Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic rubber, semi-finished and finished products. This chapter is divided into headings by polymer type, such as polyethylene, polypropylene, polyvinyl chloride, etc. Primary forms refer to liquid, paste, block, powder, granule and other forms, excluding articles already made into specific shapes. This chapter is a core chapter for chemical trade and tariff classification, involving a wide range of industrial raw materials. Heading 3905 covers vinyl ester polymers and other vinyl polymers in primary forms, including polyvinyl acetate, polyvinyl alcohol, polyvinyl acetal, etc. These polymers are usually formed by polymerization of vinyl acetate or other vinyl ester monomers, and are widely used in adhesives, coatings, textile sizing, pharmaceutical coatings and other fields. Under this heading, they are further subdivided according to polymer type and form. The first 2 digits 39 represent Chapter 39, plastics and articles thereof. Digits 3-4, 05, represent heading 3905, namely vinyl ester polymers and other vinyl polymers in primary forms. Digits 5-6, 91, represent subheading 390591, namely other vinyl ester polymers in primary forms, referring to vinyl ester polymers other than those specifically named such as polyvinyl acetate (3905.12, 3905.19) and polyvinyl alcohol (3905.30). This subheading covers a relatively broad scope, including vinyl ester copolymers, modified polymers, etc. This product is classified under 390591 because it is a vinyl ester polymer in primary form and does not belong to specifically named polyvinyl acetate or polyvinyl alcohol, etc. It differs from the adjacent code 3905.12 (polyvinyl acetate aqueous dispersion) in form or monomer composition; it differs from 3905.30 (polyvinyl alcohol) in degree of alcoholysis or chemical structure. If it is a copolymer and vinyl ester is the main monomer, it is also classified under this code.

Product name: The standard name of the declared commodity should use the normative name recognized by customs, such as "ethylene-vinyl acetate copolymer". Appearance: Describe the physical form of the primary shape, such as liquid, powder, granule, block, etc., and indicate the color. Composition and content: List the main monomers and content percentages, such as vinyl acetate content, other comonomers and their content. Types and proportions of monomer units: Clearly state the names of the various monomer units in the polymer and their molar ratio or weight ratio. Whether modified: State whether it has undergone chemical modification, such as hydrolysis, acetalization, etc., and the degree of modification. Use: Briefly describe the main application fields, such as adhesives, coatings, textile sizing, etc. Brand: The brand or manufacturer name of the declared commodity; if there is no brand, fill in "none". Model: The model or specification of the declared commodity, such as viscosity, molecular weight and other parameters. Product name: ethylene-vinyl acetate copolymer; Appearance: white granules; Composition and content: vinyl acetate 28%, ethylene 72%; Types and proportions of monomer units: vinyl acetate:ethylene=28:72; Whether modified: unmodified; Use: used for hot melt adhesive; Brand: none; Model: EVA-280. Mistakenly classifying polyvinyl acetate under 390591, when it should actually be classified under 390512 or 390519. Failure to distinguish primary forms from semi-finished products; for example, if already made into film, it is classified under other headings. False declaration of composition and content, leading to incorrect classification or tax evasion.

The core basis for classification is the chemical composition of the polymer, the types and proportions of monomer units, whether it is modified, and the physical form. According to the notes to Chapter 39 of the Import and Export Tariff, primary forms include liquid, paste, block, powder, granule, etc. 390591 applies only to other vinyl ester polymers, that is, vinyl ester homopolymers or copolymers other than those specifically named such as polyvinyl acetate and polyvinyl alcohol. If the vinyl ester monomer unit has the greatest weight in the copolymer, it is classified under this subheading. 390512 Polyvinyl acetate aqueous dispersion: 390512 is an aqueous dispersion of polyvinyl acetate, while 390591 is other forms or other vinyl ester polymers. If it is solid polyvinyl acetate, it should be classified under 390519. 390519 Other polyvinyl acetate: 390519 is polyvinyl acetate other than aqueous dispersion, while 390591 is other vinyl ester polymers, such as ethylene-vinyl acetate copolymer. 390530 Polyvinyl alcohol: Polyvinyl alcohol is the hydrolysis product of vinyl acetate. If fully hydrolyzed, it is classified under 390530; if partially hydrolyzed and unmodified, it may be classified under 390591. 390599 Other vinyl polymers: 390599 covers other vinyl polymers not elsewhere named, such as polyvinyl butyral, while 390591 is limited to vinyl ester polymers. Is it in primary form? Is it a vinyl ester polymer? Is it already specifically named? Are the proportions of monomer units clear? Has it undergone chemical modification?

How can it be determined whether an ethylene-vinyl acetate copolymer is classified under 390591? First confirm that it is in primary form, then confirm that the vinyl acetate monomer unit accounts for the greatest weight proportion and that it has not undergone modification such as hydrolysis. If so, it is classified under 390591. If the vinyl acetate content is lower than that of other monomers, it may be classified under other headings. What is the difference between 390591 and 390512 when declaring? 390512 applies only to aqueous dispersions of polyvinyl acetate, while 390591 applies to other vinyl ester polymers, such as solid polyvinyl acetate or copolymers. When declaring, the form and polymer type must be clearly specified. Is it possible for polyvinyl alcohol to be classified under 390591? Polyvinyl alcohol is usually classified under 390530, but if it is a partially hydrolyzed vinyl ester copolymer that is not fully alcoholized, it may be classified under 390591. Judgment should be based on the degree of hydrolysis and the proportions of monomer units. What should be noted when filling in composition and content during declaration? The names and content percentages of each monomer unit must be accurately filled in, especially the vinyl acetate content. Different contents may lead to changes in classification. It is recommended to provide test reports or MSDS as supporting documents. Are there regulatory conditions for goods under 390591? Regulatory conditions vary depending on the specific use and composition of the commodity, and may involve import and export licenses, hazardous chemicals registration, etc. It is recommended to consult the latest Customs Import and Export Tariff or consult the local customs. How can the tariff rate for 390591 be checked? It can be checked through the official website of the General Administration of Customs, China International Trade Single Window, or the Import and Export Tariff. The rate may vary depending on trade agreements, country of origin and other factors, and should be considered in light of the specific trade situation. If the commodity is a vinyl ester copolymer but contains other non-vinyl ester monomers, how should it be classified? According to the notes to Chapter 39, if the vinyl ester monomer unit has the greatest weight, it is classified under 390591; otherwise, it is classified under the corresponding heading according to the other monomers. Accurate monomer proportions must be provided. Is an MSDS required when exporting goods under 390591? If it is a hazardous chemical, an MSDS is required; if it is an ordinary chemical product, it is recommended to provide an MSDS for customs review. The specific requirements shall be subject to customs requirements.