Chapter 39 covers plastics and articles thereof, including polymers in primary forms, waste and scrap, and semi-manufactures. This chapter is divided into four sections by polymer origin: 39.01-39.11 for petroleum resins and synthetic polymers, 39.12-39.14 for natural polymers and their derivatives (such as cellulose, rubber), 39.15-39.25 for waste and scrap and articles, and 39.26 for other articles of plastics. The chapter notes strictly define "primary forms" to include liquids, pastes, blocks, powders, etc., and this chapter does not cover plastics that have been made into specific articles. Heading 3912 covers other cellulose and its chemical derivatives in primary forms, including cellulose nitrate, cellulose acetate, other cellulose ethers and esters, etc. This heading is subdivided according to whether plasticized and the specific type of derivative. Cellulose acetate is an ester derivative produced by the reaction of cellulose with acetic anhydride; when plasticized it has thermoplastic properties and can be used to manufacture film, fibers, plastic articles, etc. Code 391212 consists of 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 "12" represent subheading 3912.12 (plasticized cellulose acetate in primary forms). Here "plasticized" means the addition of plasticizers to improve processing properties, as distinct from non-plasticized cellulose acetate (3912.11). This subheading covers only primary forms (such as powder, granules, blocks, etc.), and does not cover semi-manufactures or articles already made into sheets, film, filaments, etc. This commodity is plasticized cellulose acetate, a chemical derivative of cellulose, and is in primary form, so it is classified under 3912. Non-plasticized cellulose acetate is classified under 3912.11; if already made into non-primary forms (such as plates, sheets, film), it is classified under headings after 3912 (such as 3920 or 3921). Also, if it is cellulose acetate waste and scrap, it is classified under 3915, not 3912. Therefore, being plasticized and in primary form is the key to classification under 3912.12.
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, waste and scrap, and semi-manufactures. This chapter is divided into four sections by polymer origin: 39.01-39.11 for petroleum resins and synthetic polymers, 39.12-39.14 for natural polymers and their derivatives (such as cellulose, rubber), 39.15-39.25 for waste and scrap and articles, and 39.26 for other articles of plastics. The chapter notes strictly define "primary forms" to include liquids, pastes, blocks, powders, etc., and this chapter does not cover plastics that have been made into specific articles.
Heading
Heading 3912 covers other cellulose and its chemical derivatives in primary forms, including cellulose nitrate, cellulose acetate, other cellulose ethers and esters, etc. This heading is subdivided according to whether plasticized and the specific type of derivative. Cellulose acetate is an ester derivative produced by the reaction of cellulose with acetic anhydride; when plasticized it has thermoplastic properties and can be used to manufacture film, fibers, plastic articles, etc.
Digit Breakdown
Code 391212 consists of 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 "12" represent subheading 3912.12 (plasticized cellulose acetate in primary forms). Here "plasticized" means the addition of plasticizers to improve processing properties, as distinct from non-plasticized cellulose acetate (3912.11). This subheading covers only primary forms (such as powder, granules, blocks, etc.), and does not cover semi-manufactures or articles already made into sheets, film, filaments, etc.
Classification Basis
This commodity is plasticized cellulose acetate, a chemical derivative of cellulose, and is in primary form, so it is classified under 3912. Non-plasticized cellulose acetate is classified under 3912.11; if already made into non-primary forms (such as plates, sheets, film), it is classified under headings after 3912 (such as 3920 or 3921). Also, if it is cellulose acetate waste and scrap, it is classified under 3915, not 3912. Therefore, being plasticized and in primary form is the key to classification under 3912.12.
📝 Declaration Elements
Product name: The specific name of the declared commodity, which should be stated as "plasticized cellulose acetate in primary forms" or "plasticized cellulose acetate". Appearance: Describe the physical form of the commodity, such as powder, granules, blocks, liquid, etc., which must conform to the definition of "primary forms". Composition and content: Indicate the cellulose acetate content, type and content of plasticizer, other additives (such as stabilizers, colorants) and moisture, etc. Type of plasticizer: Specify the chemical name of the plasticizer, such as dioctyl phthalate, tricresyl phosphate, etc. Source: State whether it is virgin (new material) or recycled material; recycled material may involve environmental protection or tariff differences. Brand or model: If there is a brand or model, declare it truthfully; if no brand, fill in "none". Use: Briefly describe the main use, such as for manufacturing plastic articles, fibers, coatings, etc. Product name: plasticized cellulose acetate in primary forms; Appearance: white granules; Composition and content: cellulose acetate 85%, dioctyl phthalate 12%, stabilizer 2%, moisture 1%; Type of plasticizer: dioctyl phthalate; Source: virgin; Brand: none; Model: CA-100; Use: used for injection molding to manufacture tool handles. Misclassifying non-primary form cellulose acetate (such as sheets) under 3912.12, when it should actually be classified under 3920 or 3921. Failing to provide specific information on the plasticizer, unable to prove "plasticized", may be classified under 3912.11. Recycled material not declared, may violate environmental regulations or affect tariff treatment. Incomplete declaration of composition and content, such as failing to list additives, affecting classification and customs valuation.
Product name
The specific name of the declared commodity, which should be stated as "plasticized cellulose acetate in primary forms" or "plasticized cellulose acetate".
⚠️ Writing only "cellulose acetate" without indicating plasticized or primary form, leading to classification disputes.
Appearance
Describe the physical form of the commodity, such as powder, granules, blocks, liquid, etc., which must conform to the definition of "primary forms".
⚠️ Describing it as "sheet" or "film", which are non-primary forms and should be classified under other headings.
Composition and content
Indicate the cellulose acetate content, type and content of plasticizer, other additives (such as stabilizers, colorants) and moisture, etc.
⚠️ Failing to list the specific name and proportion of the plasticizer, making it impossible to determine whether it is plasticized.
Type of plasticizer
Specify the chemical name of the plasticizer, such as dioctyl phthalate, tricresyl phosphate, etc.
⚠️ Writing only "plasticizer" without providing the specific chemical name, affecting classification.
Source
State whether it is virgin (new material) or recycled material; recycled material may involve environmental protection or tariff differences.
⚠️ Failing to distinguish between virgin and recycled material, which may lead to different regulatory conditions.
Brand or model
If there is a brand or model, declare it truthfully; if no brand, fill in "none".
⚠️ Brand and model inconsistent with the actual goods, affecting customs inspection.
Use
Briefly describe the main use, such as for manufacturing plastic articles, fibers, coatings, etc.
⚠️ Use description too general, such as "industrial use", lacking specificity.
Example： Product name: plasticized cellulose acetate in primary forms; Appearance: white granules; Composition and content: cellulose acetate 85%, dioctyl phthalate 12%, stabilizer 2%, moisture 1%; Type of plasticizer: dioctyl phthalate; Source: virgin; Brand: none; Model: CA-100; Use: used for injection molding to manufacture tool handles.
Common Mistakes：
Misclassifying non-primary form cellulose acetate (such as sheets) under 3912.12, when it should actually be classified under 3920 or 3921.
Failing to provide specific information on the plasticizer, unable to prove "plasticized", may be classified under 3912.11.
Recycled material not declared, may violate environmental regulations or affect tariff treatment.
Incomplete declaration of composition and content, such as failing to list additives, affecting classification and customs valuation.
🎯 Classification Logic
The core basis for classification is the "Import and Export Tariff" and the "HS Explanatory Notes". First, confirm that the commodity belongs to Chapter 39 plastics and is in primary form. Second, according to chemical composition, cellulose acetate is a cellulose derivative and should be classified under 3912. Then, according to whether it is plasticized, plasticized cellulose acetate is classified under 3912.12, and non-plasticized under 3912.11. If the commodity has been made into non-primary forms, then subsequent headings of Chapter 39 (such as 3920, 3921) or Chapter 54 (man-made fibers) etc. need to be considered. At the same time, attention should be paid to excluding waste and scrap (3915) and commodities made into specific articles. 391211 Non-plasticized cellulose acetate: The difference from 3912.12 lies in whether a plasticizer is added. Non-plasticized products are brittle, while plasticized products are flexible. When declaring, proof of plasticizer is required. 391231 Carboxymethyl cellulose and its salts: Carboxymethyl cellulose is a cellulose ether, while cellulose acetate is a cellulose ester. They have different chemical structures and different uses, but may appear similar and need to be distinguished by composition analysis. 391220 Cellulose nitrate: Cellulose nitrate is also a cellulose ester, but the substituent is nitrate, which is flammable and explosive, and is classified differently. Cellulose acetate is relatively stable. 392073 Plates, sheets, film of cellulose acetate: This code is for semi-manufactures or articles, not primary forms. If cellulose acetate has been made into plates, sheets, film, it should be classified under 3920.73, not 3912.12. 391510 Waste and scrap of cellulose acetate: Waste and scrap are classified under 3915, not 3912. If the commodity is recycled cellulose acetate waste, even if in primary form, it should be classified as waste and scrap. Is the commodity in primary form (powder, granules, blocks, etc.)? Has a plasticizer been added? Is cellulose acetate the main component in the composition? Does it belong to waste and scrap or recycled material? Has it been made into non-primary forms such as plates, sheets, film?
Basis
The core basis for classification is the "Import and Export Tariff" and the "HS Explanatory Notes". First, confirm that the commodity belongs to Chapter 39 plastics and is in primary form. Second, according to chemical composition, cellulose acetate is a cellulose derivative and should be classified under 3912. Then, according to whether it is plasticized, plasticized cellulose acetate is classified under 3912.12, and non-plasticized under 3912.11. If the commodity has been made into non-primary forms, then subsequent headings of Chapter 39 (such as 3920, 3921) or Chapter 54 (man-made fibers) etc. need to be considered. At the same time, attention should be paid to excluding waste and scrap (3915) and commodities made into specific articles.
Confused Codes：
391211 - Non-plasticized cellulose acetate
The difference from 3912.12 lies in whether a plasticizer is added. Non-plasticized products are brittle, while plasticized products are flexible. When declaring, proof of plasticizer is required.
391231 - Carboxymethyl cellulose and its salts
Carboxymethyl cellulose is a cellulose ether, while cellulose acetate is a cellulose ester. They have different chemical structures and different uses, but may appear similar and need to be distinguished by composition analysis.
391220 - Cellulose nitrate
Cellulose nitrate is also a cellulose ester, but the substituent is nitrate, which is flammable and explosive, and is classified differently. Cellulose acetate is relatively stable.
392073 - Plates, sheets, film of cellulose acetate
This code is for semi-manufactures or articles, not primary forms. If cellulose acetate has been made into plates, sheets, film, it should be classified under 3920.73, not 3912.12.
391510 - Waste and scrap of cellulose acetate
Waste and scrap are classified under 3915, not 3912. If the commodity is recycled cellulose acetate waste, even if in primary form, it should be classified as waste and scrap.
Self-Check：
✓ Is the commodity in primary form (powder, granules, blocks, etc.)?
✓ Has a plasticizer been added?
✓ Is cellulose acetate the main component in the composition?
✓ Does it belong to waste and scrap or recycled material?
✓ Has it been made into non-primary forms such as plates, sheets, film?
❓ FAQ
How to determine whether cellulose acetate is "plasticized"? Plasticization refers to adding plasticizers (such as phthalates, phosphates) to cellulose acetate to improve processing properties. Usually the plasticizer content is between 10% and 30%. When declaring, the name and content of the plasticizer must be provided, and customs may require testing. If no plasticizer is added or the amount added is extremely low, it is considered non-plasticized and classified under 3912.11. What is the import tariff rate for plasticized cellulose acetate in primary forms? Tariff rates vary depending on country, trade agreements, origin, etc. It is recommended to check the latest "Import and Export Tariff" or query through the General Administration of Customs website or the International Trade Single Window. MFN rates, general rates, agreement rates, etc. need to be determined according to the specific origin. This reply does not provide specific tariff rate figures. If the cellulose acetate is recycled material, can it still be classified under 3912.12? No. Recycled cellulose acetate waste and scrap should be classified under 3915. Even if it has undergone primary form processing such as pelletizing, if its source is waste and scrap, it may still be classified as waste and scrap. However, if the recycled material has undergone chemical modification to become new cellulose acetate, it may be classified under 3912. Judgment should be based on the actual processing technology and composition. How should the "Appearance" column be filled in when declaring? It should accurately describe the physical form of the commodity, such as "white granules", "transparent blocks", "powder", etc. Avoid using descriptions of non-primary forms such as "sheet", "film", otherwise it may lead to classification errors. If it is liquid, indicate "liquid" and viscosity, etc. Are cellulose acetate and acetic acid cellulose the same substance? Yes, cellulose acetate is also called acetic acid cellulose, both are Cellulose acetate in English. When declaring, it is recommended to use "cellulose acetate" to be consistent with the tariff. However, note that if it is a derivative of cellulose acetate ester (such as cellulose acetate butyrate), it is classified under other subheadings. How to distinguish between 3912.12 and 3920.73? 3912.12 is for primary forms (such as granules, powder), while 3920.73 is for non-primary forms already made into plates, sheets, film, etc. If cellulose acetate has been pressed into sheets, even if not further processed, it should be classified under 3920.73. The key to judgment is whether the shape belongs to primary forms. How detailed does the "Composition and content" in the declaration elements need to be? It is necessary to list the cellulose acetate content, type and content of plasticizer, other additives (such as stabilizers, colorants) and moisture. If it is a mixture, the proportion of each component must also be indicated. The content percentage should be accurate, and the error should not exceed 5%. If the commodity contains both plasticized and non-plasticized cellulose acetate, how to classify? If it is a mixture, classification should be determined based on the main component (the one with the largest weight proportion). If plasticized cellulose acetate accounts for the largest proportion, it is classified under 3912.12; otherwise under 3912.11. If it cannot be distinguished, it is recommended to provide a test report, or classify as non-plasticized (strictly).
Q: How to determine whether cellulose acetate is "plasticized"?
A: Plasticization refers to adding plasticizers (such as phthalates, phosphates) to cellulose acetate to improve processing properties. Usually the plasticizer content is between 10% and 30%. When declaring, the name and content of the plasticizer must be provided, and customs may require testing. If no plasticizer is added or the amount added is extremely low, it is considered non-plasticized and classified under 3912.11.
Q: What is the import tariff rate for plasticized cellulose acetate in primary forms?
A: Tariff rates vary depending on country, trade agreements, origin, etc. It is recommended to check the latest "Import and Export Tariff" or query through the General Administration of Customs website or the International Trade Single Window. MFN rates, general rates, agreement rates, etc. need to be determined according to the specific origin. This reply does not provide specific tariff rate figures.
Q: If the cellulose acetate is recycled material, can it still be classified under 3912.12?
A: No. Recycled cellulose acetate waste and scrap should be classified under 3915. Even if it has undergone primary form processing such as pelletizing, if its source is waste and scrap, it may still be classified as waste and scrap. However, if the recycled material has undergone chemical modification to become new cellulose acetate, it may be classified under 3912. Judgment should be based on the actual processing technology and composition.
Q: How should the "Appearance" column be filled in when declaring?
A: It should accurately describe the physical form of the commodity, such as "white granules", "transparent blocks", "powder", etc. Avoid using descriptions of non-primary forms such as "sheet", "film", otherwise it may lead to classification errors. If it is liquid, indicate "liquid" and viscosity, etc.
Q: Are cellulose acetate and acetic acid cellulose the same substance?
A: Yes, cellulose acetate is also called acetic acid cellulose, both are Cellulose acetate in English. When declaring, it is recommended to use "cellulose acetate" to be consistent with the tariff. However, note that if it is a derivative of cellulose acetate ester (such as cellulose acetate butyrate), it is classified under other subheadings.
Q: How to distinguish between 3912.12 and 3920.73?
A: 3912.12 is for primary forms (such as granules, powder), while 3920.73 is for non-primary forms already made into plates, sheets, film, etc. If cellulose acetate has been pressed into sheets, even if not further processed, it should be classified under 3920.73. The key to judgment is whether the shape belongs to primary forms.
Q: How detailed does the "Composition and content" in the declaration elements need to be?
A: It is necessary to list the cellulose acetate content, type and content of plasticizer, other additives (such as stabilizers, colorants) and moisture. If it is a mixture, the proportion of each component must also be indicated. The content percentage should be accurate, and the error should not exceed 5%.
Q: If the commodity contains both plasticized and non-plasticized cellulose acetate, how to classify?
A: If it is a mixture, classification should be determined based on the main component (the one with the largest weight proportion). If plasticized cellulose acetate accounts for the largest proportion, it is classified under 3912.12; otherwise under 3912.11. If it cannot be distinguished, it is recommended to provide a test report, or classify as non-plasticized (strictly).
⚠️ 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.