Water based Petroleum Adhesive
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3824994900 | 41.5% | CN | US | Official Doc |
| 3824100000 | 41.0% | CN | US | Official Doc |
| 3901909000 | 41.5% | CN | US | Official Doc |
| 3901905501 | 41.5% | CN | US | Official Doc |
| 3506915000 | 37.1% | CN | US | Official Doc |
AI Analysis
π§ Petroleum-Based Water Adhesives: HS Code Classification & US Tariff Strategy (2026)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional-Level Clearance Strategy
π 1. Product Definition & Classification: Are You Sure You Know "Water Based Petroleum Adhesive"?
Despite the name "Water Based," the products in question are explicitly defined in the data as "Petroleum-based Binders/Adhesives" (derived from petroleum hydrocarbons). This is a critical distinction. In international trade, the classification depends on the chemical nature (petroleum/hydrocarbon origin) and the function (binder/adhesive), not merely the solvent carrier.
These products fall under two main chapters: * Chapter 35: Preparations for use in printing plates, photography, or similar applications (specifically polymer-based adhesives). * Chapter 38: Miscellaneous chemical products (petroleum-based binders not elsewhere specified). * Chapter 39: Plastics and articles thereof (if considered ethylene polymer preparations).
β οΈ Key Distinction Point:
- If the product is a polymer-based adhesive preparation βε½η±» to Chapter 35.
- If the product is a petroleum hydrocarbon binder βε½η±» to Chapter 38.
- If the product is effectively an ethylene polymer mixture βε½η±» to Chapter 39.
π¦ 2. HS Code Classification Details (2026 Latest Tariff Authoritative Comparison)
| HS Code | Product Description | Application Scenario | Tax Rate (US/CN) |
|---|---|---|---|
3824.99.49.00 |
Petroleum-based binder, derived from petroleum hydrocarbons | Generic petroleum binders, industrial glues | 41.5% |
3824.10.00.00 |
Petroleum-based binder, modified adhesives | Modifiers for adhesives, specific petroleum blends | 41.0% |
3901.90.90.00 |
Petroleum-based binder, ethylene polymers | Ethylene-based polymer preparations | 41.5% |
3901.90.55.01 |
Petroleum-based binder, ethylene copolymers | Specific ethylene copolymer preparations | 41.5% |
3506.91.50.00 |
Petroleum-based binder, polymer-based adhesives | Adhesives based on polymers (Chapter 35 scope) | 37.1% |
π Key Reminder:
- "Water-based" does not mean "Non-petroleum." The origin is Petroleum.
- The lowest tariff option is Chapter 35 (3506.91.50.00) at 37.1%, but this requires the product to be strictly classified as a "polymer-based adhesive" under Chapter 35 rules.
- Most generic "petroleum binders" will fall under Chapter 38 or 39, resulting in higher rates (41.0% - 41.5%).
π° 3. 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: 2025/2026 (Current Section 301 & IEEPA tariffs)
π― 1. 3824.99.49.00 & 3901.90.90.00 & 3901.90.55.01 ββ Petroleum & Ethylene Binders
| Item | Content |
|---|---|
| Base Tariff | 6.5% (Ad valorem) |
| Section 301 Surtax | +25% (From USITC Footnote 9903.88.01 / 301 Tariff List) |
| IEEPA Surtax | +10% (Against China/HK products, effective since Nov 10, 2025) |
| 122-Clause Tariff | +10% (As specified in data) |
| Total Effective Rate | 41.5% |
| Tax Calculation | CIF Value Γ 41.5% |
| De Minimis Exemption | β Not Eligible (Highly regulated chemical goods) |
| Legal Basis Path | Base: 6.5% + 301: 25.0% + 122: 10.0% = 41.5% |
π Explanation:
- The 25% Section 301 tariff applies to most chemical products of Chinese origin.
- The 10% IEEPA/122-Clause tariff is a specific additional surcharge for certain Chinese goods.
- Total 41.5% is extremely high for bulk chemicals. Profit margins will be severely impacted.
π― 2. 3824.10.00.00 ββ Modified Petroleum Binders
| Item | Content |
|---|---|
| Base Tariff | 6.0% (Ad valorem) |
| Section 301 Surtax | +25% |
| IEEPA Surtax | +10% |
| 122-Clause Tariff | +10% |
| Total Effective Rate | 41.0% |
| Tax Calculation | CIF Value Γ 41.0% |
| Legal Basis Path | Base: 6.0% + 301: 25.0% + 122: 10.0% = 41.0% |
π Note:
- Slightly lower base rate (6.0% vs 6.5%) results in a total of 41.0%, saving 0.5% compared to other codes.
- This requires precise formulation documentation proving it is a "modified adhesive" under HS 3824.10.
π― 3. 3506.91.50.00 ββ Polymer-Based Adhesives (Lowest Tax Option)
| Item | Content |
|---|---|
| Base Tariff | 2.1% (Ad valorem) |
| Section 301 Surtax | +25% |
| IEEPA Surtax | +10% |
| 122-Clause Tariff | +10% |
| Total Effective Rate | 37.1% |
| Tax Calculation | CIF Value Γ 37.1% |
| Legal Basis Path | Base: 2.1% + 301: 25.0% + 122: 10.0% = 37.1% |
π Crucial Note:
- This is the only code with a base tariff under 3%.
- However, it is only applicable if the product can be legally classified as a "Preparation for use as adhesive, based on polymers" (Chapter 35).
- If customs determines the product is primarily a "petroleum hydrocarbon binder" rather than a "polymer adhesive," they may force reclassification to Chapter 38 or 39, increasing the rate to 41.0%+.
π οΈ 4. Customs Clearance Practical Advice (Battle-Tested Pitfall Avoidance)
β 1. Required Documentation Checklist (Non-Negotiable)
| Document | Required? | Explanation |
|---|---|---|
| β Technical Data Sheet (TDS) | βοΈ | Must specify % of petroleum hydrocarbons, polymer content, and solvent type (water vs. organic). |
| β Formula/Composition Breakdown | βοΈ | Essential for determining if it falls under Ch 35 (Polymer) or Ch 38 (Petroleum). |
| β Product Photos (Label & Container) | βοΈ | Must show "Petroleum-based," "Water-based," and chemical name. |
| β Material Safety Data Sheet (MSDS/SDS) | βοΈ | Required for all chemical shipments. |
| β Commercial Invoice | βοΈ | Must clearly state: "Petroleum-based Water Adhesive, Model XYZ." |
| β Certificate of Origin (CO) | βοΈ | Mandatory for origin determination. |
| β Packaging List | βοΈ | Net/Gross weight, number of containers. |
β 2. Declaration Strategy (Key Mantra)
π₯ "Clarify Chemistry, Not Just Solvent! Polymer = Lower Rate!"
| Scenario | Correct Declaration | Incorrect Action |
|---|---|---|
| High Polymer Content, Water Carrier | 3506.91.50.00 (37.1%) |
Misdeclare as petroleum binder β 41.5% |
| Low Polymer, High Petroleum Resin | 3824.99.49.00 (41.5%) |
Try to force Ch 35 β Risk of audit/penalty |
| Modified Petroleum Adhesive | 3824.10.00.00 (41.0%) |
Generic "Adhesive" β Incorrect base rate |
| Ethylene Polymer Blend | 3901.90.90.00 (41.5%) |
Misclassify as raw plastic β Wrong chapter |
β 3. Special Case Handling
| Situation | Handling Advice |
|---|---|
| OEM Custom Adhesive | Provide client contract + formula sheet. If polymer > 50%, argue for Chapter 35. |
| "Water-Based" Claim | Ensure SDS confirms water is the carrier, but active ingredient is petroleum/polymer. This supports Chapter 35/38 classification. |
| Mixed Shipments | Do not mix Ch 35 and Ch 38 products in one entry unless properly split. Different rates apply. |
| Origin Tracing | If raw materials are from Vietnam/Malaysia, check if substantial transformation occurred. May qualify for IEEPA exemption. |
π 5. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Rate | Certification | Remarks |
|---|---|---|---|---|
| πΊπΈ USA | 3506.91.50.00 |
37.1% | SDS + TDS | Best rate if Ch 35 applies. Otherwise 41.5%. |
| π¨π³ China | 3506.91.50.00 |
6.5% | GB Standards | Low base rate. No Section 301. |
| πͺπΊ EU | 3506.91.50.00 |
4.2% | REACH + CLP | Lower base rate. No 301 surtax. |
| π¦πΊ Australia | 3506.91.50.00 |
5.0% | AICIS | Moderate rate. |
| π―π΅ Japan | 3506.91.50.00 |
3.0% | JIS | Lowest among major markets. |
π Conclusion:
- The US market is the most expensive due to Section 301 (+25%) and IEEPA (+10%) surtaxes.
- Strategic Shift: If possible, source from or process in Vietnam, Mexico, or Thailand to mitigate IEEPA taxes.
- Classification Strategy: Aggressively pursue Chapter 35 (3506.91.50.00) to save 4.4% compared to Chapter 38/39 codes.
π 6. Common Mistakes & Pitfall Guide (Blood & Tears Lessons)
β Mistake 1: Assuming "Water-Based" = "Low Tax"
π Consequence: Customs ignores the "water" part and focuses on "Petroleum Origin" β Tax jumps to 41.5%.
β Mistake 2: Using Generic Name "Adhesive"
π Consequence: Customs officer assigns highest default rate or audits β Delays + Storage Fees.
β Mistake 3: Misclassifying Ethylene Copolymers as Simple Petroleum Resins
π Consequence: Wrong HS code β Back-tariffs + Penalties.
β Mistake 4: Ignoring the 122-Clause Tariff
π Consequence: Underestimating total duty β Profit Loss. The 10% is real and mandatory.
β Correct Practice:
"Polymer-Based Water Adhesive (Petroleum Derivative), Model XYZ, Water-Carrier, SDS Provided"
π― 7. Conclusion: Precision Classification Saves Money!
π― Remember the Mantra:
πΉ "Polymer First, Petroleum Second, Water is Just Carrier!"
πΉ "Chapter 35 saves 4.4%, Chapter 38 pays 41.5%!"
πΉ "US Tariff: Base + 25% + 10% + 10% = High Pain!"
π Pro Tip:
If your adhesive contains >50% synthetic polymers, insist on HS 3506.91.50.00 for the 37.1% rate. Provide polymer structural data to customs brokers immediately.
If your product is primarily petroleum hydrocarbons, prepare for 41.0%-41.5%. Consider origin shifting to avoid IEEPA taxes.
π£ Immediate Action:
π Consult a licensed customs broker with your Chemical Formula.
π Do not guess HS Codes. The difference between 37.1% and 41.5% is significant on large volumes.
β¨ Professional clearance starts with accurate chemical classification!
πΌ Your bottom line depends on the first 4 digits of your HS Code!
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) 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.