Water based Chlorinated Adhesive
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3901909000 | 41.5% | CN | US | Official Doc |
| 3901302000 | 35.0% | CN | US | Official Doc |
| 3824100000 | 41.0% | CN | US | Official Doc |
| 3506990000 | 37.1% | CN | US | Official Doc |
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🧪 Water-Based Chlorinated Adhesive (WBCA)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
📌 Part I: Product Definition & Classification – Do You Really Understand “Chlorinated Adhesive”?
Water-based chlorinated adhesive is a specialized chemical bonding agent used primarily in industrial applications such as casting, molding, and high-speed industrial assembly. In international trade, its classification depends heavily on its chemical composition, functional purpose, and state of preparation.
Key distinctions: - Is it a raw polymer? If the product is primarily a chlorinated polymer in primary form (not yet mixed with solvents, catalysts, or fillers), it falls under Chapter 39 (Plastics). - Is it a formulated adhesive? If the product is pre-mixed, activated, or designed for immediate use (e.g., fast-curing or mold-specific), it may fall under Chapter 35 (Albuminoidal substances; Glues) or Chapter 38 (Miscellaneous chemical products).
⚠️ Critical Distinction Point:
- If the product is a polymer resin intended for further processing → HS 3901.90.90.00
- If the product contains vinyl chloride copolymers → HS 3901.30.20.00
- If the product is a prepared binder for casting → HS 3824.10.00.00
- If the product is a fast-curing prepared adhesive → HS 3506.91.50.00 or 3506.99.00.00
📦 Part II: HS Code Classification Details (2026 Latest Tariff Authority Cross-Reference)
| HS Code | Product Description | Applicable Scenario | Key Characteristic |
|---|---|---|---|
3901.90.90.00 |
Chlorinated Adhesive Formula: Main component is chlorinated polymer, classified as “Other primary forms of ethylene polymers” | Raw polymer resins, intermediate chemicals | ✅ Polymer Base |
3901.30.20.00 |
Chlorinated Adhesive Formula: Contains vinyl chloride, classified as “Primary forms of ethylene-vinyl acetate-vinyl chloride copolymers” | Copolymer-based adhesives | ✅ Copolymer Base |
3824.10.00.00 |
Chlorinated Adhesive Formula: Designed for mold or core preparation, reflects “prepared” characteristic | Foundry binders, molding agents | ✅ Prepared Binder |
3506.91.50.00 |
Fast-Curing Chlorinated Adhesive: Classified as “Prepared adhesives, polymeric base” | Industrial fast-bonding applications | ✅ Prepared Adhesive |
3506.99.00.00 |
Fast-Curing Chlorinated Adhesive: Classified as “Other prepared adhesives” | General-purpose prepared glues | ✅ Prepared Adhesive |
🔍 Key Reminder:
- Products labeled as “formula” or “prepared” must not be misclassified as raw polymers if they contain additives that alter their chemical nature for immediate use. - Chapter 35 products are typically ready-to-use, while Chapter 39 products are raw materials for further manufacturing. - Misclassification can lead to severe tariff penalties due to differing duty rates.
💰 Part III: 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN)
✅ Effective Date: From November 10, 2025 (and subsequent imports)
🎯 1. 3901.90.90.00 —— Chlorinated Polymer (Other Primary Forms)
| Item | Content |
|---|---|
| Base Duty Rate | 6.5% |
| Section 301 Surtax | +25% |
| IEEPA Add-on Tariff | +10% (Section 122 tariffs) |
| Total Effective Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Eligibility | ❌ Not Eligible (deny_de_minimis) |
| Legal Path | Base: 6.5% → Section 301: +25% → IEEPA: +10% |
📌 Explanation:
- This classification applies to raw chlorinated polymer resins. - Despite being a “chemical,” it is treated as a plastic product (Chapter 39), attracting significant additional tariffs. - 41.5% is a high-cost barrier for exporters.
🎯 2. 3901.30.20.00 —— Ethylene-Vinyl Acetate-Vinyl Chloride Copolymer
| Item | Content |
|---|---|
| Base Duty Rate | 0.0% |
| Section 301 Surtax | +25% |
| IEEPA Add-on Tariff | +10% |
| Total Effective Rate | 35.0% |
| Tax Calculation | CIF Value × 35.0% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Path | Base: 0.0% → Section 301: +25% → IEEPA: +10% |
📌 Note:
- Lower base rate due to specific copolymer classification. - Still subject to heavy surtaxes. Ideal for companies importing high-purity copolymers.
🎯 3. 3824.10.00.00 —— Prepared Binders for Molding or Core
| Item | Content |
|---|---|
| Base Duty Rate | 6.0% |
| Section 301 Surtax | +25% |
| IEEPA Add-on Tariff | +10% |
| Total Effective Rate | 41.0% |
| Tax Calculation | CIF Value × 41.0% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Path | Base: 6.0% → Section 301: +25% → IEEPA: +10% |
📌 Explanation:
- Applies specifically to foundry or molding binders. - If your product is used for casting cores/molds, this is the most accurate classification. - 41.0% total duty remains high.
🎯 4. 3506.91.50.00 —— Fast-Curing Prepared Adhesive (Polymeric Base)
| Item | Content |
|---|---|
| Base Duty Rate | 2.1% |
| Section 301 Surtax | +25% |
| IEEPA Add-on Tariff | +10% |
| Total Effective Rate | 37.1% |
| Tax Calculation | CIF Value × 37.1% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Path | Base: 2.1% → Section 301: +25% → IEEPA: +10% |
📌 Note:
- Best option for “fast-curing” adhesives. - Lower base rate (2.1%) compared to polymer categories. - Still high due to surtaxes, but cheaper than raw polymer imports.
🎯 5. 3506.99.00.00 —— Other Prepared Adhesives
| Item | Content |
|---|---|
| Base Duty Rate | 2.1% |
| Section 301 Surtax | +25% |
| IEEPA Add-on Tariff | +10% |
| Total Effective Rate | 37.1% |
| Tax Calculation | CIF Value × 37.1% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Path | Base: 2.1% → Section 301: +25% → IEEPA: +10% |
📌 Note:
- Catch-all for other prepared adhesives not fitting specific sub-categories. - Same rate as3506.91.50.00, so ensure the product truly fits “prepared” rather than “raw polymer” criteria.
🛠️ Part IV: Customs Clearance Practical Advice (Pitfall Avoidance Guide)
✅ 1. Required Documentation Checklist (All Mandatory)
| Document | Mandatory | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must include composition, active ingredients, curing time, viscosity |
| ✅ Formula/Composition Ratio | ✔️ | Critical for determining if it’s “prepared” vs. “raw polymer” |
| ✅ Product Photos (Label & Packaging) | ✔️ | Show MSDS label, hazard symbols, brand, model |
| ✅ Third-Party Lab Report | ✔️ | MSDS, REACH, or equivalent safety data sheets |
| ✅ Commercial Invoice | ✔️ | Must clearly state “Water-Based Chlorinated Adhesive, Prepared” or “Chlorinated Polymer Resin” |
| ✅ Certificate of Origin (CO) | ✔️ | Required for tariff calculation; if not China-origin, may qualify for lower rates |
| ✅ Packing List | ✔️ | Detail net/gross weight, quantity, and packaging type |
✅ 2. Declaration Tips (Key Mantra)
🔥 “Prepared vs. Raw: Declare the Function, Not Just the Name!”
| Scenario | Correct Declaration | Incorrect Practice |
|---|---|---|
| Raw polymer resin | 3901.90.90.00 |
Mislabeling as “adhesive” → Audit risk |
| Foundry binder | 3824.10.00.00 |
Declaring as “general glue” → Wrong classification |
| Fast-curing glue | 3506.91.50.00 |
Declaring as “polymer” → Higher duty (41.5% vs 37.1%) |
| Generic prepared glue | 3506.99.00.00 |
Over-specifying as “fast-curing” without proof |
📌 Pro Tip:
- Use terms like “Prepared Adhesive” or “Formulated Binder” in the description to justify Chapter 35/38 classification. - Avoid vague terms like “Glue” or “Chemical” without context.
✅ 3. Special Cases Handling
| Situation | Handling Advice |
|---|---|
| OEM Custom Adhesive | Provide customer specs + safety data sheet to prove “prepared” status |
| Adhesive with Solvents | If >50% solvent, may reclassify under Chapter 38 (other chemicals) |
| Water-Based Claim | Must provide MSDS showing water as primary carrier, not solvent |
| Mixed Chemicals | If multiple active ingredients, consult a customs broker for final ruling |
🌍 Part V: Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Total Duty (China Origin) | Certification Required | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3506.99.00.00 |
37.1% | MSDS, TSCA | High surtaxes apply |
| 🇨🇳 China | 3506.99.00.00 |
~2-6% (varies) | CCC (if applicable) | Lower tariffs, no surtaxes |
| 🇪🇺 EU | 3506.99.00.00 |
~6.5% | REACH, CLP | No Section 301 equivalent |
| 🇬🇧 UK | 3506.99.00.00 |
~6.5% | UK REACH | Post-Brexit rules apply |
| 🇯🇵 Japan | 3506.99.00.00 |
~5-7% | JIS, PSE | No major surtaxes |
📌 Conclusion:
- USA is the most expensive market for chlorinated adhesives due to Section 301 and IEEPA tariffs. - EU and Japan offer more favorable conditions for prepared adhesives. - Consider supply chain diversification if exporting to the US at scale.
📌 Part VI: Common Errors & Pitfall Guide (Lessons Learned)
❌ Error 1: Declaring “Prepared Adhesive” as “Raw Polymer”
👉 Consequence: Higher duty (41.5% vs 37.1%) + audit risk
❌ Error 2: Misclassifying “Foundry Binder” as “General Glue”
👉 Consequence: Wrong HS code, potential fines for misdeclaration
❌ Error 3: Omitting MSDS or Composition Details
👉 Consequence: Customs holds shipment for verification → Delays + storage fees
❌ Error 4: Using “Glue” without specifying “Prepared” or “Raw”
👉 Consequence: Ambiguous classification, customs may choose highest applicable rate
✅ Correct Practice:
“Water-Based Fast-Curing Chlorinated Adhesive, Pre-Formulated, Polymeric Base, MSDS Available, Model XYZ”
🎯 Part VII: Conclusion – Precise Classification Saves Money!
🎯 Remember the Mantra:
🔹 “Prepared vs. Raw: Choose Chapter 35/38, Not 39!”
🔹 “Base Rate 2.1% vs 6.5%: Small Difference, Big Savings!”
🔹 “Always Include MSDS: Avoid Customs Delays!”
📌 Pro Tip:
If your adhesive is manufactured in Vietnam, Mexico, or Thailand, you may avoid Section 301 surtaxes, reducing total duty to 0-6.5%.
Recommend pre-advance ruling with US Customs (CBP) to confirm HS code eligibility.
📣 Take Action Now:
📞 Contact a licensed customs broker + Provide MSDS + Apply for HS Code Advance Ruling
🚀 Ensure smooth clearance, cost control, and global competitiveness!
✨ Professional clearance starts with precise classification!
💼 Every percentage point of duty matters!
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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) — 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.