Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, and raw materials for chemical fibers. This chapter is an important chapter in the HS classification for chemicals and plastic products, involving a wide range of commodities from raw materials to semi-finished and finished products. Chapter 39 is divided into two subchapters: the first subchapter covers plastics in primary forms, the second subchapter covers waste, parings and scrap, and the third subchapter covers semi-manufactures and articles. Primary forms include liquid, paste, block, powder, granule and other forms. Heading 3912 covers other cellulose and its chemical derivatives in primary forms, including unplasticized cellulose acetate, cellulose nitrate, cellulose acetate butyrate, etc. Products under this heading are usually chemical raw materials used to manufacture plastic products, fibers, coatings, films, etc. Note the distinction from plastics of headings 3901-3911; 3912 specifically refers to cellulose derivatives, not synthetic resins. Code 391211 has 6 digits. The first 2 digits '39' represent Chapter 39 (Plastics and articles thereof). Digits 3-4 '12' represent heading 3912 (Other cellulose and its chemical derivatives, in primary forms). Digits 5-6 '11' represent subheading 391211, specifically unplasticized cellulose acetate. Among them, the 5th digit '1' indicates unplasticized cellulose acetate, and the 6th digit '1' further subdivides it. This subheading only includes unplasticized cellulose acetate; if plasticized, it is classified under other subheadings. The commodity is unplasticized cellulose acetate in primary forms, belonging to cellulose derivatives, therefore classified under 3912 rather than synthetic resins of 3901-3911. Unplasticized means no plasticizer has been added; if plasticized, it may be classified under 391212. At the same time, it must be distinguished from other subheadings under 3912 such as 391212 (plasticized cellulose acetate), 391213 (cellulose nitrate), etc.
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, and raw materials for chemical fibers. This chapter is an important chapter in the HS classification for chemicals and plastic products, involving a wide range of commodities from raw materials to semi-finished and finished products. Chapter 39 is divided into two subchapters: the first subchapter covers plastics in primary forms, the second subchapter covers waste, parings and scrap, and the third subchapter covers semi-manufactures and articles. Primary forms include liquid, paste, block, powder, granule and other forms.
Heading
Heading 3912 covers other cellulose and its chemical derivatives in primary forms, including unplasticized cellulose acetate, cellulose nitrate, cellulose acetate butyrate, etc. Products under this heading are usually chemical raw materials used to manufacture plastic products, fibers, coatings, films, etc. Note the distinction from plastics of headings 3901-3911; 3912 specifically refers to cellulose derivatives, not synthetic resins.
Digit Breakdown
Code 391211 has 6 digits. The first 2 digits '39' represent Chapter 39 (Plastics and articles thereof). Digits 3-4 '12' represent heading 3912 (Other cellulose and its chemical derivatives, in primary forms). Digits 5-6 '11' represent subheading 391211, specifically unplasticized cellulose acetate. Among them, the 5th digit '1' indicates unplasticized cellulose acetate, and the 6th digit '1' further subdivides it. This subheading only includes unplasticized cellulose acetate; if plasticized, it is classified under other subheadings.
Classification Basis
The commodity is unplasticized cellulose acetate in primary forms, belonging to cellulose derivatives, therefore classified under 3912 rather than synthetic resins of 3901-3911. Unplasticized means no plasticizer has been added; if plasticized, it may be classified under 391212. At the same time, it must be distinguished from other subheadings under 3912 such as 391212 (plasticized cellulose acetate), 391213 (cellulose nitrate), etc.
📝 Declaration Elements
Product name: The Chinese and English names of the declared commodity should accurately reflect the product attributes, such as 'unplasticized cellulose acetate' or 'cellulose diacetate' Appearance: Describe the specific form of the primary shape, such as powder, granules, blocks, liquid, etc., and indicate the color Composition and content: Indicate cellulose acetate content, moisture, impurities, etc., and whether plasticizers are contained. If unplasticized, it should be stated that no plasticizer is contained Source: Explain the source of cellulose, such as wood pulp, cotton pulp, etc., and whether it has undergone chemical modification Grade: If there is a commercial grade or model, it should be declared truthfully to facilitate customs identification Use: Explain the main use, such as for manufacturing plastic products, fibers, films, coatings, etc. Plasticization status: Clearly state whether it is plasticized; if unplasticized, it should be declared as 'unplasticized' or 'contains no plasticizer' Customs declaration example:
Product name: Unplasticized cellulose acetate (cellulose diacetate)
Appearance: White powder
Composition and content: Cellulose acetate ≥95%, moisture ≤5%, contains no plasticizer
Source: Wood pulp
Grade: CA-398-3
Use: Used to manufacture plastic films
Plasticization status: Unplasticized
HS code: 39121100 Mistakenly classifying plasticized cellulose acetate under 391211, when it should actually be classified under 391212 Failing to indicate plasticizer content, causing customs to question the classification Confusing cellulose acetate with acetyl cellulose, the latter of which may be classified under other codes Ignoring the definition of primary forms and incorrectly classifying semi-finished products or articles
Product name
The Chinese and English names of the declared commodity should accurately reflect the product attributes, such as 'unplasticized cellulose acetate' or 'cellulose diacetate'
⚠️ Incorrectly declared as 'plasticized cellulose acetate' or 'acetate fiber'
Appearance
Describe the specific form of the primary shape, such as powder, granules, blocks, liquid, etc., and indicate the color
⚠️ Only writing 'solid' or 'liquid' without specifying the form
Composition and content
Indicate cellulose acetate content, moisture, impurities, etc., and whether plasticizers are contained. If unplasticized, it should be stated that no plasticizer is contained
⚠️ Failing to indicate plasticizer content, or incorrectly labeling that a plasticizer is contained
Source
Explain the source of cellulose, such as wood pulp, cotton pulp, etc., and whether it has undergone chemical modification
⚠️ Ignoring source information, or confusing natural cellulose with regenerated cellulose
Grade
If there is a commercial grade or model, it should be declared truthfully to facilitate customs identification
⚠️ The grade does not match the actual goods, or no grade is provided
Use
Explain the main use, such as for manufacturing plastic products, fibers, films, coatings, etc.
⚠️ The use description is too broad, such as 'industrial use'
Plasticization status
Clearly state whether it is plasticized; if unplasticized, it should be declared as 'unplasticized' or 'contains no plasticizer'
⚠️ Failing to clarify the plasticization status, leading to classification errors
Example： Customs declaration example:
Product name: Unplasticized cellulose acetate (cellulose diacetate)
Appearance: White powder
Composition and content: Cellulose acetate ≥95%, moisture ≤5%, contains no plasticizer
Source: Wood pulp
Grade: CA-398-3
Use: Used to manufacture plastic films
Plasticization status: Unplasticized
HS code: 39121100
Common Mistakes：
Mistakenly classifying plasticized cellulose acetate under 391211, when it should actually be classified under 391212
Failing to indicate plasticizer content, causing customs to question the classification
Confusing cellulose acetate with acetyl cellulose, the latter of which may be classified under other codes
Ignoring the definition of primary forms and incorrectly classifying semi-finished products or articles
🎯 Classification Logic
Core criteria for classification: 1. The commodity is in primary forms (liquid, paste, block, powder, granule, etc.); 2. The composition is cellulose acetate and it is unplasticized (contains no plasticizer or the plasticizer content is below the standard); 3. It belongs to cellulose derivatives, not synthetic resins. According to HS notes, 3912 includes chemically modified cellulose, such as cellulose acetate. If plasticized, it is classified under 391212. If it is cellulose acetate waste and scrap, it is classified under 3915. 391212 Plasticized cellulose acetate: Plasticized cellulose acetate contains a plasticizer, while 391211 does not. The difference lies in the presence or absence of a plasticizer, and a composition certificate must be provided at declaration. 391213 Cellulose nitrate: Cellulose nitrate is another cellulose derivative, but its chemical composition is different. 391211 specifically refers to cellulose acetate, while cellulose nitrate is classified under 391213. 391231 Carboxymethylcellulose and its salts: Carboxymethylcellulose is a cellulose ether, while cellulose acetate is a cellulose ester. Their chemical structures are different, so their classification is different. 390130 Ethylene-vinyl acetate copolymers in primary forms: This code is for synthetic resins, while 391211 is for cellulose derivatives. Their sources and chemical structures are different. 391590 Waste, parings and scrap of other plastics: If cellulose acetate is waste and scrap, it should be classified under 3915, not 391211. 391211 applies only to primary forms. Is it confirmed to be in primary forms? Does it contain no plasticizer? Is it cellulose acetate rather than other cellulose derivatives? Is it not mixed with other substances? Is it intended for further processing rather than direct use?
Basis
Core criteria for classification: 1. The commodity is in primary forms (liquid, paste, block, powder, granule, etc.); 2. The composition is cellulose acetate and it is unplasticized (contains no plasticizer or the plasticizer content is below the standard); 3. It belongs to cellulose derivatives, not synthetic resins. According to HS notes, 3912 includes chemically modified cellulose, such as cellulose acetate. If plasticized, it is classified under 391212. If it is cellulose acetate waste and scrap, it is classified under 3915.
Confused Codes：
391212 - Plasticized cellulose acetate
Plasticized cellulose acetate contains a plasticizer, while 391211 does not. The difference lies in the presence or absence of a plasticizer, and a composition certificate must be provided at declaration.
391213 - Cellulose nitrate
Cellulose nitrate is another cellulose derivative, but its chemical composition is different. 391211 specifically refers to cellulose acetate, while cellulose nitrate is classified under 391213.
391231 - Carboxymethylcellulose and its salts
Carboxymethylcellulose is a cellulose ether, while cellulose acetate is a cellulose ester. Their chemical structures are different, so their classification is different.
390130 - Ethylene-vinyl acetate copolymers in primary forms
This code is for synthetic resins, while 391211 is for cellulose derivatives. Their sources and chemical structures are different.
391590 - Waste, parings and scrap of other plastics
If cellulose acetate is waste and scrap, it should be classified under 3915, not 391211. 391211 applies only to primary forms.
Self-Check：
✓ Is it confirmed to be in primary forms?
✓ Does it contain no plasticizer?
✓ Is it cellulose acetate rather than other cellulose derivatives?
✓ Is it not mixed with other substances?
✓ Is it intended for further processing rather than direct use?
❓ FAQ
How can it be determined whether cellulose acetate is plasticized? Plasticization refers to the addition of plasticizers (such as phthalates) to increase flexibility. It can be determined by testing the plasticizer content; if the content exceeds a certain standard (usually above 0.5%), it is considered plasticized. A test report should be provided at declaration. What is the difference between cellulose acetate and acetyl cellulose? Cellulose acetate and acetyl cellulose are different Chinese translations of the same substance, both being Cellulose acetate in English. However, note that sometimes 'acetyl cellulose' may refer to products with different degrees of esterification, such as cellulose triacetate. Classification is based on chemical composition. If cellulose acetate is recycled material, can it still be classified under 391211? If the recycled material is in primary forms and unplasticized, it can still be classified under 391211. However, if it is waste and scrap, it should be classified under 3915. Judgment should be based on form and source. What is the import tariff rate for 391211? Tariff rates vary by country, trade agreement, year, etc. It is recommended to consult the latest customs tariff or use an official database. For example, the website of the General Administration of Customs of China or tariff query tools provided by the CCPIT. Is an MSDS required at declaration? Generally, an MSDS is not required, but if customs requests it, it should be provided. An MSDS helps explain composition and hazards, but classification is mainly based on composition and form. Is a cellulose acetate solution classified under 391211? If cellulose acetate is dissolved in a volatile solvent and the solvent content exceeds 50%, it is usually classified under Chapter 32 (Paints, varnishes). If it is cellulose acetate in primary forms (such as powder or granules), even if it contains a small amount of solvent, it may still be classified under 391211. How can 391211 and 390130 be distinguished? 391211 is a cellulose derivative, while 390130 is an ethylene-vinyl acetate copolymer, which is a synthetic resin. They can be distinguished by chemical analysis such as infrared spectroscopy. If cellulose acetate contains fillers, does it affect classification? If the filler is only a small amount of additive (such as titanium dioxide), it does not affect classification. However, if the filler causes the product to lose the essential characteristics of primary forms, or if it becomes an article, it may be classified under other codes.
Q: How can it be determined whether cellulose acetate is plasticized?
A: Plasticization refers to the addition of plasticizers (such as phthalates) to increase flexibility. It can be determined by testing the plasticizer content; if the content exceeds a certain standard (usually above 0.5%), it is considered plasticized. A test report should be provided at declaration.
Q: What is the difference between cellulose acetate and acetyl cellulose?
A: Cellulose acetate and acetyl cellulose are different Chinese translations of the same substance, both being Cellulose acetate in English. However, note that sometimes 'acetyl cellulose' may refer to products with different degrees of esterification, such as cellulose triacetate. Classification is based on chemical composition.
Q: If cellulose acetate is recycled material, can it still be classified under 391211?
A: If the recycled material is in primary forms and unplasticized, it can still be classified under 391211. However, if it is waste and scrap, it should be classified under 3915. Judgment should be based on form and source.
Q: What is the import tariff rate for 391211?
A: Tariff rates vary by country, trade agreement, year, etc. It is recommended to consult the latest customs tariff or use an official database. For example, the website of the General Administration of Customs of China or tariff query tools provided by the CCPIT.
Q: Is an MSDS required at declaration?
A: Generally, an MSDS is not required, but if customs requests it, it should be provided. An MSDS helps explain composition and hazards, but classification is mainly based on composition and form.
Q: Is a cellulose acetate solution classified under 391211?
A: If cellulose acetate is dissolved in a volatile solvent and the solvent content exceeds 50%, it is usually classified under Chapter 32 (Paints, varnishes). If it is cellulose acetate in primary forms (such as powder or granules), even if it contains a small amount of solvent, it may still be classified under 391211.
Q: How can 391211 and 390130 be distinguished?
A: 391211 is a cellulose derivative, while 390130 is an ethylene-vinyl acetate copolymer, which is a synthetic resin. They can be distinguished by chemical analysis such as infrared spectroscopy.
Q: If cellulose acetate contains fillers, does it affect classification?
A: If the filler is only a small amount of additive (such as titanium dioxide), it does not affect classification. However, if the filler causes the product to lose the essential characteristics of primary forms, or if it becomes an article, it may be classified under other codes.
⚠️ 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.