Chapter 39 covers plastics and articles thereof, including polymers in primary forms, waste, parings and scrap, and semi-manufactures, as well as articles in specific forms such as plates, sheets, film, foil, and strip. This chapter is subdivided by polymer type and processing stage; primary forms refer to unprocessed forms such as liquid, paste, block, powder, etc. Heading 3905 includes vinyl acetate polymers and other vinyl ester polymers in primary forms, such as polyvinyl acetate, vinyl acetate copolymers, etc. Copolymers refer to those obtained by copolymerization of vinyl acetate with other monomers and must contain vinyl acetate units. The first 2 digits 39 indicate Chapter 39, plastics and articles thereof; digits 3-4, 05, indicate heading 3905, namely vinyl acetate polymers and other vinyl ester polymers in primary forms; digits 5-6, 29, are a subheading indicating other vinyl acetate copolymers in primary forms, i.e., copolymers other than polyvinyl acetate homopolymer (3905.12) and aqueous dispersions of vinyl acetate copolymers (3905.21), etc. The goods are copolymers of vinyl acetate and other monomers, in primary forms, not dissolved in an aqueous medium, and not homopolymers, so they are classified under 3905.29; if they were aqueous dispersions, they would be classified under 3905.21, and if they were homopolymers, under 3905.12.

Product name: The specific name of the declared goods, such as "vinyl acetate-ethylene copolymer." Appearance: Describe the primary form, such as powder, granules, blocks, etc. Composition content: Mass percentage of each monomer unit, such as vinyl acetate 30%, ethylene 70%. Types of monomer units: List all comonomers, such as vinyl acetate, ethylene, acrylate, etc. Whether soluble in water: State whether it is soluble in water or forms an aqueous dispersion. Use: Main use, such as adhesives, coatings, plastic modification, etc. Brand: Brand or manufacturer name of the goods. Model: Product model or specification. Product name: vinyl acetate-ethylene copolymer; Appearance: white granules; Composition content: vinyl acetate 28%, ethylene 72%; Types of monomer units: vinyl acetate, ethylene; Whether soluble in water: insoluble in water; Use: for hot melt adhesives; Brand: EVAX; Model: EV-100. Incorrectly declaring an aqueous dispersion as a solid, resulting in classification under 3905.21. Failure to distinguish homopolymers from copolymers, incorrectly classifying under 3905.12. Incomplete declaration of composition content, affecting classification.

Classification basis: 1. Primary form; 2. Vinyl acetate copolymer, not homopolymer; 3. Not an aqueous dispersion; 4. Meets the description of heading 3905. If it is an aqueous dispersion, classify under 3905.21; if it is a homopolymer, classify under 3905.12. 3905.12 Polyvinyl acetate homopolymer: Homopolymers contain only vinyl acetate monomer, whereas 3905.29 is for copolymers containing other monomers. 3905.21 Aqueous dispersion of vinyl acetate copolymer: Aqueous dispersions are liquid, while 3905.29 is for solid primary forms. 3901.30 Ethylene-vinyl acetate copolymer: 3901.30 refers to copolymers in which ethylene is the main monomer and vinyl acetate content is relatively low; 3905.29 refers to copolymers in which vinyl acetate is the main monomer. 3906.90 Other acrylic polymers: If the copolymer is mainly based on acrylate, it should be classified under 3906, not 3905. Is it in primary form? Does it contain vinyl acetate units? Is it a copolymer? Is it an aqueous dispersion? Is vinyl acetate the predominant monomer?

How to determine whether a vinyl acetate copolymer should be classified under 3905.29 or 3901.30? Based on which monomer unit has the largest weight proportion in the copolymer. If the vinyl acetate unit accounts for the largest proportion, classify under 3905.29; if the ethylene unit accounts for the largest proportion, classify under 3901.30. What is the difference between 3905.29 and 3905.21? 3905.21 applies only to aqueous dispersions of vinyl acetate copolymers, while 3905.29 applies to other primary forms, such as solids, powders, granules, etc. How should the composition content be filled in during declaration? List the mass percentage of all monomer units, such as vinyl acetate 30%, ethylene 70%, and ensure the total is 100%. If the copolymer contains a third monomer, does it affect classification? No, as long as vinyl acetate is the main monomer and it is in primary form, it is still classified under 3905.29; however, all monomer types and contents must be declared. How to check the tax rate for 3905.29? You can consult the Customs Import and Export Tariff of China or use the customs classification inquiry system; tax rates may vary depending on trade agreements and country of origin. What are the considerations for cross-border e-commerce retail export of this product? Accurately declare the product name, composition, and use to avoid customs clearance delays caused by classification errors; also pay attention to export tax rebates and regulatory conditions. Does this code involve anti-dumping? Check announcements from the General Administration of Customs; some vinyl acetate copolymers may be subject to anti-dumping measures. It is recommended to verify the latest policies before customs declaration. If the product is a vinyl acetate copolymer emulsion but not an aqueous dispersion, how should it be classified? If the emulsion is an aqueous dispersion, classify under 3905.21; if it is a solvent-based dispersion, it is still classified under 3905.29.