Polyethylene Terephthalate Primary Form
CN โ US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3907610010 | 41.5% | CN | US | Official Doc |
| 3901909000 | 41.5% | CN | US | Official Doc |
| 3907610050 | 41.5% | CN | US | Official Doc |
| 3901905501 | 41.5% | CN | US | Official Doc |
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๐งช Polyethylene Terephthalate (PET) Primary Form โ High-Tariff Import Alert (USA/China)
๐ HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Critical Compliance Strategy
๐ 1. Product Definition & Classification: What is "PET Primary Form"?
Polyethylene Terephthalate (PET) Primary Form refers to raw, unprocessed polymer resins or granules used as the foundational material for manufacturing plastic bottles, fibers, films, and sheets. In international trade, this is classified strictly under Chapter 39 (Plastics and Articles Thereof), specifically as Polyesters.
โ ๏ธ Key Distinction:
- "Primary Form" includes granules, powders, liquids, or non-vulcanized shapes that are not yet manufactured into specific articles (like bottles or films).
- If the PET is already shaped into bottles, films, or fibers, it does NOT belong here; it falls under Chapter 39 sub-headings for specific articles or Chapter 54/62 for textiles.
- Misclassification Risk: Declaring finished PET bottles as "Primary Form" to avoid tariffs is illegal and triggers severe penalties.
๐ฆ 2. HS Code Classification Matrix (2026 Tariff Book)
Based on the provided data, PET Primary Form is classified under four specific sub-headings. All share the same high tariff profile due to trade restrictions.
| HS Code | Product Description | Classification Logic | Key Characteristics |
|---|---|---|---|
3907.61.00.10 |
Polyethylene Terephthalate (PET), Primary Form | Classified as Polyester Polymers under heading 3907 (Polyethers, Epoxides, Polyacetals, Other Polyethers, Polyesters). | Standard commercial PET resin. |
3901.90.90.00 |
Polyethylene Terephthalate (PET), Primary Form | Classified under Polymers of Ethylene (Heading 3901). Used when the polymer structure aligns more closely with ethylene-based classifications or specific regulatory interpretations. | Alternative classification for specific resin grades or manufacturing origins. |
3907.61.00.50 |
Polyethylene Terephthalate (PET), Primary Form | Classified as Polyester Polymers (Heading 3907). | Similar to .10 but may differ in specific sub-category metrics (e.g., intrinsic viscosity or additive packages) defined by customs. |
3901.90.55.01 |
Polyethylene Terephthalate (PET), Primary Form | Classified under Polymers of Ethylene, aligning with logical polymer shape classification. | Specific sub-type for ethylene-related polymer logic. |
๐ Critical Note:
- Despite different HS Codes (3907 vs. 3901), all four codes result in the exact same total tax rate of 41.5%.
- The choice of HS Code depends on the specific chemical composition, manufacturing process, and customs interpretation of "polyester" vs. "ethylene polymer" structure, but the financial impact is identical.
๐ฐ 3. 2026 Latest Tariff Rate Breakdown (USA Import from China)
โ Applicable Country: United States (US)
โ Country of Origin: China (CN)
โ Effective Date: Ongoing (High Tariff Regime)
๐ฏ Total Effective Tax Rate: 41.5%
| Tax Component | Rate | Description |
|---|---|---|
| Base Tariff | 6.5% | Standard Most Favored Nation (MFN) duty for plastics under Chapter 39. |
| Section 301 Tariff (Trade War) | 25.0% | Additional duty imposed under the US Trade Representative (USTR) Section 301 actions against Chinese goods. |
| Section 122 Tariff | 10.0% | Additional duty under Section 122 of the Trade Act of 1974 (specific to certain strategic materials). |
| TOTAL | 41.5% | Cumulative Ad Valorem Duty |
๐ Legal Basis:
- Base: HTSUS Chapter 39.
- Section 301: 25% surcharge on Category 4 (Consumer Goods/Industrial Inputs).
- Section 122: 10% surcharge for specific import restrictions.
- No De Minimis Exemption: This cargo is NOT eligible for the $800 de minimis exemption. It must be formally entered through CBP.โ ๏ธ Warning:
- There are NO known exemptions for PET resin from China under current policies.
- Attempting to route through third countries (transshipment) without substantial transformation may trigger anti-circumvention duties.
๐ ๏ธ 4. Customs Clearance Operational Advice (Avoiding Pitfalls)
โ 1. Required Documentation Checklist
| Document | Mandatory? | Notes |
|---|---|---|
| Commercial Invoice | โ Yes | Must clearly state: "Polyethylene Terephthalate (PET), Primary Form, Granules/Powder". |
| Packing List | โ Yes | Must specify net/gross weight, bag count, and palletization. |
| Certificate of Origin (CO) | โ Yes | Crucial to prove origin. If claiming non-China origin, must provide valid CO from eligible country. |
| Bill of Lading / Airway Bill | โ Yes | Ensure "Shipper" and "Consignee" details match invoice. |
| Product Specification Sheet | โ Recommended | Include intrinsic viscosity, melt flow rate, and colorant details to support HS Code classification. |
| Import Entry Summary | โ Yes | Filed via ACE portal with correct HS Code (e.g., 3907.61.00.10). |
โ 2. Classification Strategy & Naming Conventions
| Scenario | Correct HS Code | Incorrect HS Code | Risk |
|---|---|---|---|
| Raw PET Granules | 3907.61.00.10 or 3907.61.00.50 |
3907.99.90 (Other plastics) |
Misclassification may lead to audit or penalty for wrong duty rate. |
| PET Bottles (Finished) | 3923.30.00.00 |
3907.61.00.10 |
High Risk: Finished goods have different tariff rates and may trigger anti-dumping duties. |
| PET Film Rolls | 3920.62.00.00 |
3907.61.00.10 |
High Risk: Film is not "primary form" in the polymer sense but a manufactured article. |
| Mixed Shipment (Resin + Bottles) | Split Lines | Combined Line | High Risk: Customs will reject mixed classification. Separate entries required. |
๐ฅ Key Phrase for Declaration:
"Polyethylene Terephthalate (PET), Primary Form, Unvulcanized, In Granular Form, Not Further Processed, Chemical Formula (C10H8O4)n"
โ 3. Special Cases & Mitigation Strategies
| Case | Recommendation |
|---|---|
| Origin Transshipment | If goods are shipped from Vietnam/Malaysia but originate in China, ensure substantial transformation occurred. Otherwise, CBP will apply Chinese origin rules and 41.5% tariff. |
| Free Trade Agreements (FTAs) | Check if any component qualifies for FTAs (e.g., USMCA if sourced from US/Mexico). PET resin itself rarely qualifies if produced in China. |
| Anti-Dumping Duties (AD/CVD) | Verify if PET resin from China is subject to AD/CVD. (Note: Currently, AD/CVD is more common for aluminum and steel, but always check the latest CBP notices). |
| Intrinsic Viscosity Disputes | CBP may question if the product is truly "primary form" or a pre-polymer. Provide lab test reports to confirm it is suitable for further polymerization or molding. |
๐ 5. Global Market Comparison (2026)
| Region | HS Code | Base Tariff | Additional Tariffs (China) | Total Effective Rate | Notes |
|---|---|---|---|---|---|
| ๐บ๐ธ USA | 3907.61.00.10 |
6.5% | 25% (301) + 10% (122) | 41.5% | Highest tariff globally. Must budget for full cost. |
| ๐จ๐ณ China (Import) | 3907.61.00.00 |
6.5% | None | 6.5% | Lower cost for domestic Chinese buyers. |
| ๐ช๐บ EU | 3907.61.00 |
6.5% | None (generally) | 6.5% | No Section 301 equivalent. Favorable for EU importers. |
| ๐ฏ๐ต Japan | 3907.61.00 |
6.0% | None | 6.0% | Low tariff, stable supply chain. |
| ๐ฎ๐ณ India | 3907.61.00 |
7.5% | Anti-dumping Duty (may apply) | Varies | Check for ongoing AD investigations on PET from China. |
๐ Conclusion:
- USA is the most expensive market for importing PET primary form from China due to layered tariffs.
- EU and Japan remain cost-effective alternatives for global supply chains.
- Supply Chain Diversification: Consider sourcing PET resin from Vietnam, Thailand, or India to mitigate US tariffs, but ensure origin compliance.
๐ 6. Common Mistakes & Pitfalls (Lessons Learned)
โ Mistake 1: Declaring PET films or bottles as "Primary Form"
๐ Consequence: CBP will reclassify as finished goods, assess different tariffs (possibly higher), and impose penalties for misdeclaration.
โ Mistake 2: Ignoring Section 122 Tariff
๐ Consequence: Underpaying duty by 10%. CBP audits will recover back-taxes plus interest and penalties.
โ Mistake 3: Using vague descriptions like "Plastic Resin"
๐ Consequence: Customs may select goods for inspection, causing delays. Always specify "Polyethylene Terephthalate (PET), Primary Form".
โ Mistake 4: Assuming De Minimis Exemption applies
๐ Consequence: Packages under $800 are NOT exempt from Section 301/122 duties. They are still subject to the 41.5% rate.
โ Correct Practice:
"Polyethylene Terephthalate (PET) Primary Form, Granules, Intrinsic Viscosity 0.6-0.8, For Injection Molding, HS Code 3907.61.00.10, Country of Origin: China"
๐ฏ 7. Conclusion: Strategic Import Planning
๐ฏ Key Takeaways:
๐น Total Tariff = 41.5% (6.5% Base + 25% Section 301 + 10% Section 122).
๐น No Exemptions for Chinese-origin PET primary form in the US.
๐น Accurate Classification is critical: Ensure the product is truly "primary form" (granules/powder) and not a finished article.
๐น Documentation must be robust: Invoice, Packing List, CO, and Specification Sheets must align perfectly.
๐ Pro Tip:
If you are importing large volumes, consider Apply for an Exclusion under Section 301 (if available) or explore Foreign Trade Zones (FTZs) to defer duty payments.
Consult a Licensed Customs Broker to review your specific product specifications and optimize HS Code selection (e.g.,3907.61.00.10vs.3907.61.00.50) to ensure full compliance.
๐ฃ Immediate Action:
๐ Contact your Customs Broker today.
๐ Prepare Product Specifications (Viscosity, Melt Flow, Additives).
๐ฐ Budget for 41.5% Duty in your landed cost calculations.
๐ Ensure Smooth Clearance by avoiding misclassification penalties!
โจ Professional Customs Compliance, Starting with Accurate Classification!
๐ผ Your Cost Savings Depend on Precision!
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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) โ Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) โ More specific grouping within the chapter
- Subheading (6 digits) โ Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) โ 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 โ The standard duty rate applied to WTO members
- General rate โ Applied to countries without trade agreements
- Trade remedy duties โ 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.