polymer"

Item Content
Base MFN Rate 6.5% (Ad valorem)
USITC Section 301 +25% (List 3/4 adjustments)
IEEPA (122 Provision) +10% (Specific punitive tariff on Chinese goods)
Total Effective Rate 41.5%
De Minimis Eligibility NO
Legal Path HTSUS:3909.39.00.00USITC:301-FootnoteIEEPA:122

📌 Explanation:
Raw phenolic resins have a higher base duty (6.5%). Even though it’s a "chemical," the U.S. protects its domestic chemical manufacturing base with higher base tariffs. The total tax is higher (41.5%) than the adhesive classification.

🎯 3. Category C: Foundry/Casting Use (HS 3824.99.29.00)

Used specifically for Mold/Core Binding Agents

Item Content
Base MFN Rate 6.5% (Ad valorem)
USITC Section 301 +25%
IEEPA (122 Provision) +10%
Total Effective Rate 41.5%
Special Note Requires proof of use in casting/foundry industries.

🛠️ IV. Customs Clearance Practical Advice (Avoid Pitfalls)

✅ 1. Documentation Checklist (Critical for Classification)

Document Required? Purpose
Product Specification Sheet ✔️ Must explicitly state: "Is this a raw resin or a prepared adhesive?" List ingredients.
Technical Data Sheet (TDS) ✔️ Shows viscosity, curing time, and intended application (Bonding vs. Casting).
Formula/Composition ✔️ Crucial for distinguishing between Ch 35 (Adhesive) and Ch 39 (Resin). If it contains fillers, solvents, or activators, it leans towards Ch 35.
Photos of Packaging & Label ✔️ Label should clearly state "Phenolic Adhesive" or "Phenolic Resin Powder." Mislabeling causes delays.
Commercial Invoice ✔️ Must match HS Code description. Do not just write "Resin"; write "Phenolic Resin Adhesive Powder."
Certificate of Origin (CO) ✔️ Required for proving Chinese origin (triggers 301/122 tariffs).

✅ 2. Declaration Strategy (Key Formulas)

🔥 "Adhesive = Lower Base Duty; Resin = Higher Base Duty. Use it right!"

Scenario Correct Declaration Reason
Sold as Glue Powder (for wood/metal bonding) 3506.91.50.00 It is a "prepared adhesive" based on resin. Best base rate (2.1%).
Sold as Raw Material (for further processing) 3909.39.00.00 It is a primary polymer. Higher base rate (6.5%).
Sold for Sand Casting Molds 3824.99.29.00 Specific use in foundries requires this specialized code.

⚠️ Warning:
- If you declare 3909.39.00.00 (Raw Resin) but your invoice says "Adhesive," customs will reclassify you to 3506.91.50.00. While the base rate is lower, the total tax is similar (37.1% vs 41.5%), but you risk penalties for misdeclaration.
- If you declare 3506.91.50.00 but it’s actually raw resin, you may be accused of tariff evasion if the difference were significant (though here the raw resin is more expensive, so this risk is lower, but accuracy is key).

✅ 3. Special Case Handling

Situation Handling Suggestion
Mixed Shipment (Resin + Adhesive) Declare Separately. Do not combine. Different HS codes = different duties.
Private Label (OEM) Provide a letter from the buyer confirming the product is for "Adhesive Application" to support 3506 classification.
Foundry Application Provide a Statement of Use from the end-user confirming it is used for molding/coring, not general bonding.

🌍 V. Global Market Comparison (2026)

Region Recommended HS Code Estimated Total Duty (China Origin) Notes
🇺🇸 USA 3506.91.50.00 (Adhesive) 37.1% High Section 301 + IEEPA tariffs.
🇺🇸 USA 3909.39.00.00 (Resin) 41.5% Higher base duty.
🇨🇳 China 3506.91.50.00 5% - 10% Import duties for raw materials may be lower or zero depending on specific trade agreements.
🇪🇺 EU 3506.91 / 3909.39 Varies (0-6.5%) No 25% Section 301 equivalent, but VAT applies (19-27%).
🇯🇵 Japan 3506.91 / 3909.39 0-3.9% Generally favorable tariffs for chemical intermediates.

📌 Conclusion:
The US market is the most expensive due to the 25% Section 301 and 10% IEEPA tariffs. The total duty burden is 37.1% to 41.5%. This must be factored into pricing.


📌 VI. Common Errors & Pitfalls (Blood Lessons)

Error 1: Declaring "Phenolic Resin" (HS 3909) when the product is clearly marketed as "Adhesive Powder."
👉 Consequence: Customs may accept it but charge higher base duty (41.5%), or if challenged, issue a rejection notice for inconsistent description.
Fix: If it is an adhesive, use 3506.91.50.00.

Error 2: Using "Resin" on the invoice but declaring "Adhesive" to get lower duty.
👉 Consequence: While 3506 has lower base duty, the Section 301 and IEEPA apply regardless. The risk is misdeclaration fraud.
Fix: Be accurate. The total duty difference (37.1% vs 41.5%) is small compared to the risk of penalties.

Error 3: Ignoring the 122 Provision (10% IEEPA).
👉 Consequence: Underestimating costs by 10%.
Fix: Always add 37.1% (Adhesive) or 41.5% (Resin) as the minimum effective rate.


🎯 VII. Conclusion: Professional Declaration Saves Money!

🎯 Remember the Golden Rule:

🔹 "Adhesive = 3506.91.50.00 (37.1% Total)"
🔹 "Raw Resin = 3909.39.00.00 (41.5% Total)"
🔹 "Foundry Use = 3824.99.29.00 (41.5% Total)"

📌 Tip:
If you are importing into the US, prepare for a 37-42% duty burden.
For non-US markets (EU, Asia), duties are significantly lower (0-6.5% + VAT). Consider transshipment or supplier diversification if US market costs are prohibitive.


📣 Immediate Action:

📞 Consult your customs broker with the Technical Data Sheet (TDS).
📝 Label accurately: "Phenolic Resin Adhesive" or "Phenolic Resin Powder."
🚀 Plan for 37-42% duty in your cost structure for US imports.


Professional Customs Clearance Starts with Accurate Classification!
💼 Every Percent 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) — Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
  • Heading (4 digits) — More specific grouping within the chapter
  • Subheading (6 digits) — Internationally standardized breakdown, used by all WCO member countries
  • National subdivisions (8-10 digits) — 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 — The standard duty rate applied to WTO members
  • General rate — Applied to countries without trade agreements
  • Trade remedy duties — 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.