Chapter 39 covers plastics and articles thereof, and is an important chapter in the HS classification divided by material properties. This chapter includes polymers in primary forms, plastic semi-finished products other than synthetic rubber, waste and scrap, and articles. Primary forms refer to unprocessed forms such as liquids, pastes, blocks, powders, and granules, covering polyethylene, polypropylene, polyvinyl chloride, etc. The notes to this chapter clarify the boundaries with Chapter 28, Chapter 40, etc., and emphasize the chemical synthesis properties of plastics. Heading 3901 covers polymers of ethylene in primary forms, including polyethylene and its copolymers. Specific subheadings are divided by density and comonomer: 3901.10 is polyethylene with a specific gravity of less than 0.94, namely low-density polyethylene (LDPE) and linear low-density polyethylene (LLDPE); 3901.20 is high-density polyethylene (HDPE) with a specific gravity of >= 0.94; 3901.30 is ethylene-vinyl acetate copolymers; 3901.40 is ethylene-propylene copolymers, etc. This heading is one of the most common headings in the trade of plastic raw materials. Code 390110 is a six-digit subheading: the first 2 digits "39" represent Chapter 39 (plastics and articles thereof); the 3rd-4th digits "01" represent heading 3901 (polymers of ethylene in primary forms); the 5th-6th digits "10" represent subheading 3901.10, namely polyethylene with a specific gravity of less than 0.94. In the HS classification, the 5th-6th digits are internationally harmonized subheadings, while the 7th-8th digits and beyond are further subdivided by individual countries. China Customs further subdivides 390110 into 10 (polyethylene with a specific gravity <0.94), etc. Therefore, 390110.10 may refer to low-density polyethylene, while 390110.90 may refer to others. When classifying, note that density is the core distinguishing indicator. This commodity is polyethylene in primary forms with a specific gravity of less than 0.94, which conforms to the description of subheading 3901.10. The difference from 3901.20 (polyethylene with a specific gravity >= 0.94) lies in density; the difference from 3901.30 (ethylene-vinyl acetate copolymers) lies in the comonomer; the difference from 3902 (polymers of propylene in primary forms) lies in the monomer units. Therefore, based on density and monomer type, it is correctly classified under 390110.
Chapter
Chapter 39 covers plastics and articles thereof, and is an important chapter in the HS classification divided by material properties. This chapter includes polymers in primary forms, plastic semi-finished products other than synthetic rubber, waste and scrap, and articles. Primary forms refer to unprocessed forms such as liquids, pastes, blocks, powders, and granules, covering polyethylene, polypropylene, polyvinyl chloride, etc. The notes to this chapter clarify the boundaries with Chapter 28, Chapter 40, etc., and emphasize the chemical synthesis properties of plastics.
Heading
Heading 3901 covers polymers of ethylene in primary forms, including polyethylene and its copolymers. Specific subheadings are divided by density and comonomer: 3901.10 is polyethylene with a specific gravity of less than 0.94, namely low-density polyethylene (LDPE) and linear low-density polyethylene (LLDPE); 3901.20 is high-density polyethylene (HDPE) with a specific gravity of >= 0.94; 3901.30 is ethylene-vinyl acetate copolymers; 3901.40 is ethylene-propylene copolymers, etc. This heading is one of the most common headings in the trade of plastic raw materials.
Digit Breakdown
Code 390110 is a six-digit subheading: the first 2 digits "39" represent Chapter 39 (plastics and articles thereof); the 3rd-4th digits "01" represent heading 3901 (polymers of ethylene in primary forms); the 5th-6th digits "10" represent subheading 3901.10, namely polyethylene with a specific gravity of less than 0.94. In the HS classification, the 5th-6th digits are internationally harmonized subheadings, while the 7th-8th digits and beyond are further subdivided by individual countries. China Customs further subdivides 390110 into 10 (polyethylene with a specific gravity <0.94), etc. Therefore, 390110.10 may refer to low-density polyethylene, while 390110.90 may refer to others. When classifying, note that density is the core distinguishing indicator.
Classification Basis
This commodity is polyethylene in primary forms with a specific gravity of less than 0.94, which conforms to the description of subheading 3901.10. The difference from 3901.20 (polyethylene with a specific gravity >= 0.94) lies in density; the difference from 3901.30 (ethylene-vinyl acetate copolymers) lies in the comonomer; the difference from 3902 (polymers of propylene in primary forms) lies in the monomer units. Therefore, based on density and monomer type, it is correctly classified under 390110.
📝 Declaration Elements
Product name: The specific name of the declared commodity, such as low-density polyethylene, linear low-density polyethylene, etc., which must be consistent with the contract. Appearance: Describe the physical form of the primary form, such as granules, powder, liquid, etc., and indicate the color. Density: Declare the specific gravity or density value of the polyethylene, which must be less than 0.94, usually expressed in g/cm³. Composition content: Indicate the percentage content of polyethylene and whether it contains other comonomers or additives. Types of monomer units: Explain what monomer units the polymer is composed of, such as ethylene monomer. Grade: Declare the manufacturer's grade or model to facilitate Customs identification of the specific product. Use: Briefly describe the processing use, such as for film, injection molding, blow molding, etc. Source: Indicate whether it is virgin or recycled; recycled materials require relevant certificates. Product name: Low-density polyethylene (LDPE); Appearance: milky white granules; Density: 0.92g/cm³; Composition content: polyethylene >=99%, additives <=1%; Monomer unit: ethylene monomer; Grade: LF-123; Use: used for producing packaging films; Source: virgin. Inaccurate density declaration, mistakenly classifying high-density polyethylene with a specific gravity of 0.94 or above under 390110. Mistakenly classifying ethylene-vinyl acetate copolymer (EVA) under 390110, when it should actually be classified under 390130. Failure to declare the source of recycled polyethylene, which may be determined as solid waste, leading to return or penalties.
Product name
The specific name of the declared commodity, such as low-density polyethylene, linear low-density polyethylene, etc., which must be consistent with the contract.
⚠️ Writing only "polyethylene" without indicating the density type, or mistakenly writing non-standard names such as "high-pressure polyethylene".
Appearance
Describe the physical form of the primary form, such as granules, powder, liquid, etc., and indicate the color.
⚠️ Omitting color or form description, such as writing only "granules" without stating whether they are transparent, milky white, etc.
Density
Declare the specific gravity or density value of the polyethylene, which must be less than 0.94, usually expressed in g/cm³.
⚠️ Failing to provide a specific value, or mistakenly reporting it as 0.94 or above, resulting in incorrect classification.
Composition content
Indicate the percentage content of polyethylene and whether it contains other comonomers or additives.
⚠️ Failing to list additive components, or incorrectly reporting ethylene-vinyl acetate copolymers as polyethylene.
Types of monomer units
Explain what monomer units the polymer is composed of, such as ethylene monomer.
⚠️ Ignoring comonomers, such as simply reporting ethylene-propylene copolymers as polyethylene.
Grade
Declare the manufacturer's grade or model to facilitate Customs identification of the specific product.
⚠️ Incorrect grade entry or inconsistency with the contract.
Use
Briefly describe the processing use, such as for film, injection molding, blow molding, etc.
⚠️ Use description is too general, such as "industrial use".
Source
Indicate whether it is virgin or recycled; recycled materials require relevant certificates.
⚠️ Failure to declare recycled materials, leading to suspected solid waste risk.
Inaccurate density declaration, mistakenly classifying high-density polyethylene with a specific gravity of 0.94 or above under 390110.
Mistakenly classifying ethylene-vinyl acetate copolymer (EVA) under 390110, when it should actually be classified under 390130.
Failure to declare the source of recycled polyethylene, which may be determined as solid waste, leading to return or penalties.
🎯 Classification Logic
The core basis for classification is that the commodity is a polymer of ethylene in primary forms with a specific gravity of less than 0.94. According to the notes to Chapter 39 and subheading notes of the Import and Export Tariff, 3901.10 applies only to polyethylene with a specific gravity of less than 0.94. If the specific gravity is >= 0.94, it is classified under 3901.20. If it contains other comonomers (such as vinyl acetate) and the content exceeds a certain proportion, it may be classified under 3901.30 or other subheadings. In addition, it is necessary to confirm whether the commodity has undergone further processing; if it has been made into plates, sheets, film, etc., it is classified under subsequent headings of Chapter 39. 390120 Polyethylene in primary forms (specific gravity >= 0.94): Different density: 390120 is high-density polyethylene with a density >= 0.94; 390110 is low-density polyethylene with a density <0.94. 390130 Ethylene-vinyl acetate copolymers in primary forms: Different comonomer: 390130 contains vinyl acetate comonomer, while 390110 is an ethylene homopolymer. 390140 Ethylene-propylene copolymers in primary forms: Different monomer units: 390140 is a copolymer of ethylene and propylene, while 390110 is an ethylene homopolymer. 390210 Polypropylene in primary forms: Different polymer type: 390210 is a propylene polymer, while 390110 is an ethylene polymer. 390410 Polyvinyl chloride in primary forms: Different polymer type: 390410 is a vinyl chloride polymer, while 390110 is an ethylene polymer. Confirm that the commodity is in primary forms (granules, powder, liquid, etc.). Confirm whether the density is less than 0.94g/cm³ and retain the test report. Confirm whether it contains other comonomers, such as vinyl acetate, propylene, etc. Confirm whether it has undergone further processing, such as being made into film, pipes, etc. Confirm whether it is recycled material; recycled materials require compliance certificates.
Basis
The core basis for classification is that the commodity is a polymer of ethylene in primary forms with a specific gravity of less than 0.94. According to the notes to Chapter 39 and subheading notes of the Import and Export Tariff, 3901.10 applies only to polyethylene with a specific gravity of less than 0.94. If the specific gravity is >= 0.94, it is classified under 3901.20. If it contains other comonomers (such as vinyl acetate) and the content exceeds a certain proportion, it may be classified under 3901.30 or other subheadings. In addition, it is necessary to confirm whether the commodity has undergone further processing; if it has been made into plates, sheets, film, etc., it is classified under subsequent headings of Chapter 39.
Confused Codes：
390120 - Polyethylene in primary forms (specific gravity >= 0.94)
Different density: 390120 is high-density polyethylene with a density >= 0.94; 390110 is low-density polyethylene with a density <0.94.
390130 - Ethylene-vinyl acetate copolymers in primary forms
Different comonomer: 390130 contains vinyl acetate comonomer, while 390110 is an ethylene homopolymer.
390140 - Ethylene-propylene copolymers in primary forms
Different monomer units: 390140 is a copolymer of ethylene and propylene, while 390110 is an ethylene homopolymer.
390210 - Polypropylene in primary forms
Different polymer type: 390210 is a propylene polymer, while 390110 is an ethylene polymer.
390410 - Polyvinyl chloride in primary forms
Different polymer type: 390410 is a vinyl chloride polymer, while 390110 is an ethylene polymer.
Self-Check：
✓ Confirm that the commodity is in primary forms (granules, powder, liquid, etc.).
✓ Confirm whether the density is less than 0.94g/cm³ and retain the test report.
✓ Confirm whether it contains other comonomers, such as vinyl acetate, propylene, etc.
✓ Confirm whether it has undergone further processing, such as being made into film, pipes, etc.
✓ Confirm whether it is recycled material; recycled materials require compliance certificates.
❓ FAQ
How can I check the import tariff rate for 390110? It can be checked through the "Import and Export Tariff" on the official website of the General Administration of Customs of China, or by using the Customs commodity classification system. The tariff rate will change according to trade agreements, origin, etc., and the latest tariff should be used as the standard. You may also consult a professional customs broker. Is there a difference in HS codes between low-density polyethylene and linear low-density polyethylene? Under the six-digit subheading 390110, both are classified under the same code because their densities are both less than 0.94. However, under China Customs' eight-digit and ten-digit codes, they may be further subdivided and must be declared according to specific composition and density. If the density of polyethylene is exactly 0.94, which code should it be classified under? When the density is equal to 0.94, it should be classified under 390120 (specific gravity >= 0.94), because 390110 requires a specific gravity of less than 0.94. Classification must be judged strictly by the numerical value to avoid errors at the critical point. Can recycled polyethylene granules be classified under 390110? Yes, but they must meet the requirements for primary forms and density. At the same time, recycled materials must comply with China's solid waste management regulations and provide relevant test reports proving that they are not solid waste. Otherwise, import may be prohibited. What are the requirements for the density test report at the time of declaration? The test report should be issued by an authoritative institution, use a standard method (such as ISO 1183), and clearly state the density value. The report must be attached at the time of customs declaration for Customs inspection. If it cannot be provided, classification may be affected. What is the main difference between 390110 and 390130? 390110 is an ethylene homopolymer with a density <0.94; 390130 is an ethylene-vinyl acetate copolymer containing vinyl acetate monomer. If polyethylene contains a small amount of vinyl acetate, it must be judged according to the definition of copolymer; usually, if the content exceeds 5%, it is classified under 390130. What regulatory documents are required for importing polyethylene? Generally, no special regulatory documents are required for importing polyethylene, but if it is recycled material, a solid waste import license (if applicable) and test reports must be provided. For details, check the regulatory conditions issued by the General Administration of Customs. How can polyethylene classification errors be avoided? Recommendations: 1. Accurately measure density; 2. Clarify monomer units and comonomers; 3. Retain complete technical documentation; 4. Consult professional classification personnel; 5. Use Customs advance classification services.
Q: How can I check the import tariff rate for 390110?
A: It can be checked through the "Import and Export Tariff" on the official website of the General Administration of Customs of China, or by using the Customs commodity classification system. The tariff rate will change according to trade agreements, origin, etc., and the latest tariff should be used as the standard. You may also consult a professional customs broker.
Q: Is there a difference in HS codes between low-density polyethylene and linear low-density polyethylene?
A: Under the six-digit subheading 390110, both are classified under the same code because their densities are both less than 0.94. However, under China Customs' eight-digit and ten-digit codes, they may be further subdivided and must be declared according to specific composition and density.
Q: If the density of polyethylene is exactly 0.94, which code should it be classified under?
A: When the density is equal to 0.94, it should be classified under 390120 (specific gravity >= 0.94), because 390110 requires a specific gravity of less than 0.94. Classification must be judged strictly by the numerical value to avoid errors at the critical point.
Q: Can recycled polyethylene granules be classified under 390110?
A: Yes, but they must meet the requirements for primary forms and density. At the same time, recycled materials must comply with China's solid waste management regulations and provide relevant test reports proving that they are not solid waste. Otherwise, import may be prohibited.
Q: What are the requirements for the density test report at the time of declaration?
A: The test report should be issued by an authoritative institution, use a standard method (such as ISO 1183), and clearly state the density value. The report must be attached at the time of customs declaration for Customs inspection. If it cannot be provided, classification may be affected.
Q: What is the main difference between 390110 and 390130?
A: 390110 is an ethylene homopolymer with a density <0.94; 390130 is an ethylene-vinyl acetate copolymer containing vinyl acetate monomer. If polyethylene contains a small amount of vinyl acetate, it must be judged according to the definition of copolymer; usually, if the content exceeds 5%, it is classified under 390130.
Q: What regulatory documents are required for importing polyethylene?
A: Generally, no special regulatory documents are required for importing polyethylene, but if it is recycled material, a solid waste import license (if applicable) and test reports must be provided. For details, check the regulatory conditions issued by the General Administration of Customs.
Q: How can polyethylene classification errors be avoided?
A: Recommendations: 1. Accurately measure density; 2. Clarify monomer units and comonomers; 3. Retain complete technical documentation; 4. Consult professional classification personnel; 5. Use Customs advance classification services.
⚠️ Disclaimer: HS code classification, declaration elements, tariff rates and regulatory conditions on this page are for reference only and do not constitute legal advice on customs classification. Tariff rates and regulations are subject to change; the latest announcements from the General Administration of Customs and on-site determinations shall prevail. Please consult professional customs brokers or customs authorities before import/export.