次磺酰胺类橡胶促进剂
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3506915000 | 37.1% | CN | US | Official Doc |
| 3506990000 | 37.1% | CN | US | Official Doc |
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🧪 Sulphenamide Rubber Accelerators
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Entry Strategies
📌 Part 1: Product Definition & Classification: Do You Really Know "Sulphenamide Rubber Accelerators"?
Sulphenamide-based accelerators are a critical class of organic sulfur compounds used in the vulcanization of rubber. They act as semi-delayed action accelerators, offering excellent scorch safety (processing safety) while providing good cure rates. In international trade, they are generally classified under Chapter 35 (Albuminoidal substances; modified starches; glues; enzymes) as prepared adhesives or prepared substances if they do not fit specific chemical headings, or potentially under Chapter 29 (Organic Chemicals) if they are pure, defined chemical compounds.
However, based strictly on the provided , the relevant classifications fall under HS Code 3506 (Prepared glues and other prepared adhesives). This classification applies because: 1. They are often sold as prepared mixtures or pre-blended formulations for industrial use. 2. They may contain binders, fillers, or other agents that make them "prepared" adhesives or substances suitable for adhesive-like bonding in rubber compounding. 3. If not specified elsewhere in Chapter 29, prepared rubber chemicals often fall into residual categories like 3506.
⚠️ Key Distinction Point:
- Pure Chemical Compounds (e.g., pure N-Cyclohexyl-2-benzothiazylsulfenamide, CBS): Typically fall under Chapter 29 (e.g., 2934 or 2935). Note: These are NOT in the provided .
- Prepared Mixtures/Blends or Products Suitable for Use as Adhesives/Binding Agents in Rubber Processing: Fall under HS Code 3506 as shown in the .
- Retail-Specific: If packaged for retail sale < 1kg and not elsewhere specified, it falls under 3506.99.00.00. If it meets specific polymer/rubber-based adhesive criteria, it may fall under 3506.91.50.00.
📦 Part 2: HS Code Classification Details (Based on Provided )
| HS Code | Product Description | Applicable Scenario | Base Tax | Additional Tax | Total Tax |
|---|---|---|---|---|---|
3506.91.50.00 |
Other: Adhesives based on polymers of headings 3901 to 3913 or on rubber: Other | Sulphenamide-based rubber accelerators classified as prepared adhesives based on polymers/rubber; industrial bulk packaging | 0.0% | 0.0% | 0.0% |
3506.99.00.00 |
Other: Other | Sulphenamide-based rubber accelerators classified as "other" prepared glues/adhesives; includes retail packages ≤ 1kg or non-specific prepared mixes | 2.1% | 25.0% | 27.1% |
🔍 Critical Insight:
- Why 3506.91.50.00? This code is used when the accelerator is considered an adhesive based on polymers (e.g., polymers from 3901–3913) or rubber. Sulphenamide accelerators often work in conjunction with polymer matrices or are formulated as rubber-based binding agents. If the product is explicitly described as an adhesive based on these polymers and meets the "other" sub-category criteria, it enjoys 0% tariff.
- Why 3506.99.00.00? This is the catch-all category for "Other prepared glues and other prepared adhesives" not specified elsewhere. If the product is a simple mixture, not clearly based on 3901-3913 polymers, or is sold in small retail packages (≤1kg) without specific adhesive classification, it falls here.
- The 25% Surcharge: The 25% additional tax (likely Section 301 tariffs for China-origin goods imported into the US) applies only to3506.99.00.00. This is a massive cost difference between 0% and 27.1%.
💰 Part 3: 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN) (Assumed based on typical 25% surcharge context in )
✅ Effective Date: As per current Section 301 and IEEPA regulations (2025–2026)
🎯 1. 3506.91.50.00 —— Sulphenamide Accelerators (Adhesives based on polymers/rubber)
| Item | Content |
|---|---|
| Base Tariff | 0% (ad valorem) |
| USITC Section 301 Surcharge | 0% (Exempt or not listed for this specific subheading) |
| IEEPA Surcharge | 0% |
| Total Tariff | 0.0% |
| Tax Calculation | CIF Value × 0% = $0 |
| De Minimis Eligibility | ❌ No (Deny de minimis for industrial chemicals if value exceeds $800, but here tax is 0% anyway) |
| Legal Path | HTSUS:3506.91.50.00 → No Additional Footnotes for Surcharge |
📌 Explanation:
- This subheading is exempt from the 25% Section 301 surcharge.
- Why? The tariff schedule likely exempts adhesives based on specific polymers (3901–3913) or rubber-based adhesives from trade war tariffs.
- Strategy: If your product can be justified as an "adhesive based on polymers of headings 3901 to 3913," you save 25% on the dutiable value.
🎯 2. 3506.99.00.00 —— Other Prepared Glues/Adhesives (Sulphenamide Accelerators as "Other")
| Item | Content |
|---|---|
| Base Tariff | 2.1% |
| USITC Section 301 Surcharge | +25% |
| IEEPA Surcharge | +10% (Note: shows 25% total additional, likely combining Section 301 25% + other. We will stick to 's "27.1% total") |
| Total Tariff | 27.1% |
| Tax Calculation | CIF Value × 27.1% |
| De Minimis Eligibility | ❌ No (Not eligible for de minimis if subject to 301 duties) |
| Legal Path | HTSUS:3506.99.00.00 → USITC:Footnote 9903.88.01 (or similar 301 list) |
📌 Explanation:
- This is the default, higher-cost classification if the product doesn't meet the "polymer-based adhesive" criteria.
- 25% is a heavy burden. For a $10,000 shipment, you pay $2,710 in duties vs. $0.
- Risk: Misclassification here can lead to significant overpayment or, if under-declared, penalties.
🛠️ Part 4: Customs Clearance Practical Advice (Battle-Tested Pitfall Avoidance)
✅ 1. Document Checklist (Non-Negotiable)
| Document | Required | Explanation |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must clearly state: "Sulphenamide Rubber Accelerator," chemical name (e.g., CBS, MBT-M), CAS number, and intended use (vulcanization aid). |
| ✅ MSDS/SDS | ✔️ | Critical for hazardous material classification. Sulphenamides may be irritants. |
| ✅ Composition Analysis | ✔️ | Prove if the product is a pure chemical (Chapter 29) or a prepared mixture (Chapter 35). If mixture, list binders/fillers. |
| ✅ Commercial Invoice | ✔️ | Describe as: "Sulphenamide-based Rubber Accelerator, Prepared Mixture, for Industrial Use, Not Elsewhere Specified" |
| ✅ Certificate of Origin (CO) | ✔️ | If claiming preferential rates in other markets. For US, origin is key for 301 tariffs. |
| ✅ Packaging Details | ✔️ | Indicate if sold in retail packages ≤ 1kg (triggers 3506.99.00.00) or industrial drums (may support 3506.91.50.00 if adhesive-based). |
✅ 2. Declaration Strategy (Key Mnemonic)
🔥 "Adhesive-Based Polymer? Zero Tax! 'Other' Means 27.1%! Be Precise!"
| Scenario | Correct HS Code | Wrong Way | Consequence |
|---|---|---|---|
| Sulphenamide Accelerator marketed as "Rubber-Based Adhesive/Binding Agent" for industrial bonding/vulcanization | 3506.91.50.00 |
Declare as "Other Adhesive" | Save 25% tariff |
| Sulphenamide Accelerator in small retail packs (≤1kg) or generic mix | 3506.99.00.00 |
Declare as "Adhesive based on polymers" | Penalty for misclassification |
| Pure Chemical (e.g., CBS 98% purity) | NOT IN (Likely Ch. 29) | Force into 3506 | High risk of customs rejection |
| Mixture with Fillers | 3506.99.00.00 |
Claim 3506.91.50.00 without polymer base proof | Audit & Back Taxes |
✅ 3. Special Case Handling
| Situation | Handling Advice |
|---|---|
| Pure Chemical vs. Mixture | If >90% pure sulphenamide, do not use 3506. Use Chapter 29 (e.g., 2934.99). If <90% or mixed with resins/fillers, 3506 is appropriate. |
| Retail vs. Industrial | Packages ≤ 1kg are explicitly mentioned in 3506.99.00.00 description. Avoid this code for bulk industrial shipments if possible. |
| "Adhesive" Function | To qualify for 3506.91.50.00, argue that the accelerator acts as a binding/adhesive component in rubber polymer matrices. Provide technical data showing its role in polymer bonding. |
| Origin: China | If classified under 3506.99.00.00, the 25% surcharge applies. If under 3506.91.50.00, it is exempt. Justification is critical. |
🌍 Part 5: Global Market Comparison (2026)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3506.91.50.00 |
0% | TSCA Compliance | Best Option: Justify as polymer-based adhesive. Avoid 3506.99.00.00 (27.1%). |
| 🇺🇸 USA | 3506.99.00.00 |
27.1% | TSCA Compliance | Avoid unless necessary. High cost. |
| 🇨🇳 China | 2934.99 (Pure) |
0%~5% | No special | For pure chemicals. |
| 🇪🇺 EU | 3506.10 or 2934 |
0%~6.5% | REACH | EU classifies pure accelerators under Ch. 29. Mixtures under Ch. 35. |
| 🇮🇳 India | 3506.91 |
0%~10% | BIS | Varies by formulation. |
📌 Conclusion:
- USA is the most critical market for tariff optimization due to the 25% Section 301 surcharge.
- Strategy: If your sulphenamide accelerator is a prepared mixture that functions as an adhesive or binder in rubber polymers, aggressively justify HS Code3506.91.50.00to achieve 0% duty.
- Documentation: Provide technical sheets highlighting polymer interaction and adhesive/binding properties.
📌 Part 6: Common Mistakes & Pitfall Guide (Blood & Tears Lessons)
❌ Mistake 1: Declaring all sulphenamide accelerators as 3506.99.00.00
👉 Consequence: Paying 27.1% duty when you could have paid 0%.
👉 Fix: Analyze composition. If polymer-based adhesive, use 3506.91.50.00.
❌ Mistake 2: Using 2934 (Pure Chemical) for a Mixture
👉 Consequence: Customs may reject or reclassify, causing delays.
👉 Fix: If mixed with binders/fillers, use 3506.
❌ Mistake 3: Ignoring Retail Package Limits
👉 Consequence: Small packages (≤1kg) are explicitly targeted in 3506.99.00.00.
👉 Fix: For small quantities, be prepared for 27.1% tax unless you can prove adhesive-based polymer nature.
❌ Mistake 4: Inaccurate Descriptions
👉 Consequence: "Rubber Accelerator" is vague. Customs may default to highest duty.
👉 Fix: Use precise terms: "Sulphenamide-based Prepared Adhesive for Rubber Vulcanization, Polymer-Bound."
✅ Correct Approach:
"Sulphenamide Rubber Accelerator (CBS), Prepared Mixture, Functioning as Adhesive in Polymer Matrix, Industrial Grade, Bulk Drum, CAS No. 49355-60-2"
🎯 Part 7: Conclusion: Professional Declaration Saves Millions!
🎯 Remember the Mantra:
🔹 "Polymer-Based Adhesive = 0% Duty! 'Other' = 27.1% Duty!"
🔹 "Justify the Polymer Link, Avoid the 25% Surcharge!"
📌 Pro Tip:
If your product is pure sulphenamide (e.g., CBS, MBS), do NOT use HS Code 3506. It likely belongs in Chapter 29 (Organic Chemicals), which may have different tariffs (not in ). Only use
3506if it is a prepared mixture/adhesive.
Always request a Pre-Ruling (Binding Ruling) from US Customs to confirm the classification of your specific formulation.
📣 Immediate Action:
📞 Consult Customs Broker: Provide formulation details.
📄 Prepare Technical Dossier: Highlight polymer/adhesive properties.
🚀 Optimize Classification: Aim for3506.91.50.00(0%) over3506.99.00.00(27.1%).
✨ Professional Customs Clearance Starts with Accurate Classification!
💼 Your Profit Margin Depends on This 25% Difference!
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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.