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Water based Adhesive

CN β†’ US
HS Code Tariff Rate Origin Destination Doc
3506915000 37.1% CN US Official Doc
3506105000 37.1% CN US Official Doc
3214100020 38.7% CN US Official Doc
3214905000 38.25% CN US Official Doc

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πŸ§ͺ Water-Based Adhesive (ζ°΄ζ€§θƒΆζ°΄)


🌐 HS Code Reference & Customs Clearance Guide | 2024-2026 Tax Regime Analysis | Professional Entry Strategy
πŸ“Œ I. Product Definition & Classification: What Exactly Is "Water-Based Adhesive"?

Water-based adhesives are polymer-based bonding agents where water acts as the primary solvent or carrier. In international trade, their classification hinges on two critical factors:
1. Chemical Composition: Are they purely "glues" (Chapter 35) or "prepared sealants/fillers" (Chapter 32)?
2. Packaging Format: Is it a retail-ready dual-bottle system (implying use) or bulk industrial packaging?

⚠️ Key Distinction:
- If the product is primarily a polymer-based glue in a retail-ready dual-bottle format β†’ Classified under Chapter 35 (Prepared Glues).
- If the product functions as a sealant, caulk, or filler (often silicone/acrylic blends for construction) β†’ Classified under Chapter 32 (Prepared Sealants/Other Chemical Products).


πŸ“¦ II. HS Code Classification Details (Based on Provided Data)

HS Code Product Description Applicability Tax Rate
3506.91.50.00 Prepared adhesives based on polymers; dual-bottle retail packaging Matches "polymer-based prepared adhesives" with retail features 37.1%
3506.10.50.00 Prepared glues/adhesives; inferred retail packaging from dual-bottle form General "prepared glues" category 37.1%
3214.10.00.20 Prepared sealants, caulking compounds, etc. (Other) Fits "sealant/caulk" material attributes; "Other" sub-category 38.7%
3214.90.50.00 Other prepared sealants, filling powders, etc. Water-based sealant/filler material/usage attributes 38.25%

πŸ” Focus Reminder:
- The dual-bottle format strongly suggests a retail-ready adhesive (Chapter 35), but customs may reclassify it as a sealant (Chapter 32) if the chemical profile leans toward construction sealing rather than general bonding.
- Chapter 32 codes generally carry higher base tariffs (3.25%-3.7%) compared to Chapter 35 (2.1%-2.1%), impacting the total tax burden.


πŸ’° III. 2026 Latest Tariff Rate Breakdown (Including Add-ons & Policy Surcharges)

βœ… Applicable Country: United States (US)
βœ… Origin: China (CN)
βœ… Effective Date: Current US-China Trade Regime (Section 301 & IEEPA)

🎯 1. 3506.91.50.00 & 3506.10.50.00 β€”β€” Prepared Adhesives (Chapter 35)

Item Content
Base Tariff 2.1% (ad valorem)
Section 301 Additional Tariff +25.0% (From USITC Footnote 9903.88.01)
IEEPA Section 122 Tariff +10.0% (Specific surcharge for certain Chinese imports)
Total Effective Tax Rate 37.1%
Tax Calculation CIF Value Γ— 37.1%
De Minimis Exemption ❌ Not Eligible (High-value chemical products are excluded)
Legal Basis Path USITC:3506.91.50.00 β†’ FOOTNOTE:301 β†’ IEEPA:122

πŸ“Œ Explanation:
- The 25% Section 301 tariff is the standard penalty for most Chinese-manufactured chemical goods;
- The 10% IEEPA 122 tariff is an additional layer for specific product lines;
- Total 37.1% is a high-cost barrier. Proper classification is crucial to avoid overpayment or audit risks.

🎯 2. 3214.10.00.20 & 3214.90.50.00 β€”β€” Prepared Sealants/Other Chemicals (Chapter 32)

Item Content
Base Tariff 3.7% (Code 3214.10) / 3.25% (Code 3214.90)
Section 301 Additional Tariff +25.0%
IEEPA Section 122 Tariff +10.0%
Total Effective Tax Rate 38.7% (for 3214.10) / 38.25% (for 3214.90)
Tax Calculation CIF Value Γ— Rate
De Minimis Exemption ❌ Not Eligible
Legal Basis Path USITC:3214.x0.x0.00 β†’ FOOTNOTE:301 β†’ IEEPA:122

πŸ“Œ Note:
- Even with a slightly higher base rate, Chapter 32 codes are often used if the product is marketed as a sealant (e.g., for windows, bathrooms).
- The difference between 37.1% and 38.7% is small, but the risk of misclassification (e.g., calling a sealant an "adhesive" to save 1.6%) can lead to penalties and delays.


πŸ› οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Avoidance)

βœ… 1. Documentation Checklist (Non-Negotiable)

Document Required Notes
βœ… Product Spec Sheet βœ”οΈ Must include chemical composition (polymer type, water content), viscosity, drying time.
βœ… Material Safety Data Sheet (MSDS) βœ”οΈ Critical for chemicals. Must confirm it is water-based (non-flammable helps clearance).
βœ… Product Photos (with Packaging) βœ”οΈ Must clearly show dual-bottle packaging if claiming Chapter 35 retail status.
βœ… Commercial Invoice βœ”οΈ Description must match HS code logic: e.g., "Water-Based Polymer Adhesive, Retail Pack" vs. "Water-Based Sealant".
βœ… Original Certificate of Origin βœ”οΈ Mandatory for Section 301 tariff verification.

βœ… 2. Declaration Strategy (Key Mantra)

πŸ”₯ "Form Dictates Code, Chemistry Confirms It!"

Scenario Correct Declaration Wrong Action
Dual-bottle, polymer glue, retail use 3506.91.50.00 or 3506.10.50.00 Mislabeling as "Industrial Solvent" β†’ 85% penalty
Single tube, construction sealant 3214.10.00.20 Calling it "Glue" β†’ Potential reclassification & fine
Bulk drum, generic adhesive 3506.91.50.00 Assuming retail tax rate β†’ Incorrect if not retail-ready

βœ… 3. Special Handling

Situation Recommendation
Dual-Bottle Unclear If bottles are for mixing two parts (A+B), clearly state "Two-Component Water-Based Adhesive".
Chemical Ambiguity Provide SDS (Safety Data Sheet) to prove water-based nature (reduces hazardous material scrutiny).
Customs Audit Risk If classified under Chapter 32 but intended as general glue, be prepared to justify functional use (sealing vs. bonding).

🌍 V. Global Market Comparison (2024-2026)

Country/Region Recommended HS Code Approx. Tariff Certification Notes
πŸ‡ΊπŸ‡Έ USA 3506.91.50.00 / 3214.10.00.20 37.1% - 38.7% EPA, State-Level VOC Rules Highest barriers due to Section 301 + IEEPA 122
πŸ‡¨πŸ‡³ China 3506.91.50.00 / 3214.10.00.20 ~5-10% CCC (if applicable) Lower base rate, no Section 301
πŸ‡ͺπŸ‡Ί EU 3506.91 / 3214.10 ~0-6.5% REACH, CLP No additional tariffs, but strict chemical compliance
πŸ‡―πŸ‡΅ Japan 3506.91 / 3214.10 ~5-6% JIS Standards Moderate barriers

πŸ“Œ Conclusion:
- The US is the most challenging market for water-based adhesives due to cumulative tariffs (25% + 10% + base).
- Cost Optimization: Ensure precise classification. If the product is not a sealant, Chapter 35 (37.1%) is slightly cheaper than Chapter 32 (38.7%).
- Documentation is Key: MSDS and clear packaging photos prevent delays.


πŸ“Œ VI. Common Mistakes & Pitfalls (Blood-Lesson Guide)

❌ Mistake 1: Declaring as "Glue" but packaging looks like a construction sealant (tube/caulk gun format)
πŸ‘‰ Consequence: Customs may reclassify to 3214.x0 β†’ Higher tax + Penalty.

❌ Mistake 2: Omitting MSDS or SDS
πŸ‘‰ Consequence: Hold at port for chemical safety review β†’ Storage fees & delays.

❌ Mistake 3: Assuming "Water-Based" means "Non-Hazardous"
πŸ‘‰ Consequence: Incorrect hazardous material declaration β†’ Heavy Fines even if non-flammable.

❌ Mistake 4: Using vague descriptions like "Adhesive" on Invoice
πŸ‘‰ Consequence: Customs may request additional info, delaying clearance by 5-7 days.

βœ… Correct Practice:

"Water-Based Polymer Adhesive, Two-Component, Retail Dual-Bottle Packaging, Non-Flammable, MSDS Attached"


🎯 VII. Conclusion: Precision Saves Money!

🎯 Key Takeaways:

πŸ”Ή "Dual-Bottle = Retail (Ch35)?" Not always! Check chemical function.
πŸ”Ή "Sealant = Chapter 32?" Yes, if used for gaps/cracks.
πŸ”Ή "US Tariffs = 37.1%-38.7%" Budget accordingly! No de minimis.
πŸ”Ή "MSDS is King" Without it, your cargo stays in the port.


πŸ“Œ Pro Tip:
If your product is originating from Vietnam, Thailand, or Mexico, you may avoid US Section 301 tariffs. Consider supply chain adjustment for high-volume exports to the US.


πŸ“£ Action Plan:

πŸ“ž Contact a Licensed Customs Broker + Provide MSDS & Photos + Apply for Advance Ruling
πŸš€ Clear Customs Smoothly, Maximize Profit Margins, Avoid Surprises!


✨ Professional Clearance Starts with Accurate Classification!
πŸ’Ό Every 0.5% in Tariff Difference Counts!

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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.