Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, plastic materials, etc. This chapter classifies according to the chemical structure, source, and processing stage of polymers. Primary forms refer to unprocessed forms such as liquids, pastes, blocks, powders, granules, etc. Phenolic resins, as representatives of thermosetting resins, are important commodities under this chapter. Heading 3909 includes amino resins, phenolic resins, and polyurethanes in primary forms. Phenolic resins are synthetic resins formed by the polycondensation of phenols with aldehydes, possessing heat resistance, flame resistance, insulation, and other properties, and are widely used in adhesives, coatings, composite materials, and other fields. Under this heading, they are further subdivided according to the specific type of resin. The first 2 digits 39 represent Chapter 39, plastics and articles thereof; the 3rd-4th digits 09 represent heading 3909, namely amino resins, phenolic resins, and polyurethanes in primary forms; the 5th-6th digits 40 represent subheading 390940, specifically phenolic resins in primary forms. Under this subheading, they may be further subdivided according to form, use, etc., but 390940 is already clearly defined as the primary form of phenolic resins. This commodity is phenolic resin in primary form, which conforms to the description of heading 3909 and has not been further processed or mixed with other substances into articles, so it is classified under 390940. If it were phenolic resin articles (such as sheets, pipes), it should be classified under subsequent headings of Chapter 39 or Chapter 85, etc.; if it were other types of resins such as amino resins, it would be classified under 390910.
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, plastic materials, etc. This chapter classifies according to the chemical structure, source, and processing stage of polymers. Primary forms refer to unprocessed forms such as liquids, pastes, blocks, powders, granules, etc. Phenolic resins, as representatives of thermosetting resins, are important commodities under this chapter.
Heading
Heading 3909 includes amino resins, phenolic resins, and polyurethanes in primary forms. Phenolic resins are synthetic resins formed by the polycondensation of phenols with aldehydes, possessing heat resistance, flame resistance, insulation, and other properties, and are widely used in adhesives, coatings, composite materials, and other fields. Under this heading, they are further subdivided according to the specific type of resin.
Digit Breakdown
The first 2 digits 39 represent Chapter 39, plastics and articles thereof; the 3rd-4th digits 09 represent heading 3909, namely amino resins, phenolic resins, and polyurethanes in primary forms; the 5th-6th digits 40 represent subheading 390940, specifically phenolic resins in primary forms. Under this subheading, they may be further subdivided according to form, use, etc., but 390940 is already clearly defined as the primary form of phenolic resins.
Classification Basis
This commodity is phenolic resin in primary form, which conforms to the description of heading 3909 and has not been further processed or mixed with other substances into articles, so it is classified under 390940. If it were phenolic resin articles (such as sheets, pipes), it should be classified under subsequent headings of Chapter 39 or Chapter 85, etc.; if it were other types of resins such as amino resins, it would be classified under 390910.
📝 Declaration Elements
Product Name: The specific name of the declared commodity should accurately describe it as phenolic resin and indicate the form such as liquid, powder, granules, etc. Composition and Content: List the main components and content of the resin, such as the degree of polymerization of phenol and formaldehyde, free phenol content, etc. Appearance: Describe the color, shape, transparency, and other physical appearance, such as light yellow transparent liquid, white powder. Use: Explain the main application areas of the resin, such as adhesives, coatings, molding compounds, composite materials, etc. Brand: The brand or manufacturer name of the declared commodity; if no brand, fill in 'none'. Model: The model or grade of the product, used to distinguish resins of different specifications and properties. Packaging Specifications: Packaging form and weight per unit, such as iron drum, 200kg/drum; or paper bag, 25kg/bag. Modified or Not: Declare whether it is modified phenolic resin, such as rosin-modified, epoxy-modified, etc. Product Name: Phenolic resin (liquid); Composition and Content: Phenol 45%, Formaldehyde 30%, Water 25%; Appearance: Light yellow transparent viscous liquid; Use: Used for manufacturing sandpaper adhesive; Brand: XX; Model: PF-101; Packaging Specifications: Iron drum, 200kg/drum; Modified or Not: Unmodified. Confusing phenolic resin with amino resin, incorrectly classified under 390910. Failure to distinguish primary forms from semi-finished products or articles, leading to classification under other headings. Incomplete declaration of composition and content, lacking key information such as free phenol and free aldehyde.
Product Name
The specific name of the declared commodity should accurately describe it as phenolic resin and indicate the form such as liquid, powder, granules, etc.
⚠️ Writing only 'resin' or 'phenolic resin' without indicating the primary form, leading to classification disputes.
Composition and Content
List the main components and content of the resin, such as the degree of polymerization of phenol and formaldehyde, free phenol content, etc.
⚠️ Failure to provide free phenol or free aldehyde content, affecting safety and classification.
Appearance
Describe the color, shape, transparency, and other physical appearance, such as light yellow transparent liquid, white powder.
⚠️ Appearance description is too general, such as 'solid', making it impossible to distinguish whether it is block or powder.
Use
Explain the main application areas of the resin, such as adhesives, coatings, molding compounds, composite materials, etc.
⚠️ Use is not specific, such as 'industrial use', lacking specificity.
Brand
The brand or manufacturer name of the declared commodity; if no brand, fill in 'none'.
⚠️ Confusing brand with manufacturer, or failing to declare truthfully.
Model
The model or grade of the product, used to distinguish resins of different specifications and properties.
⚠️ Incorrect model filling or inconsistency with the actual product.
Packaging Specifications
Packaging form and weight per unit, such as iron drum, 200kg/drum; or paper bag, 25kg/bag.
⚠️ Incomplete packaging specifications, missing units or weight.
Modified or Not
Declare whether it is modified phenolic resin, such as rosin-modified, epoxy-modified, etc.
⚠️ Failure to declare modification status, which may affect classification.
Example： Product Name: Phenolic resin (liquid); Composition and Content: Phenol 45%, Formaldehyde 30%, Water 25%; Appearance: Light yellow transparent viscous liquid; Use: Used for manufacturing sandpaper adhesive; Brand: XX; Model: PF-101; Packaging Specifications: Iron drum, 200kg/drum; Modified or Not: Unmodified.
Common Mistakes：
Confusing phenolic resin with amino resin, incorrectly classified under 390910.
Failure to distinguish primary forms from semi-finished products or articles, leading to classification under other headings.
Incomplete declaration of composition and content, lacking key information such as free phenol and free aldehyde.
🎯 Classification Logic
Classification basis: According to the Import and Export Tariff and its notes, heading 3909 applies to amino resins, phenolic resins, and polyurethanes in primary forms. Phenolic resin refers to synthetic resin formed by the polycondensation of phenols (such as phenol, cresol) with aldehydes (such as formaldehyde). When determining, it is necessary to confirm that the commodity is in primary form (unprocessed or only primary processed) and that the chemical structure is phenolic resin. If it is a copolymer or modified product of phenolic resin with other substances, it should be determined based on the main components and characteristics. 390910 Amino resins: Amino resins are formed by the polycondensation of amino compounds with aldehydes, such as urea-formaldehyde resin, melamine-formaldehyde resin; phenolic resins are formed by the polycondensation of phenols with aldehydes. The chemical structures are different and can be distinguished by composition analysis. 390920 Melamine resins: Melamine resin is a polycondensate of melamine and formaldehyde, belonging to amino resins; phenolic resin does not contain melamine and can be distinguished by nitrogen content and infrared spectroscopy. 390930 Other amino resins: Other amino resins include urea-formaldehyde resin, etc., which have obvious differences from phenolic resins in raw materials and properties, such as water resistance and heat resistance. 390950 Polyurethanes: Polyurethane is prepared by the reaction of isocyanates with polyols and contains urethane bonds; phenolic resin is a phenolic polycondensate and does not contain urethane bonds. 390791 Other polyesters: Polyesters are formed by the polycondensation of polyacids with polyols, such as PET, PBT; phenolic resin is a phenolic polycondensate and can be distinguished by characteristic functional groups. Is it confirmed to be in primary form (liquid, powder, granules, etc.)? Is it formed by the polycondensation of phenols with aldehydes? Does it contain other polymers or modifying components? Are the composition and content clear, especially free phenol and free aldehyde? Is it confused with amino resins, polyurethanes, etc.?
Basis
Classification basis: According to the Import and Export Tariff and its notes, heading 3909 applies to amino resins, phenolic resins, and polyurethanes in primary forms. Phenolic resin refers to synthetic resin formed by the polycondensation of phenols (such as phenol, cresol) with aldehydes (such as formaldehyde). When determining, it is necessary to confirm that the commodity is in primary form (unprocessed or only primary processed) and that the chemical structure is phenolic resin. If it is a copolymer or modified product of phenolic resin with other substances, it should be determined based on the main components and characteristics.
Confused Codes：
390910 - Amino resins
Amino resins are formed by the polycondensation of amino compounds with aldehydes, such as urea-formaldehyde resin, melamine-formaldehyde resin; phenolic resins are formed by the polycondensation of phenols with aldehydes. The chemical structures are different and can be distinguished by composition analysis.
390920 - Melamine resins
Melamine resin is a polycondensate of melamine and formaldehyde, belonging to amino resins; phenolic resin does not contain melamine and can be distinguished by nitrogen content and infrared spectroscopy.
390930 - Other amino resins
Other amino resins include urea-formaldehyde resin, etc., which have obvious differences from phenolic resins in raw materials and properties, such as water resistance and heat resistance.
390950 - Polyurethanes
Polyurethane is prepared by the reaction of isocyanates with polyols and contains urethane bonds; phenolic resin is a phenolic polycondensate and does not contain urethane bonds.
390791 - Other polyesters
Polyesters are formed by the polycondensation of polyacids with polyols, such as PET, PBT; phenolic resin is a phenolic polycondensate and can be distinguished by characteristic functional groups.
Self-Check：
✓ Is it confirmed to be in primary form (liquid, powder, granules, etc.)?
✓ Is it formed by the polycondensation of phenols with aldehydes?
✓ Does it contain other polymers or modifying components?
✓ Are the composition and content clear, especially free phenol and free aldehyde?
✓ Is it confused with amino resins, polyurethanes, etc.?
❓ FAQ
How to determine whether phenolic resin is in primary form or an article? Primary form refers to unprocessed or only primary processed forms, such as liquid, paste, block, powder, granules, etc. If it has been made into specific shapes such as sheets, pipes, rods, etc., it is an article and should be classified under subsequent headings of Chapter 39 (such as 3920, 3921, etc.) or other chapters. What is the difference in classification between phenolic resin and phenolic molding compound? Phenolic resin in primary form is classified under 390940; phenolic molding compound (such as with fillers, reinforcing materials added) if in primary form may still be classified under 390940, but if made into molded articles, it is classified under 3920, etc. It should be determined based on the degree of processing and composition. Is modified phenolic resin still classified under 390940? If modified phenolic resin still retains the basic characteristics of phenolic resin and is in primary form, it is usually classified under 390940. However, if after modification it becomes another polymer (such as epoxy resin after epoxy modification), it should be classified according to the main component. What specific data on composition and content need to be provided during declaration? The content of main components (such as phenol, formaldehyde) should be provided, as well as the content of free phenol, free aldehyde, moisture, additives, etc. For modified resins, the name and content of the modifier should also be provided. How does the use of phenolic resin affect classification? The use itself does not change the classification, but if the use indicates that it has been made into specific articles (such as adhesives, coatings) and has been further processed, it may affect classification. Phenolic resin in primary form is classified under 390940 regardless of use. How to inquire about the import tariff rate for phenolic resin? It can be inquired through the official website of the General Administration of Customs, China International Trade Single Window, or the Import and Export Tariff. The tariff rate varies according to origin, trade agreements, etc., and it is recommended to use the latest official data. What regulatory documents are required for the export of phenolic resin? Generally, basic documents such as export declaration form, invoice, packing list, contract, etc. are required. If it is a hazardous chemical, the 'Outbound Goods Transport Packaging Use Appraisal Result Sheet' etc. are also required. Specific requirements are subject to customs. How to distinguish phenolic resin from urea resin in HS codes? Urea resin belongs to amino resins and is classified under 390910; phenolic resin is classified under 390940. They can be distinguished by composition analysis; urea resin has high nitrogen content, while phenolic resin contains phenolic hydroxyl groups.
Q: How to determine whether phenolic resin is in primary form or an article?
A: Primary form refers to unprocessed or only primary processed forms, such as liquid, paste, block, powder, granules, etc. If it has been made into specific shapes such as sheets, pipes, rods, etc., it is an article and should be classified under subsequent headings of Chapter 39 (such as 3920, 3921, etc.) or other chapters.
Q: What is the difference in classification between phenolic resin and phenolic molding compound?
A: Phenolic resin in primary form is classified under 390940; phenolic molding compound (such as with fillers, reinforcing materials added) if in primary form may still be classified under 390940, but if made into molded articles, it is classified under 3920, etc. It should be determined based on the degree of processing and composition.
Q: Is modified phenolic resin still classified under 390940?
A: If modified phenolic resin still retains the basic characteristics of phenolic resin and is in primary form, it is usually classified under 390940. However, if after modification it becomes another polymer (such as epoxy resin after epoxy modification), it should be classified according to the main component.
Q: What specific data on composition and content need to be provided during declaration?
A: The content of main components (such as phenol, formaldehyde) should be provided, as well as the content of free phenol, free aldehyde, moisture, additives, etc. For modified resins, the name and content of the modifier should also be provided.
Q: How does the use of phenolic resin affect classification?
A: The use itself does not change the classification, but if the use indicates that it has been made into specific articles (such as adhesives, coatings) and has been further processed, it may affect classification. Phenolic resin in primary form is classified under 390940 regardless of use.
Q: How to inquire about the import tariff rate for phenolic resin?
A: It can be inquired through the official website of the General Administration of Customs, China International Trade Single Window, or the Import and Export Tariff. The tariff rate varies according to origin, trade agreements, etc., and it is recommended to use the latest official data.
Q: What regulatory documents are required for the export of phenolic resin?
A: Generally, basic documents such as export declaration form, invoice, packing list, contract, etc. are required. If it is a hazardous chemical, the 'Outbound Goods Transport Packaging Use Appraisal Result Sheet' etc. are also required. Specific requirements are subject to customs.
Q: How to distinguish phenolic resin from urea resin in HS codes?
A: Urea resin belongs to amino resins and is classified under 390910; phenolic resin is classified under 390940. They can be distinguished by composition analysis; urea resin has high nitrogen content, while phenolic resin contains phenolic hydroxyl groups.
⚠️ 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.