Chapter 39 covers plastics and articles thereof, including polymers in primary forms, waste and scrap, semi-manufactures and finished products. This chapter is subdivided by polymer origin and chemical structure. Alkyd resins, as a type of synthetic polymer, fall within the scope of plastics in primary forms. The chapter notes provide strict definitions of terms such as primary forms and polymers, and classification must first satisfy the requirements of the chapter notes. Heading 3907 covers polyacetals, other polyethers and epoxide resins, polycarbonates, alkyd resins, polyallyl esters and other polyesters, in primary forms. This heading is divided by chemical structure. Alkyd resins, as a specific polyester, are explicitly listed under subheading 3907.50. The first 2 digits 39 represent Chapter 39, plastics and articles thereof; digits 3-4, 07, represent heading 3907, namely polyacetals, other polyethers and epoxide resins, polycarbonates, alkyd resins, polyallyl esters and other polyesters, in primary forms; digits 5-6, 50, represent subheading 3907.50, specifically alkyd resins in primary forms. The 5th digit 5 indicates the sequential number of alkyd resins under heading 3907, and the 6th digit 0 indicates that there is no further subdivision under this subheading. Alkyd resins are polyesters formed by the polycondensation of polyols, polyacids and fatty acids, and are synthetic polymers. Because their chemical structure is polyester and they are in primary forms, they are classified under 3907.50, rather than 3907.60 (polyethylene terephthalate) or 3907.99 (other polyesters). At the same time, if they are waste and scrap or semi-manufactures, they may be classified under other headings.
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, waste and scrap, semi-manufactures and finished products. This chapter is subdivided by polymer origin and chemical structure. Alkyd resins, as a type of synthetic polymer, fall within the scope of plastics in primary forms. The chapter notes provide strict definitions of terms such as primary forms and polymers, and classification must first satisfy the requirements of the chapter notes.
Heading
Heading 3907 covers polyacetals, other polyethers and epoxide resins, polycarbonates, alkyd resins, polyallyl esters and other polyesters, in primary forms. This heading is divided by chemical structure. Alkyd resins, as a specific polyester, are explicitly listed under subheading 3907.50.
Digit Breakdown
The first 2 digits 39 represent Chapter 39, plastics and articles thereof; digits 3-4, 07, represent heading 3907, namely polyacetals, other polyethers and epoxide resins, polycarbonates, alkyd resins, polyallyl esters and other polyesters, in primary forms; digits 5-6, 50, represent subheading 3907.50, specifically alkyd resins in primary forms. The 5th digit 5 indicates the sequential number of alkyd resins under heading 3907, and the 6th digit 0 indicates that there is no further subdivision under this subheading.
Classification Basis
Alkyd resins are polyesters formed by the polycondensation of polyols, polyacids and fatty acids, and are synthetic polymers. Because their chemical structure is polyester and they are in primary forms, they are classified under 3907.50, rather than 3907.60 (polyethylene terephthalate) or 3907.99 (other polyesters). At the same time, if they are waste and scrap or semi-manufactures, they may be classified under other headings.
📝 Declaration Elements
Product Name: The specific name of the declared commodity, which should state alkyd resin in primary forms and distinguish between water-based or solvent-based types, etc. Appearance: Describe the appearance and form of the product, such as liquid, paste, block, powder, etc., to prove that it is in primary forms. Composition and Content: List the main components and their percentages, such as alkyd resin content, solvents, additives, etc. Use: Explain the final use of the resin, such as for manufacturing coatings, inks, adhesives, etc. Brand: Declare the brand or manufacturer name; if there is no brand, state "no brand". Model: Declare the model or grade of the product to distinguish different specifications. Packaging Specification: State the packaging form and net weight, such as iron drum, net weight 200 kg/drum. Whether Modified: State whether the alkyd resin has been chemically modified, such as acrylic modification, silicone modification, etc. Product Name: Alkyd resin; Appearance: Light yellow viscous liquid; Composition and Content: Alkyd resin 70%, xylene 30%; Use: For manufacturing industrial coatings; Brand: ABC; Model: ALK-100; Packaging Specification: Iron drum, net weight 200 kg/drum; Whether Modified: Unmodified. Misdeclaring alkyd resin coating as resin in primary forms, resulting in classification error. Failing to list the solvent ratio in the composition and content, which may lead to misclassification under 3907.99. The appearance is described as "finished product" or "coating", which cannot prove that it is in primary forms. Failing to distinguish between water-based or solvent-based, affecting the determination of the subheading.
Product Name
The specific name of the declared commodity, which should state alkyd resin in primary forms and distinguish between water-based or solvent-based types, etc.
⚠️ Declaring only as "resin" or "alkyd resin" without stating primary forms.
Appearance
Describe the appearance and form of the product, such as liquid, paste, block, powder, etc., to prove that it is in primary forms.
⚠️ Declaring a finished coating as primary forms, with the appearance described as "coating" rather than "resin".
Composition and Content
List the main components and their percentages, such as alkyd resin content, solvents, additives, etc.
⚠️ Failing to list solvent content, which may lead to misclassification as solvent-based coating.
Use
Explain the final use of the resin, such as for manufacturing coatings, inks, adhesives, etc.
⚠️ The use description is too broad, such as "for industrial use", without specific explanation.
Brand
Declare the brand or manufacturer name; if there is no brand, state "no brand".
⚠️ Confusing brand with manufacturer, or omitting the brand.
Model
Declare the model or grade of the product to distinguish different specifications.
⚠️ The model is incomplete or inconsistent with the actual product.
Packaging Specification
State the packaging form and net weight, such as iron drum, net weight 200 kg/drum.
⚠️ The packaging specification is inconsistent with the declared unit, such as declaring by "drum" but not stating the net weight.
Whether Modified
State whether the alkyd resin has been chemically modified, such as acrylic modification, silicone modification, etc.
⚠️ Failing to state the modification status, which may affect classification.
Example： Product Name: Alkyd resin; Appearance: Light yellow viscous liquid; Composition and Content: Alkyd resin 70%, xylene 30%; Use: For manufacturing industrial coatings; Brand: ABC; Model: ALK-100; Packaging Specification: Iron drum, net weight 200 kg/drum; Whether Modified: Unmodified.
Common Mistakes：
Misdeclaring alkyd resin coating as resin in primary forms, resulting in classification error.
Failing to list the solvent ratio in the composition and content, which may lead to misclassification under 3907.99.
The appearance is described as "finished product" or "coating", which cannot prove that it is in primary forms.
Failing to distinguish between water-based or solvent-based, affecting the determination of the subheading.
🎯 Classification Logic
The core basis for classification is: 1) the goods are in primary forms, meeting the definition of "primary forms" in Chapter 39 Note 6; 2) the chemical structure is alkyd resin, i.e., a polyester formed by the polycondensation of polyols, polyacids and fatty acids; 3) it is not mixed with other substances or is only mixed with additives such as stabilizers. If it has been made into coatings or adhesives, it is classified under Chapter 32 or Chapter 35. 3907.60 Polyethylene terephthalate: 3907.60 is the specific polyester PET, while 3907.50 is alkyd resin. Their chemical structures are different. PET is formed by the polycondensation of terephthalic acid and ethylene glycol, while alkyd resin contains fatty acids. 3907.99 Other polyesters: 3907.99 is for other polyesters not elsewhere specified. Alkyd resins are explicitly listed under 3907.50, so they should not be classified under 3907.99. 3208.10 Polyester paints and varnishes: 3208.10 is polyester coatings dissolved in non-aqueous media, already made into paint, while 3907.50 is resin in primary forms, not made into paint. 3909.50 Polyurethanes: 3909.50 is polyurethane, with a different chemical structure. Alkyd resin is a polyester, while polyurethane contains urethane bonds. Is it in primary forms? Is the chemical composition alkyd resin? Is it mixed with other substances? Has it been made into coating or adhesive? Has it been chemically modified?
Basis
The core basis for classification is: 1) the goods are in primary forms, meeting the definition of "primary forms" in Chapter 39 Note 6; 2) the chemical structure is alkyd resin, i.e., a polyester formed by the polycondensation of polyols, polyacids and fatty acids; 3) it is not mixed with other substances or is only mixed with additives such as stabilizers. If it has been made into coatings or adhesives, it is classified under Chapter 32 or Chapter 35.
Confused Codes：
3907.60 - Polyethylene terephthalate
3907.60 is the specific polyester PET, while 3907.50 is alkyd resin. Their chemical structures are different. PET is formed by the polycondensation of terephthalic acid and ethylene glycol, while alkyd resin contains fatty acids.
3907.99 - Other polyesters
3907.99 is for other polyesters not elsewhere specified. Alkyd resins are explicitly listed under 3907.50, so they should not be classified under 3907.99.
3208.10 - Polyester paints and varnishes
3208.10 is polyester coatings dissolved in non-aqueous media, already made into paint, while 3907.50 is resin in primary forms, not made into paint.
3909.50 - Polyurethanes
3909.50 is polyurethane, with a different chemical structure. Alkyd resin is a polyester, while polyurethane contains urethane bonds.
Self-Check：
✓ Is it in primary forms?
✓ Is the chemical composition alkyd resin?
✓ Is it mixed with other substances?
✓ Has it been made into coating or adhesive?
✓ Has it been chemically modified?
❓ FAQ
What is the difference in HS codes between alkyd resin and alkyd coating? Alkyd resin is in primary forms and is classified under 3907.50; alkyd coating is a finished paint and is classified under 3208.10. The difference lies in whether solvents, pigments, etc. have been added to make a coating. If it contains only resin and a small amount of stabilizer, it is still classified as resin. How to determine whether alkyd resin is in primary forms? According to Chapter 39 Note 6, primary forms include liquid, paste, block, powder, etc., but they must not have been further processed. If it has been made into film, sheet, etc., it is not in primary forms. Which code should modified alkyd resin be classified under? If it remains alkyd resin after modification, it is usually still classified under 3907.50. However, if it becomes another polymer after modification, such as acrylic-modified alkyd resin, it may be classified under 3906.90 or other subheadings, depending on the specific composition. How should aqueous dispersions of alkyd resin be classified? If the aqueous dispersion is in primary forms, it is still classified under 3907.50. However, if it has been made into water-based coating, it is classified under 3208.10. The key is whether pigments, etc. have been added to make a coating. When declaring alkyd resin, how should the composition and content be filled in? The content of alkyd resin, the type and content of solvents, additives, etc. should be listed. If the solvent content is relatively high, it may affect classification, and it is recommended to declare truthfully. Which code should alkyd resin waste be classified under? Waste is usually classified under 3915, but if it is waste in primary forms, it may be classified under 3907.50. It needs to be determined based on the form and source of the waste. How to inquire about the import tax rate for alkyd resin? Tax rates change. It is recommended to check the latest tax rate through the official website of the General Administration of Customs or the International Trade Single Window, and apply the agreement rate based on the country of origin. How to distinguish alkyd resin from polyester resin in classification? Alkyd resin is a type of polyester but contains fatty acids. If it is another polyester, such as PET, it is classified under 3907.60; other polyesters not elsewhere specified are classified under 3907.99. Alkyd resin is specifically listed under 3907.50.
Q: What is the difference in HS codes between alkyd resin and alkyd coating?
A: Alkyd resin is in primary forms and is classified under 3907.50; alkyd coating is a finished paint and is classified under 3208.10. The difference lies in whether solvents, pigments, etc. have been added to make a coating. If it contains only resin and a small amount of stabilizer, it is still classified as resin.
Q: How to determine whether alkyd resin is in primary forms?
A: According to Chapter 39 Note 6, primary forms include liquid, paste, block, powder, etc., but they must not have been further processed. If it has been made into film, sheet, etc., it is not in primary forms.
Q: Which code should modified alkyd resin be classified under?
A: If it remains alkyd resin after modification, it is usually still classified under 3907.50. However, if it becomes another polymer after modification, such as acrylic-modified alkyd resin, it may be classified under 3906.90 or other subheadings, depending on the specific composition.
Q: How should aqueous dispersions of alkyd resin be classified?
A: If the aqueous dispersion is in primary forms, it is still classified under 3907.50. However, if it has been made into water-based coating, it is classified under 3208.10. The key is whether pigments, etc. have been added to make a coating.
Q: When declaring alkyd resin, how should the composition and content be filled in?
A: The content of alkyd resin, the type and content of solvents, additives, etc. should be listed. If the solvent content is relatively high, it may affect classification, and it is recommended to declare truthfully.
Q: Which code should alkyd resin waste be classified under?
A: Waste is usually classified under 3915, but if it is waste in primary forms, it may be classified under 3907.50. It needs to be determined based on the form and source of the waste.
Q: How to inquire about the import tax rate for alkyd resin?
A: Tax rates change. It is recommended to check the latest tax rate through the official website of the General Administration of Customs or the International Trade Single Window, and apply the agreement rate based on the country of origin.
Q: How to distinguish alkyd resin from polyester resin in classification?
A: Alkyd resin is a type of polyester but contains fatty acids. If it is another polyester, such as PET, it is classified under 3907.60; other polyesters not elsewhere specified are classified under 3907.99. Alkyd resin is specifically listed under 3907.50.
⚠️ 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.