Chapter 39 covers plastics and articles thereof, including polymers in primary forms, waste, parings and scrap, and semi-manufactures, as well as articles of plastics in specific forms such as plates, sheets, film, foil, and strip. This chapter is divided into headings by polymer type and form, and is a core chapter for the classification of plastic raw materials in international trade. Heading 3904 covers polymers of vinyl chloride or of other halogenated olefins, in primary forms, including polyvinyl chloride (PVC) homopolymers, vinyl chloride copolymers, and other halogenated olefin polymers. Under this heading, goods are further subdivided by polymer type and form. The first 2 digits "39" represent Chapter 39 (Plastics and articles thereof); digits 3-4 "04" represent heading 3904 (Polymers of vinyl chloride or of other halogenated olefins, in primary forms); digits 5-6 "90" represent subheading 3904.90, i.e., "Other" polymers of vinyl chloride in primary forms, referring to vinyl chloride polymers other than polyvinyl chloride homopolymers (3904.10), unmixed vinyl chloride copolymers (3904.21/22), and fluoropolymers (3904.30), etc. The goods are vinyl chloride polymers in primary forms, but do not meet the definition of 3904.10 (pure PVC homopolymer) or 3904.21/22 (specific copolymers), and are therefore classified under 3904.90 "Other". Common examples include chlorinated polyvinyl chloride (CPVC), vinyl chloride-vinyl acetate copolymers (VCVA), etc., but note that if the vinyl chloride units do not predominate in the copolymer, classification may fall under other headings.
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, waste, parings and scrap, and semi-manufactures, as well as articles of plastics in specific forms such as plates, sheets, film, foil, and strip. This chapter is divided into headings by polymer type and form, and is a core chapter for the classification of plastic raw materials in international trade.
Heading
Heading 3904 covers polymers of vinyl chloride or of other halogenated olefins, in primary forms, including polyvinyl chloride (PVC) homopolymers, vinyl chloride copolymers, and other halogenated olefin polymers. Under this heading, goods are further subdivided by polymer type and form.
Digit Breakdown
The first 2 digits "39" represent Chapter 39 (Plastics and articles thereof); digits 3-4 "04" represent heading 3904 (Polymers of vinyl chloride or of other halogenated olefins, in primary forms); digits 5-6 "90" represent subheading 3904.90, i.e., "Other" polymers of vinyl chloride in primary forms, referring to vinyl chloride polymers other than polyvinyl chloride homopolymers (3904.10), unmixed vinyl chloride copolymers (3904.21/22), and fluoropolymers (3904.30), etc.
Classification Basis
The goods are vinyl chloride polymers in primary forms, but do not meet the definition of 3904.10 (pure PVC homopolymer) or 3904.21/22 (specific copolymers), and are therefore classified under 3904.90 "Other". Common examples include chlorinated polyvinyl chloride (CPVC), vinyl chloride-vinyl acetate copolymers (VCVA), etc., but note that if the vinyl chloride units do not predominate in the copolymer, classification may fall under other headings.
📝 Declaration Elements
Product Name: The specific name of the declared commodity, such as "chlorinated polyvinyl chloride" or "vinyl chloride-vinyl acetate copolymer", which must be consistent with the contract and invoice. Appearance: Describe the physical form of the primary shape, such as powder, granules, paste, lumps, etc., which must match the actual goods. Composition and Content: List the main monomer units and their percentage content, such as vinyl chloride 95%, vinyl acetate 5%, accurate to one decimal place. Types and Proportions of Monomer Units: Clearly state the name and molar ratio or weight ratio of each monomer unit, used to distinguish homopolymers from copolymers. Brand (Grade): Fill in the manufacturer's brand and specific grade, such as "Shin-Etsu S-100"; if there is no brand, indicate "no brand". Model: Fill in the product model or specification, such as "CPVC-1000", which must be consistent with the quality inspection report. Use: Briefly describe the main application fields, such as "used for pipes, profiles, injection-molded parts, etc.", and it must be specific. Packaging Specifications: Indicate the packaging form and net weight, such as "25kg/bag, 1000 bags in total", which must be consistent with the bill of lading. Product Name: Chlorinated polyvinyl chloride (CPVC); Appearance: White powder; Composition and Content: Vinyl chloride 67%, chlorine 33%; Types and Proportions of Monomer Units: Vinyl chloride units 100% (chlorination-modified); Brand: No brand; Model: CPVC-1000; Use: Used for hot water pipes; Packaging Specifications: 25kg/bag, 800 bags in total. Mistakenly classifying chlorinated polyvinyl chloride (CPVC) under 3904.10; in fact, due to its high chlorine content, it should be classified under 3904.90. If the vinyl acetate content in a vinyl chloride-vinyl acetate copolymer exceeds 50%, it may be classified under 3905.30 rather than 3904.90. Failure to provide the monomer ratio makes it impossible to distinguish homopolymers from copolymers and may result in customs rejection.
Product Name
The specific name of the declared commodity, such as "chlorinated polyvinyl chloride" or "vinyl chloride-vinyl acetate copolymer", which must be consistent with the contract and invoice.
⚠️ Writing only "PVC" or "plastic raw material", which is too general and does not reflect the specific polymer type.
Appearance
Describe the physical form of the primary shape, such as powder, granules, paste, lumps, etc., which must match the actual goods.
⚠️ Mistaking granules for powder, or failing to indicate whether it is in primary forms.
Composition and Content
List the main monomer units and their percentage content, such as vinyl chloride 95%, vinyl acetate 5%, accurate to one decimal place.
⚠️ Writing only "polymer" without providing the monomer ratio, making classification impossible.
Types and Proportions of Monomer Units
Clearly state the name and molar ratio or weight ratio of each monomer unit, used to distinguish homopolymers from copolymers.
⚠️ Confusing weight ratio with molar ratio, or omitting minor monomers.
Brand (Grade)
Fill in the manufacturer's brand and specific grade, such as "Shin-Etsu S-100"; if there is no brand, indicate "no brand".
⚠️ Mistaking the grade for the model, or failing to fill it in, making traceability impossible.
Model
Fill in the product model or specification, such as "CPVC-1000", which must be consistent with the quality inspection report.
⚠️ Confusing model with grade, or providing incomplete information.
Use
Briefly describe the main application fields, such as "used for pipes, profiles, injection-molded parts, etc.", and it must be specific.
⚠️ Writing only "industrial use", which is too broad.
Packaging Specifications
Indicate the packaging form and net weight, such as "25kg/bag, 1000 bags in total", which must be consistent with the bill of lading.
⚠️ Failing to indicate net weight or packaging unit, causing difficulties in inspection.
Example： Product Name: Chlorinated polyvinyl chloride (CPVC); Appearance: White powder; Composition and Content: Vinyl chloride 67%, chlorine 33%; Types and Proportions of Monomer Units: Vinyl chloride units 100% (chlorination-modified); Brand: No brand; Model: CPVC-1000; Use: Used for hot water pipes; Packaging Specifications: 25kg/bag, 800 bags in total.
Common Mistakes：
Mistakenly classifying chlorinated polyvinyl chloride (CPVC) under 3904.10; in fact, due to its high chlorine content, it should be classified under 3904.90.
If the vinyl acetate content in a vinyl chloride-vinyl acetate copolymer exceeds 50%, it may be classified under 3905.30 rather than 3904.90.
Failure to provide the monomer ratio makes it impossible to distinguish homopolymers from copolymers and may result in customs rejection.
🎯 Classification Logic
The core basis for classification is the chemical composition of the polymer and its primary form. First confirm whether it is a vinyl chloride polymer, then determine whether it is a homopolymer or copolymer, and then classify it under the corresponding subheading according to the copolymer type. 3904.90 applies to vinyl chloride polymers other than polyvinyl chloride homopolymers, unmixed vinyl chloride copolymers (such as vinyl chloride-vinyl acetate copolymers in which vinyl chloride predominates), and fluoropolymers, such as chlorinated polyvinyl chloride, vinyl chloride-acrylate copolymers, etc. 3904.10 Polyvinyl chloride (PVC) homopolymer: 3904.10 is unmodified pure PVC homopolymer, while 3904.90 is chemically modified or copolymerized vinyl chloride polymers, such as CPVC or VCVA. 3904.21 Unmixed vinyl chloride-vinyl acetate copolymer: 3904.21 refers to VCVA copolymers not mixed with other substances, and the vinyl acetate content is usually ≤50%; if mixed or if the content exceeds the limit, classification falls under 3904.90 or elsewhere. 3904.30 Fluoropolymers: 3904.30 covers fluorine-containing halogenated olefin polymers, such as PTFE and PVDF; if the polymer does not contain fluorine, it is classified under 3904.90. 3905.30 Vinyl acetate copolymers in primary forms: 3905.30 covers copolymers in which vinyl acetate predominates, such as EVA; if vinyl chloride predominates, classification falls under 3904.90. Is it confirmed to be in primary forms (powder, granules, paste, etc.)? Does it contain vinyl chloride monomer units? Is it a homopolymer or a specific copolymer? Has it undergone chemical modification such as chlorination? Is the monomer ratio clear and consistent with the subheading definition?
Basis
The core basis for classification is the chemical composition of the polymer and its primary form. First confirm whether it is a vinyl chloride polymer, then determine whether it is a homopolymer or copolymer, and then classify it under the corresponding subheading according to the copolymer type. 3904.90 applies to vinyl chloride polymers other than polyvinyl chloride homopolymers, unmixed vinyl chloride copolymers (such as vinyl chloride-vinyl acetate copolymers in which vinyl chloride predominates), and fluoropolymers, such as chlorinated polyvinyl chloride, vinyl chloride-acrylate copolymers, etc.
Confused Codes：
3904.10 - Polyvinyl chloride (PVC) homopolymer
3904.10 is unmodified pure PVC homopolymer, while 3904.90 is chemically modified or copolymerized vinyl chloride polymers, such as CPVC or VCVA.
3904.21 refers to VCVA copolymers not mixed with other substances, and the vinyl acetate content is usually ≤50%; if mixed or if the content exceeds the limit, classification falls under 3904.90 or elsewhere.
3904.30 - Fluoropolymers
3904.30 covers fluorine-containing halogenated olefin polymers, such as PTFE and PVDF; if the polymer does not contain fluorine, it is classified under 3904.90.
3905.30 - Vinyl acetate copolymers in primary forms
3905.30 covers copolymers in which vinyl acetate predominates, such as EVA; if vinyl chloride predominates, classification falls under 3904.90.
Self-Check：
✓ Is it confirmed to be in primary forms (powder, granules, paste, etc.)?
✓ Does it contain vinyl chloride monomer units?
✓ Is it a homopolymer or a specific copolymer?
✓ Has it undergone chemical modification such as chlorination?
✓ Is the monomer ratio clear and consistent with the subheading definition?
❓ FAQ
How can one determine whether a vinyl chloride copolymer should be classified under 3904.21 or 3904.90? First confirm whether the copolymer is not mixed with other substances and whether the molar ratio of vinyl chloride to vinyl acetate is within a specific range (usually vinyl acetate ≤50%). If it meets the conditions, classify under 3904.21; if it has been mixed or the vinyl acetate content exceeds the limit, classify under 3904.90. Why can chlorinated polyvinyl chloride (CPVC) not be classified under 3904.10? 3904.10 applies only to unmodified polyvinyl chloride homopolymers. CPVC is a chlorination-modified polymer with significantly increased chlorine content and a changed chemical structure, so it should be classified under 3904.90 "Other". How should the composition and content be filled in during declaration to avoid classification disputes? The name and weight percentage of each monomer unit must be filled in accurately, such as "vinyl chloride 95%, vinyl acetate 5%", and a test report should be provided as supporting evidence. Avoid writing only "polymer" or "plastic". What regulatory conditions should be noted when importing goods under 3904.90? Attention should be paid to whether anti-dumping or countervailing measures are involved, and whether a certificate of origin, quality inspection report, etc. are required. For details, consult announcements from the General Administration of Customs or a customs broker. If the vinyl chloride units account for 30% in a vinyl chloride copolymer, which code should it be classified under? If vinyl chloride units do not predominate, it cannot be classified under 3904. It must be classified according to the other monomer units; for example, if vinyl acetate predominates, classify under 3905.30, and if acrylate predominates, classify under 3906.90. Are waste vinyl chloride polymers in primary forms classified under 3904.90? Waste is generally classified under 3915 (waste, parings and scrap of plastics), but if it is unused polymer in primary forms, it is still classified under 3904. A distinction must be made between waste and defective goods. How can one check the import tariff rate for 3904.90? Through the official website of the General Administration of Customs, China International Trade Single Window, or third-party query platforms, enter the HS code and country of origin to obtain the MFN rate, agreement rate, etc. Tariff rates may be adjusted, and the latest announcement shall prevail.
Q: How can one determine whether a vinyl chloride copolymer should be classified under 3904.21 or 3904.90?
A: First confirm whether the copolymer is not mixed with other substances and whether the molar ratio of vinyl chloride to vinyl acetate is within a specific range (usually vinyl acetate ≤50%). If it meets the conditions, classify under 3904.21; if it has been mixed or the vinyl acetate content exceeds the limit, classify under 3904.90.
Q: Why can chlorinated polyvinyl chloride (CPVC) not be classified under 3904.10?
A: 3904.10 applies only to unmodified polyvinyl chloride homopolymers. CPVC is a chlorination-modified polymer with significantly increased chlorine content and a changed chemical structure, so it should be classified under 3904.90 "Other".
Q: How should the composition and content be filled in during declaration to avoid classification disputes?
A: The name and weight percentage of each monomer unit must be filled in accurately, such as "vinyl chloride 95%, vinyl acetate 5%", and a test report should be provided as supporting evidence. Avoid writing only "polymer" or "plastic".
Q: What regulatory conditions should be noted when importing goods under 3904.90?
A: Attention should be paid to whether anti-dumping or countervailing measures are involved, and whether a certificate of origin, quality inspection report, etc. are required. For details, consult announcements from the General Administration of Customs or a customs broker.
Q: If the vinyl chloride units account for 30% in a vinyl chloride copolymer, which code should it be classified under?
A: If vinyl chloride units do not predominate, it cannot be classified under 3904. It must be classified according to the other monomer units; for example, if vinyl acetate predominates, classify under 3905.30, and if acrylate predominates, classify under 3906.90.
Q: Are waste vinyl chloride polymers in primary forms classified under 3904.90?
A: Waste is generally classified under 3915 (waste, parings and scrap of plastics), but if it is unused polymer in primary forms, it is still classified under 3904. A distinction must be made between waste and defective goods.
Q: How can one check the import tariff rate for 3904.90?
A: Through the official website of the General Administration of Customs, China International Trade Single Window, or third-party query platforms, enter the HS code and country of origin to obtain the MFN rate, agreement rate, etc. Tariff rates may be adjusted, and the latest announcement shall prevail.
⚠️ 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.