Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, plastic materials, etc. This chapter is divided into multiple headings by polymer type, such as polyethylene, polypropylene, polystyrene, etc. Primary forms refer to unprocessed forms such as liquids, pastes, blocks, powders, granules, etc., including aqueous dispersions. This chapter is an important chapter for the classification of chemical products, involving a wide range of industrial raw materials. Heading 3905 covers polyvinyl acetate and other polyvinyl acetate copolymers in primary forms, including aqueous dispersions. Specifically, it includes polyvinyl acetate homopolymers, vinyl acetate copolymers (such as copolymers with ethylene, vinyl chloride, etc.), and their dispersion forms. Under this heading, further subdivision is made according to form and composition, and aqueous dispersion is one of the common forms. Code 390512 has 6 digits. The first 2 digits '39' represent Chapter 39, plastics and articles thereof. The 3rd-4th digits '05' represent heading 3905, namely polyvinyl acetate and other polyvinyl acetate copolymers in primary forms. The 5th-6th digits '12' represent subheading 390512, specifically aqueous dispersions of polyvinyl acetate. This subheading includes only the aqueous dispersion form, not other primary forms such as solid resins or organic solvent dispersions. This commodity is an aqueous dispersion of polyvinyl acetate in primary form, which conforms to the description of heading 3905, and its form is an aqueous dispersion, so it is classified under subheading 390512. If it were solid polyvinyl acetate, it would be classified under 390519; if it were other copolymers, it might be classified under other subheadings of 3905. Aqueous dispersion specifically refers to a dispersion system using water as the medium, distinct from organic solvent dispersions.
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, plastic materials, etc. This chapter is divided into multiple headings by polymer type, such as polyethylene, polypropylene, polystyrene, etc. Primary forms refer to unprocessed forms such as liquids, pastes, blocks, powders, granules, etc., including aqueous dispersions. This chapter is an important chapter for the classification of chemical products, involving a wide range of industrial raw materials.
Heading
Heading 3905 covers polyvinyl acetate and other polyvinyl acetate copolymers in primary forms, including aqueous dispersions. Specifically, it includes polyvinyl acetate homopolymers, vinyl acetate copolymers (such as copolymers with ethylene, vinyl chloride, etc.), and their dispersion forms. Under this heading, further subdivision is made according to form and composition, and aqueous dispersion is one of the common forms.
Digit Breakdown
Code 390512 has 6 digits. The first 2 digits '39' represent Chapter 39, plastics and articles thereof. The 3rd-4th digits '05' represent heading 3905, namely polyvinyl acetate and other polyvinyl acetate copolymers in primary forms. The 5th-6th digits '12' represent subheading 390512, specifically aqueous dispersions of polyvinyl acetate. This subheading includes only the aqueous dispersion form, not other primary forms such as solid resins or organic solvent dispersions.
Classification Basis
This commodity is an aqueous dispersion of polyvinyl acetate in primary form, which conforms to the description of heading 3905, and its form is an aqueous dispersion, so it is classified under subheading 390512. If it were solid polyvinyl acetate, it would be classified under 390519; if it were other copolymers, it might be classified under other subheadings of 3905. Aqueous dispersion specifically refers to a dispersion system using water as the medium, distinct from organic solvent dispersions.
📝 Declaration Elements
Product name: The specific name of the declared commodity should include an accurate description such as 'polyvinyl acetate aqueous dispersion' or 'PVAc emulsion', and avoid using colloquial names. Composition and content: Indicate the percentage content of polyvinyl acetate, as well as the content of auxiliary components such as water, emulsifiers, and plasticizers. Appearance: Describe the appearance and form of the product, such as milky white liquid, viscous emulsion, etc., to confirm that it is an aqueous dispersion. Use: Explain the main use, such as adhesives, coatings, paper treatment, etc., which helps with classification. Brand: Declare the brand name (if any); if there is no brand, fill in 'none'. Model: Declare the product model or specifications, such as viscosity, solid content, and other parameters. Packaging specifications: Explain the packaging form and net weight, such as drums, IBC totes, etc. CAS number: The CAS number of polyvinyl acetate is 9003-20-7, and it should be declared accurately. Product name: Polyvinyl acetate aqueous dispersion (PVAc emulsion); Composition and content: Polyvinyl acetate 45%, water 50%, polyvinyl alcohol 3%, others 2%; Appearance: milky white viscous liquid; Use: used for wood bonding; Brand: XX brand; Model: XX-100; Packaging specifications: 200kg/drum; CAS number: 9003-20-7. Misreporting an aqueous dispersion as a solid resin, resulting in incorrect classification. Incomplete declaration of composition and content, failing to distinguish aqueous dispersions from organic solvent dispersions. The use description is too general and does not reflect the specific application field.
Product name
The specific name of the declared commodity should include an accurate description such as 'polyvinyl acetate aqueous dispersion' or 'PVAc emulsion', and avoid using colloquial names.
⚠️ Only writing 'glue' or 'white latex', without reflecting the chemical composition and form.
Composition and content
Indicate the percentage content of polyvinyl acetate, as well as the content of auxiliary components such as water, emulsifiers, and plasticizers.
⚠️ Only writing 'polyvinyl acetate', without stating that it is an aqueous dispersion, or failing to list other components.
Appearance
Describe the appearance and form of the product, such as milky white liquid, viscous emulsion, etc., to confirm that it is an aqueous dispersion.
⚠️ Describing it as 'solid' or 'powder', which does not match the actual form.
Use
Explain the main use, such as adhesives, coatings, paper treatment, etc., which helps with classification.
⚠️ The use description is too broad, such as 'industrial use', without being specific.
Brand
Declare the brand name (if any); if there is no brand, fill in 'none'.
⚠️ Omitting the brand or filling it in incorrectly.
Model
Declare the product model or specifications, such as viscosity, solid content, and other parameters.
⚠️ Failure to provide the model, resulting in inability to distinguish the specific product.
Packaging specifications
Explain the packaging form and net weight, such as drums, IBC totes, etc.
⚠️ Only writing 'drums', without indicating the net weight.
CAS number
The CAS number of polyvinyl acetate is 9003-20-7, and it should be declared accurately.
⚠️ Incorrect or missing CAS number.
Example： Product name: Polyvinyl acetate aqueous dispersion (PVAc emulsion); Composition and content: Polyvinyl acetate 45%, water 50%, polyvinyl alcohol 3%, others 2%; Appearance: milky white viscous liquid; Use: used for wood bonding; Brand: XX brand; Model: XX-100; Packaging specifications: 200kg/drum; CAS number: 9003-20-7.
Common Mistakes：
Misreporting an aqueous dispersion as a solid resin, resulting in incorrect classification.
Incomplete declaration of composition and content, failing to distinguish aqueous dispersions from organic solvent dispersions.
The use description is too general and does not reflect the specific application field.
🎯 Classification Logic
The core basis for classification is that the commodity is an aqueous dispersion of polyvinyl acetate in primary form. According to HS rules, primary forms include liquids, pastes, powders, etc., and aqueous dispersion belongs to the liquid form. Heading 3905 explicitly covers polyvinyl acetate and its copolymers in primary forms, and subheading 390512 specifically refers to aqueous dispersions. Therefore, as long as the product is an aqueous dispersion of polyvinyl acetate, regardless of solid content, it should be classified under 390512. 390519 Other polyvinyl acetate in primary forms: 390519 covers other primary forms besides aqueous dispersions, such as solid resins, granules, powders, etc. If the product is a solid or organic solvent dispersion, it is classified under this code. 390521 Aqueous dispersions of vinyl acetate copolymers: 390521 covers aqueous dispersions of vinyl acetate copolymers, such as VAE emulsion (vinyl acetate-ethylene copolymer). If the polymer is a homopolymer, it is classified under 390512. 390690 Other acrylic polymers in primary forms: 390690 covers acrylic polymers, such as polyacrylates. If the product is an acrylate type, it is classified under this code, not 390512. 350691 Adhesives based on polyvinyl acetate: 350691 covers finished adhesives, usually in retail packaging and with a net weight not exceeding 1 kg. If the product is in primary form and not made into an adhesive, it is classified under 390512. Confirm that the product is in primary form, not a finished or semi-finished product. Confirm that the polymer is a polyvinyl acetate homopolymer. Confirm that the form is an aqueous dispersion, not an organic solvent dispersion. Confirm that it is not copolymerized with other monomers (such as ethylene, vinyl chloride). Confirm that it is not made into an adhesive in retail packaging.
Basis
The core basis for classification is that the commodity is an aqueous dispersion of polyvinyl acetate in primary form. According to HS rules, primary forms include liquids, pastes, powders, etc., and aqueous dispersion belongs to the liquid form. Heading 3905 explicitly covers polyvinyl acetate and its copolymers in primary forms, and subheading 390512 specifically refers to aqueous dispersions. Therefore, as long as the product is an aqueous dispersion of polyvinyl acetate, regardless of solid content, it should be classified under 390512.
Confused Codes：
390519 - Other polyvinyl acetate in primary forms
390519 covers other primary forms besides aqueous dispersions, such as solid resins, granules, powders, etc. If the product is a solid or organic solvent dispersion, it is classified under this code.
390521 - Aqueous dispersions of vinyl acetate copolymers
390521 covers aqueous dispersions of vinyl acetate copolymers, such as VAE emulsion (vinyl acetate-ethylene copolymer). If the polymer is a homopolymer, it is classified under 390512.
390690 - Other acrylic polymers in primary forms
390690 covers acrylic polymers, such as polyacrylates. If the product is an acrylate type, it is classified under this code, not 390512.
350691 - Adhesives based on polyvinyl acetate
350691 covers finished adhesives, usually in retail packaging and with a net weight not exceeding 1 kg. If the product is in primary form and not made into an adhesive, it is classified under 390512.
Self-Check：
✓ Confirm that the product is in primary form, not a finished or semi-finished product.
✓ Confirm that the polymer is a polyvinyl acetate homopolymer.
✓ Confirm that the form is an aqueous dispersion, not an organic solvent dispersion.
✓ Confirm that it is not copolymerized with other monomers (such as ethylene, vinyl chloride).
✓ Confirm that it is not made into an adhesive in retail packaging.
❓ FAQ
How can it be determined whether a polyvinyl acetate aqueous dispersion should be classified under 390512 or 390519? The key is the form: if it is an aqueous dispersion (emulsion), it is classified under 390512; if it is a solid, powder, granule, or organic solvent dispersion, it is classified under 390519. Aqueous dispersion specifically refers to a dispersion system using water as the medium, usually appearing as a milky white liquid. Under which code should VAE emulsion (vinyl acetate-ethylene copolymer) be classified? VAE emulsion is an aqueous dispersion of a copolymer of vinyl acetate and ethylene, and should be classified under 390521, not 390512. 390512 applies only to aqueous dispersions of polyvinyl acetate homopolymers. Is white latex (woodworking glue) classified under 390512? If white latex is a polyvinyl acetate aqueous dispersion in primary form and has not been made into an adhesive in retail packaging, it is classified under 390512. If it has been made into retail packaging (such as 1 kg or less), it may be classified under 350691. How should the composition and content be filled in during declaration? The content of polyvinyl acetate, water content, emulsifier (such as polyvinyl alcohol) content, and other additive content should be listed in detail. For example: polyvinyl acetate 45%, water 50%, polyvinyl alcohol 3%, others 2%. What is the CAS number of polyvinyl acetate aqueous dispersion? The CAS number of polyvinyl acetate is 9003-20-7. If it is a copolymer, the CAS number may be different and must be determined according to the specific composition. An accurate CAS number should be provided at the time of declaration. What regulatory conditions are required for importing polyvinyl acetate aqueous dispersion? Usually, a composition test report, MSDS, etc. are required. Specific regulatory conditions vary by country, and it is recommended to check with the customs administration or consult a professional customs broker. Tax rates may change and need to be checked in real time. How can 390512 and 350691 be distinguished? 390512 is polyvinyl acetate aqueous dispersion in primary form, belonging to chemical raw materials; 350691 is an adhesive based on polyvinyl acetate, belonging to a finished product, usually in retail packaging. If the product has not been made into an adhesive, it is classified under 390512. What is the difference between an aqueous dispersion and an emulsion? In HS classification, aqueous dispersion and emulsion are generally regarded as the same concept, both referring to a polymer dispersion system using water as the medium. However, it should be noted that some emulsions may contain organic solvents; if the organic solvent is the main medium, they may be classified under other codes.
Q: How can it be determined whether a polyvinyl acetate aqueous dispersion should be classified under 390512 or 390519?
A: The key is the form: if it is an aqueous dispersion (emulsion), it is classified under 390512; if it is a solid, powder, granule, or organic solvent dispersion, it is classified under 390519. Aqueous dispersion specifically refers to a dispersion system using water as the medium, usually appearing as a milky white liquid.
Q: Under which code should VAE emulsion (vinyl acetate-ethylene copolymer) be classified?
A: VAE emulsion is an aqueous dispersion of a copolymer of vinyl acetate and ethylene, and should be classified under 390521, not 390512. 390512 applies only to aqueous dispersions of polyvinyl acetate homopolymers.
Q: Is white latex (woodworking glue) classified under 390512?
A: If white latex is a polyvinyl acetate aqueous dispersion in primary form and has not been made into an adhesive in retail packaging, it is classified under 390512. If it has been made into retail packaging (such as 1 kg or less), it may be classified under 350691.
Q: How should the composition and content be filled in during declaration?
A: The content of polyvinyl acetate, water content, emulsifier (such as polyvinyl alcohol) content, and other additive content should be listed in detail. For example: polyvinyl acetate 45%, water 50%, polyvinyl alcohol 3%, others 2%.
Q: What is the CAS number of polyvinyl acetate aqueous dispersion?
A: The CAS number of polyvinyl acetate is 9003-20-7. If it is a copolymer, the CAS number may be different and must be determined according to the specific composition. An accurate CAS number should be provided at the time of declaration.
Q: What regulatory conditions are required for importing polyvinyl acetate aqueous dispersion?
A: Usually, a composition test report, MSDS, etc. are required. Specific regulatory conditions vary by country, and it is recommended to check with the customs administration or consult a professional customs broker. Tax rates may change and need to be checked in real time.
Q: How can 390512 and 350691 be distinguished?
A: 390512 is polyvinyl acetate aqueous dispersion in primary form, belonging to chemical raw materials; 350691 is an adhesive based on polyvinyl acetate, belonging to a finished product, usually in retail packaging. If the product has not been made into an adhesive, it is classified under 390512.
Q: What is the difference between an aqueous dispersion and an emulsion?
A: In HS classification, aqueous dispersion and emulsion are generally regarded as the same concept, both referring to a polymer dispersion system using water as the medium. However, it should be noted that some emulsions may contain organic solvents; if the organic solvent is the main medium, they may be classified under other codes.
⚠️ 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.