Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, chemically modified natural polymers, etc. This chapter is divided into two subchapters: Subchapter I (3901-3914) covers plastics in primary forms, and Subchapter II (3915-3926) covers waste, parings and scrap, and articles. Primary forms refer to liquid, paste, block, powder, granular and other unshaped states, which are the most basic forms in plastics trade. Classification under this chapter requires attention to polymer type, specific gravity, composition and other factors. Heading 3905 covers vinyl acetate or other vinyl ester polymers in primary forms, and other vinyl polymers in primary forms. Specifically, it includes poly(vinyl acetate) (3905.12, 3905.19), vinyl acetate copolymers (3905.21, 3905.29), poly(vinyl alcohol) (3905.30), etc. Among these, 3905.19 covers other poly(vinyl acetate) in primary forms, referring to all forms other than aqueous dispersions, such as granules, powder, blocks, etc. The first 2 digits "39" represent Chapter 39: Plastics and articles thereof. The 3rd-4th digits "05" represent heading 3905: Vinyl acetate or other vinyl ester polymers in primary forms; other vinyl polymers in primary forms. The 5th-6th digits "19" represent subheading 3905.19: Other poly(vinyl acetate) in primary forms. Among these, "1" indicates a subdivision under the poly(vinyl acetate) subheading, and "9" indicates forms other than aqueous dispersions (3905.12). Therefore, the complete meaning of 390519 is: poly(vinyl acetate) homopolymer in primary forms, not in the form of aqueous dispersions. This commodity is a poly(vinyl acetate) homopolymer in primary form (not an aqueous dispersion), so it is classified under 3905.19. If it were an aqueous dispersion, it would be classified under 3905.12; if it were a vinyl acetate copolymer, it would be classified under 3905.21 or 3905.29; if it were poly(vinyl alcohol), it would be classified under 3905.30. In addition, if it were waste and scrap, it would be classified under 3915; if it had been made into articles, it would be classified under 3920, etc.
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, chemically modified natural polymers, etc. This chapter is divided into two subchapters: Subchapter I (3901-3914) covers plastics in primary forms, and Subchapter II (3915-3926) covers waste, parings and scrap, and articles. Primary forms refer to liquid, paste, block, powder, granular and other unshaped states, which are the most basic forms in plastics trade. Classification under this chapter requires attention to polymer type, specific gravity, composition and other factors.
Heading
Heading 3905 covers vinyl acetate or other vinyl ester polymers in primary forms, and other vinyl polymers in primary forms. Specifically, it includes poly(vinyl acetate) (3905.12, 3905.19), vinyl acetate copolymers (3905.21, 3905.29), poly(vinyl alcohol) (3905.30), etc. Among these, 3905.19 covers other poly(vinyl acetate) in primary forms, referring to all forms other than aqueous dispersions, such as granules, powder, blocks, etc.
Digit Breakdown
The first 2 digits "39" represent Chapter 39: Plastics and articles thereof. The 3rd-4th digits "05" represent heading 3905: Vinyl acetate or other vinyl ester polymers in primary forms; other vinyl polymers in primary forms. The 5th-6th digits "19" represent subheading 3905.19: Other poly(vinyl acetate) in primary forms. Among these, "1" indicates a subdivision under the poly(vinyl acetate) subheading, and "9" indicates forms other than aqueous dispersions (3905.12). Therefore, the complete meaning of 390519 is: poly(vinyl acetate) homopolymer in primary forms, not in the form of aqueous dispersions.
Classification Basis
This commodity is a poly(vinyl acetate) homopolymer in primary form (not an aqueous dispersion), so it is classified under 3905.19. If it were an aqueous dispersion, it would be classified under 3905.12; if it were a vinyl acetate copolymer, it would be classified under 3905.21 or 3905.29; if it were poly(vinyl alcohol), it would be classified under 3905.30. In addition, if it were waste and scrap, it would be classified under 3915; if it had been made into articles, it would be classified under 3920, etc.
📝 Declaration Elements
Product Name: The specific name of the declared commodity, such as "poly(vinyl acetate) granules" or "poly(vinyl acetate) powder." Appearance: Describe the physical form of the commodity, such as granules, powder, blocks, liquid, etc. Composition Content: Indicate the percentage content of poly(vinyl acetate) and whether other additives are present. Brand: Fill in the manufacturer or brand name; if no brand, write "None." Model: Fill in the product model or grade, such as "Vinnapas 50," etc. Use: Explain the final use of the commodity, such as adhesives, coatings, textile auxiliaries, etc. CAS Number: The CAS number for poly(vinyl acetate) is 9003-20-7 and should be accurately filled in. Product Name: Poly(vinyl acetate) granules; Appearance: White granules; Composition Content: Poly(vinyl acetate) ≥99%, moisture ≤0.5%; Brand: Vinnapas; Model: 50; Use: For producing adhesives; CAS Number: 9003-20-7. Mistakenly classifying poly(vinyl acetate) in aqueous dispersion form under 3905.19, when it should actually be classified under 3905.12. Failing to distinguish homopolymers from copolymers, resulting in subheading errors. Classifying poly(vinyl acetate) already made into sheets, films and other articles under 3905, when it should actually be classified under 3920.
Product Name
The specific name of the declared commodity, such as "poly(vinyl acetate) granules" or "poly(vinyl acetate) powder."
⚠️ Writing only "PVAc" or "glue powder" without specifying primary form.
Appearance
Describe the physical form of the commodity, such as granules, powder, blocks, liquid, etc.
⚠️ Mistakenly declaring an aqueous dispersion as granules, resulting in classification errors.
Composition Content
Indicate the percentage content of poly(vinyl acetate) and whether other additives are present.
⚠️ Failing to state whether solvents or water are present, affecting subheading determination.
Brand
Fill in the manufacturer or brand name; if no brand, write "None."
⚠️ Confusing brand with manufacturer, or omitting it.
Model
Fill in the product model or grade, such as "Vinnapas 50," etc.
⚠️ Incomplete model entry, making it impossible to match.
Use
Explain the final use of the commodity, such as adhesives, coatings, textile auxiliaries, etc.
⚠️ Use description is too broad, such as "industrial use."
CAS Number
The CAS number for poly(vinyl acetate) is 9003-20-7 and should be accurately filled in.
⚠️ Incorrect CAS number or confusion with copolymers.
Example： Product Name: Poly(vinyl acetate) granules; Appearance: White granules; Composition Content: Poly(vinyl acetate) ≥99%, moisture ≤0.5%; Brand: Vinnapas; Model: 50; Use: For producing adhesives; CAS Number: 9003-20-7.
Common Mistakes：
Mistakenly classifying poly(vinyl acetate) in aqueous dispersion form under 3905.19, when it should actually be classified under 3905.12.
Failing to distinguish homopolymers from copolymers, resulting in subheading errors.
Classifying poly(vinyl acetate) already made into sheets, films and other articles under 3905, when it should actually be classified under 3920.
🎯 Classification Logic
Core classification basis: 1) The commodity is in primary form, conforming to Chapter 39 notes; 2) The chemical structure is a vinyl acetate homopolymer, conforming to heading 3905; 3) It is not in aqueous dispersion form, so it is classified under 3905.19. A comprehensive judgment must be made based on composition, appearance, use, etc. 390512 Poly(vinyl acetate) aqueous dispersion in primary forms: 3905.12 is an aqueous dispersion, while 3905.19 is a non-aqueous dispersion. The core difference lies in whether water is used as the medium to form a dispersion. 390521 Vinyl acetate copolymer aqueous dispersion in primary forms: 3905.21 is an aqueous dispersion of vinyl acetate copolymer, while 3905.19 is a homopolymer and non-aqueous dispersion. 390529 Other vinyl acetate copolymers in primary forms: 3905.29 is vinyl acetate copolymer (non-aqueous dispersion), while 3905.19 is a homopolymer. 390530 Poly(vinyl alcohol) in primary forms: 3905.30 is poly(vinyl alcohol), which is the hydrolysis product of poly(vinyl acetate) and has a different chemical structure. 391510 Polyethylene waste and scrap: 3915 is waste and scrap, while 3905.19 is raw material in primary forms, not waste and scrap. Is it confirmed that the commodity is in primary form? Is it confirmed that the commodity is a poly(vinyl acetate) homopolymer? Is it confirmed that the commodity is not an aqueous dispersion? Has the CAS number 9003-20-7 been verified? Has it been checked whether it has already been made into articles?
Basis
Core classification basis: 1) The commodity is in primary form, conforming to Chapter 39 notes; 2) The chemical structure is a vinyl acetate homopolymer, conforming to heading 3905; 3) It is not in aqueous dispersion form, so it is classified under 3905.19. A comprehensive judgment must be made based on composition, appearance, use, etc.
Confused Codes：
390512 - Poly(vinyl acetate) aqueous dispersion in primary forms
3905.12 is an aqueous dispersion, while 3905.19 is a non-aqueous dispersion. The core difference lies in whether water is used as the medium to form a dispersion.
390521 - Vinyl acetate copolymer aqueous dispersion in primary forms
3905.21 is an aqueous dispersion of vinyl acetate copolymer, while 3905.19 is a homopolymer and non-aqueous dispersion.
390529 - Other vinyl acetate copolymers in primary forms
3905.29 is vinyl acetate copolymer (non-aqueous dispersion), while 3905.19 is a homopolymer.
390530 - Poly(vinyl alcohol) in primary forms
3905.30 is poly(vinyl alcohol), which is the hydrolysis product of poly(vinyl acetate) and has a different chemical structure.
391510 - Polyethylene waste and scrap
3915 is waste and scrap, while 3905.19 is raw material in primary forms, not waste and scrap.
Self-Check：
✓ Is it confirmed that the commodity is in primary form?
✓ Is it confirmed that the commodity is a poly(vinyl acetate) homopolymer?
✓ Is it confirmed that the commodity is not an aqueous dispersion?
✓ Has the CAS number 9003-20-7 been verified?
✓ Has it been checked whether it has already been made into articles?
❓ FAQ
How can one determine whether poly(vinyl acetate) is an aqueous dispersion? Aqueous dispersions are usually emulsion-like, contain water, and generally have a solid content of 40-60%, while commodities under 3905.19 are mostly granules, powder or blocks, contain no water or very low moisture. This can be determined by appearance and composition content. Is there any difference in classification between poly(vinyl acetate) granules and powder? No difference; both are classified under 3905.19, as long as they are in primary forms and are not aqueous dispersions. If poly(vinyl acetate) contains a small amount of additives, does it affect classification? If the additives are stabilizers, plasticizers, etc., and do not change its basic character, it is still classified under 3905.19. However, if it is blended with other polymers, it may be classified under other headings. In the declaration elements for 3905.19, how should composition content be filled in? The percentage of poly(vinyl acetate) should be filled in, along with the main additives and moisture content. For example: Poly(vinyl acetate) ≥99%, moisture ≤0.5%. Is poly(vinyl acetate) glue classified under 3905.19? If the glue is an aqueous dispersion, it should be classified under 3905.12; if it is solvent-based or solid, it is classified under 3905.19. However, if it has been made into glue in retail packaging, it may be classified under 3506. How can one inquire about the import tariff rate for 3905.19? The latest tariff rates can be inquired through the website of the General Administration of Customs or the Ministry of Commerce, and attention should be paid to preferential rates under different trade agreements. How can poly(vinyl acetate) and vinyl acetate copolymer be distinguished? Homopolymers are polymerized only from vinyl acetate monomer, while copolymers contain other monomers (such as ethylene, acrylates, etc.). They can be distinguished by infrared spectroscopy or chemical composition analysis. If poly(vinyl acetate) has already been made into film, which code should it be classified under? Poly(vinyl acetate) already made into film should be classified under 3920.99, not 3905.19, because it has exceeded the scope of primary forms.
Q: How can one determine whether poly(vinyl acetate) is an aqueous dispersion?
A: Aqueous dispersions are usually emulsion-like, contain water, and generally have a solid content of 40-60%, while commodities under 3905.19 are mostly granules, powder or blocks, contain no water or very low moisture. This can be determined by appearance and composition content.
Q: Is there any difference in classification between poly(vinyl acetate) granules and powder?
A: No difference; both are classified under 3905.19, as long as they are in primary forms and are not aqueous dispersions.
Q: If poly(vinyl acetate) contains a small amount of additives, does it affect classification?
A: If the additives are stabilizers, plasticizers, etc., and do not change its basic character, it is still classified under 3905.19. However, if it is blended with other polymers, it may be classified under other headings.
Q: In the declaration elements for 3905.19, how should composition content be filled in?
A: The percentage of poly(vinyl acetate) should be filled in, along with the main additives and moisture content. For example: Poly(vinyl acetate) ≥99%, moisture ≤0.5%.
Q: Is poly(vinyl acetate) glue classified under 3905.19?
A: If the glue is an aqueous dispersion, it should be classified under 3905.12; if it is solvent-based or solid, it is classified under 3905.19. However, if it has been made into glue in retail packaging, it may be classified under 3506.
Q: How can one inquire about the import tariff rate for 3905.19?
A: The latest tariff rates can be inquired through the website of the General Administration of Customs or the Ministry of Commerce, and attention should be paid to preferential rates under different trade agreements.
Q: How can poly(vinyl acetate) and vinyl acetate copolymer be distinguished?
A: Homopolymers are polymerized only from vinyl acetate monomer, while copolymers contain other monomers (such as ethylene, acrylates, etc.). They can be distinguished by infrared spectroscopy or chemical composition analysis.
Q: If poly(vinyl acetate) has already been made into film, which code should it be classified under?
A: Poly(vinyl acetate) already made into film should be classified under 3920.99, not 3905.19, because it has exceeded the scope of primary forms.
⚠️ 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.