Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic rubber, cellulose and its chemical derivatives, etc. This chapter is classified according to polymer types and processing stages. Heading 3912 specifically covers cellulose and its chemical derivatives not elsewhere specified or included, belonging to the category of polymer materials. Heading 3912 includes cellulose and its chemical derivatives in primary forms, such as cellulose nitrate, cellulose acetate, cellulose ethers, etc. These products are typically obtained by chemical modification of natural cellulose and are widely used in coatings, building materials, pharmaceuticals, food, and other fields. First 2 digits 39: Chapter 39 Plastics and articles thereof; digits 3-4: 12: Heading 3912 Cellulose and its chemical derivatives; digits 5-6: 39: Subheading 391239, referring to cellulose ethers in other primary forms, i.e., cellulose ethers not specified in 391231 to 391238. This commodity is cellulose ether in other primary forms. Since it is not specifically named in 391231 to 391238 (such as carboxymethyl cellulose, hydroxypropyl cellulose, etc.), it is classified under 391239. It differs from other subheadings under 3912 such as cellulose nitrate (391220) or cellulose acetate (391211) because its chemical structure is an ether.
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic rubber, cellulose and its chemical derivatives, etc. This chapter is classified according to polymer types and processing stages. Heading 3912 specifically covers cellulose and its chemical derivatives not elsewhere specified or included, belonging to the category of polymer materials.
Heading
Heading 3912 includes cellulose and its chemical derivatives in primary forms, such as cellulose nitrate, cellulose acetate, cellulose ethers, etc. These products are typically obtained by chemical modification of natural cellulose and are widely used in coatings, building materials, pharmaceuticals, food, and other fields.
Digit Breakdown
First 2 digits 39: Chapter 39 Plastics and articles thereof; digits 3-4: 12: Heading 3912 Cellulose and its chemical derivatives; digits 5-6: 39: Subheading 391239, referring to cellulose ethers in other primary forms, i.e., cellulose ethers not specified in 391231 to 391238.
Classification Basis
This commodity is cellulose ether in other primary forms. Since it is not specifically named in 391231 to 391238 (such as carboxymethyl cellulose, hydroxypropyl cellulose, etc.), it is classified under 391239. It differs from other subheadings under 3912 such as cellulose nitrate (391220) or cellulose acetate (391211) because its chemical structure is an ether.
📝 Declaration Elements
Product Name: The specific name of the declared commodity, such as hydroxyethyl cellulose, methyl cellulose, etc., which must correspond to the HS code. Appearance: Describe the primary form, such as powder, granules, liquid, etc., which affects classification. Composition and Content: Indicate key indicators such as purity, degree of substitution, moisture content of the cellulose ether. Use: Explain the main application fields, such as building materials, coatings, pharmaceuticals, etc. Brand: If there is a brand, declare the brand name; if no brand, indicate 'no brand'. Model: Declare the specific model or specification to facilitate distinguishing different products. Packaging Specification: Explain the packaging method and net weight, such as 25kg/bag. Product Name: Hydroxyethyl cellulose; Appearance: White powder; Composition and Content: Hydroxyethyl cellulose ≥95%, moisture ≤5%; Use: Used for thickening water-based coatings; Brand: No brand; Model: HEC-100; Packaging Specification: 25kg/bag. Confusing cellulose ethers with cellulose esters, such as mistakenly classifying cellulose acetate under 391239. Failure to distinguish between primary forms and non-primary forms, such as films or rods already made should be classified under other headings. Neglecting key indicators such as degree of substitution, leading to incorrect subheading classification.
Product Name
The specific name of the declared commodity, such as hydroxyethyl cellulose, methyl cellulose, etc., which must correspond to the HS code.
⚠️ Writing only 'cellulose ether' is too general and does not specify the specific variety.
Appearance
Describe the primary form, such as powder, granules, liquid, etc., which affects classification.
⚠️ Misreporting a solution form as solid powder.
Composition and Content
Indicate key indicators such as purity, degree of substitution, moisture content of the cellulose ether.
⚠️ Failure to provide degree of substitution or purity, leading to classification disputes.
Use
Explain the main application fields, such as building materials, coatings, pharmaceuticals, etc.
⚠️ Use description is too broad, such as 'industrial use'.
Brand
If there is a brand, declare the brand name; if no brand, indicate 'no brand'.
⚠️ Neglecting brand declaration, leading to subsequent inspection issues.
Model
Declare the specific model or specification to facilitate distinguishing different products.
⚠️ Model filled in incompletely or inconsistent with the actual product.
Packaging Specification
Explain the packaging method and net weight, such as 25kg/bag.
⚠️ Confusing packaging unit with net weight.
Example： Product Name: Hydroxyethyl cellulose; Appearance: White powder; Composition and Content: Hydroxyethyl cellulose ≥95%, moisture ≤5%; Use: Used for thickening water-based coatings; Brand: No brand; Model: HEC-100; Packaging Specification: 25kg/bag.
Common Mistakes：
Confusing cellulose ethers with cellulose esters, such as mistakenly classifying cellulose acetate under 391239.
Failure to distinguish between primary forms and non-primary forms, such as films or rods already made should be classified under other headings.
Neglecting key indicators such as degree of substitution, leading to incorrect subheading classification.
🎯 Classification Logic
Core basis for classification: The commodity is cellulose ether in primary forms and is not specifically named in 391231 to 391238. It is necessary to confirm that the chemical structure is an ether, not an ester; the physical form is primary form (such as powder, granules, liquid, etc.); and exclude products that have been modified or mixed with other substances. 391231 Carboxymethyl cellulose and its salts: Carboxymethyl cellulose is a specifically named cellulose ether and should be classified under 391231, not 391239. 391239 Other cellulose ethers in primary forms: This code is a residual subheading, used only when not specifically named. 391211 Non-plasticized cellulose acetate: Cellulose acetate is a cellulose ester, not an ether, and should be classified under 391211. 391220 Cellulose nitrate: Cellulose nitrate is an ester and typically contains nitrogen, classified under 391220. 391290 Other cellulose and its chemical derivatives in primary forms: 391290 covers cellulose derivatives that are neither ethers nor esters, such as regenerated cellulose. Is it in primary form (powder, granules, liquid, etc.)? Is it a cellulose ether (not ester)? Is it not specifically named in 391231-391238? Is it not mixed or modified with other substances? Are key parameters such as degree of substitution provided?
Basis
Core basis for classification: The commodity is cellulose ether in primary forms and is not specifically named in 391231 to 391238. It is necessary to confirm that the chemical structure is an ether, not an ester; the physical form is primary form (such as powder, granules, liquid, etc.); and exclude products that have been modified or mixed with other substances.
Confused Codes：
391231 - Carboxymethyl cellulose and its salts
Carboxymethyl cellulose is a specifically named cellulose ether and should be classified under 391231, not 391239.
391239 - Other cellulose ethers in primary forms
This code is a residual subheading, used only when not specifically named.
391211 - Non-plasticized cellulose acetate
Cellulose acetate is a cellulose ester, not an ether, and should be classified under 391211.
391220 - Cellulose nitrate
Cellulose nitrate is an ester and typically contains nitrogen, classified under 391220.
391290 - Other cellulose and its chemical derivatives in primary forms
391290 covers cellulose derivatives that are neither ethers nor esters, such as regenerated cellulose.
Self-Check：
✓ Is it in primary form (powder, granules, liquid, etc.)?
✓ Is it a cellulose ether (not ester)?
✓ Is it not specifically named in 391231-391238?
✓ Is it not mixed or modified with other substances?
✓ Are key parameters such as degree of substitution provided?
❓ FAQ
How to determine whether a cellulose ether should be classified under 391239? First confirm that the commodity is cellulose ether in primary form and is not specifically named in 391231 to 391238. If it is a specific variety such as carboxymethyl cellulose or hydroxypropyl cellulose, it should be classified under the corresponding subheading; otherwise, classify under 391239. What is the difference in classification between cellulose ethers and cellulose esters? Cellulose ethers are cellulose with hydroxyl groups etherified, such as hydroxyethyl cellulose; cellulose esters are esterified, such as cellulose acetate. Esters are classified under 391211 or 391220, while ethers are classified under 391231-391239. How to fill in composition and content during declaration? Indicate the chemical name and content of the main components, such as hydroxyethyl cellulose ≥95%, and provide indicators such as degree of substitution, moisture, ash content, to facilitate accurate customs classification. If cellulose ether has been formulated into a solution, can it still be classified under 391239? If the solution is in primary form and no other substances have been added, it can still be classified under 391239; but if it has been made into finished products such as coatings or adhesives, it should be classified under the corresponding heading. How to inquire about the import tariff rate for 391239? You can log on to the website of the General Administration of Customs of China or use the 'Import and Export Tariff of the People's Republic of China' to inquire about the latest tariff rate, or consult a customs broker or use the customs advance classification service. Does the packaging specification of cellulose ether affect classification? Packaging specifications generally do not affect classification, but if the packaging form indicates that it has been made into retail packaging or finished products, it may affect classification. Primary forms generally refer to powders, granules, etc., not in retail packaging. How to avoid customs risks caused by classification errors? It is recommended to provide detailed product composition, production process, use, and other information, apply for advance classification if necessary, and retain relevant technical documents for reference. How to distinguish 391239 from other cellulose derivative codes? Mainly look at the chemical structure: ethers are classified under 391231-391239, esters under 391211-391220, and other derivatives such as regenerated cellulose under 391290.
Q: How to determine whether a cellulose ether should be classified under 391239?
A: First confirm that the commodity is cellulose ether in primary form and is not specifically named in 391231 to 391238. If it is a specific variety such as carboxymethyl cellulose or hydroxypropyl cellulose, it should be classified under the corresponding subheading; otherwise, classify under 391239.
Q: What is the difference in classification between cellulose ethers and cellulose esters?
A: Cellulose ethers are cellulose with hydroxyl groups etherified, such as hydroxyethyl cellulose; cellulose esters are esterified, such as cellulose acetate. Esters are classified under 391211 or 391220, while ethers are classified under 391231-391239.
Q: How to fill in composition and content during declaration?
A: Indicate the chemical name and content of the main components, such as hydroxyethyl cellulose ≥95%, and provide indicators such as degree of substitution, moisture, ash content, to facilitate accurate customs classification.
Q: If cellulose ether has been formulated into a solution, can it still be classified under 391239?
A: If the solution is in primary form and no other substances have been added, it can still be classified under 391239; but if it has been made into finished products such as coatings or adhesives, it should be classified under the corresponding heading.
Q: How to inquire about the import tariff rate for 391239?
A: You can log on to the website of the General Administration of Customs of China or use the 'Import and Export Tariff of the People's Republic of China' to inquire about the latest tariff rate, or consult a customs broker or use the customs advance classification service.
Q: Does the packaging specification of cellulose ether affect classification?
A: Packaging specifications generally do not affect classification, but if the packaging form indicates that it has been made into retail packaging or finished products, it may affect classification. Primary forms generally refer to powders, granules, etc., not in retail packaging.
Q: How to avoid customs risks caused by classification errors?
A: It is recommended to provide detailed product composition, production process, use, and other information, apply for advance classification if necessary, and retain relevant technical documents for reference.
Q: How to distinguish 391239 from other cellulose derivative codes?
A: Mainly look at the chemical structure: ethers are classified under 391231-391239, esters under 391211-391220, and other derivatives such as regenerated cellulose under 391290.
⚠️ 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.