Chemicals & Materials Chemical import compliance
Give one resin one answer everywhere.
Fourteen entities, one resin, and a formula R&D will not share. GingerOS keeps one classification record per product, with the composition facts that decide it, for every importer of record.
GingerOS- HTS
3907.30.0000- Origin
- Japan
- Imported by
- Coatings entity, US
- Entry
- 10/06/2026
Duty stackTotal duty12.5%
- Base duty (MFN)
6.1% - Section 301, forced labor (top-up to 12.5%)
9903.05.496.4% - Pharmaceutical-use exemptionOnly for pharmaceutical use; this lot goes to coatings
9903.05.89Not applied - Section 122 surchargeCovered entries through July 23, 2026
9903.03.01Expired
Plus MPF 0.3464%, and HMF 0.125% by ocean
Why Epoxide resin is 3907.30 at 6.1%. Japan's forced-labor line tops it up to a combined 12.5%. The pharmaceutical-use exemption does not apply, because this lot goes to coatings.
A GingerOS part record with demo data for chemicals & materials: Epoxide resin, liquid, HTS 3907.30.0000, from Japan. Each duty layer is listed with its rate or exemption, for a total duty of 12.5%.
What tariffs hit imported chemicals now?
The base rate plus the forced-labor 301, topped up for Japan and the EU, exempt only for pharmaceutical use.
Since July 24, 2026 most imported chemicals pay a Section 301 forced-labor duty: Japanese goods are topped up to a combined 12.5%, EU goods to 10%, and Chinese goods add 12.5% on top of their China-list rate. Listed chemicals are exempt only when they are for pharmaceutical use, so end-use records now decide the entry. Patented-drug ingredients pay the Section 232 pharmaceutical tariff, in force for all companies since September 29, 2026, and new antidumping orders cover acrylate monomers from Taiwan and Korea.
Recent Policy UpdatesNotices that touch chemicals and resins
- Federal Register Notice91 FR 47318Forced-labor Section 301: Japan chemicals topped to 12.5%, pharma use only exempt
Listed Ch. 28, 29, 38 and 39 chemicals escape only when for pharmaceutical use (9903.05.89), so end-use records decide the entry.
9903.05.49, 9903.05.31; exemption 9903.05.89Read the explainer - Presidential ProclamationProclamation 11020Section 232 pharma tariff covers APIs and key starting materials; Japan capped at 15%
Active ingredients for patented drugs pay 100% combined by default, 15% for Japan and the EU; excipients are not covered and drawback is available.
Listed Ch. 29, 30 lines; 9903.04.60 to .70Read the explainer - Federal Register Notice91 FR 11951New AD/CVD orders on acrylate monomers and epoxy-acrylate oligomers from Taiwan
A Korea order followed on July 28, 2026 (91 FR 47214). The written scope, not the HTS code, decides coverage, and blends of 20% or more are in.
2916.12, 2916.14, 3824.99, 3907.29, 3907.30 - Federal Register Notice91 FR 55083Citric acid from India: preliminary antidumping cash deposits now required
India's preliminary AD rate is 100.21% for all others; preliminary CVD deposits apply to India and Canada since June 26.
2918.14, 2918.15
A Compliance Radar feed of 4 recent policy updates that touch chemicals & materials, each with its source, reference and effective date.
Is this a compound or a preparation?
A single acrylate with a stabilizer stays in Chapter 29; an added oligomer or photoinitiator moves it to 3824.
Trimethylolpropane triacrylate from our Japan parent, shipped pre-blended for UV coatings. The full formula is confidential.
Ginger asksBesides the monomer, what is in the drum by weight band: only impurities and a storage inhibitor, or added oligomer, photoinitiator or solvent?
About 30% epoxy-acrylate oligomer and 4% photoinitiator, added for UV curing.
3824.99.2900HTS rate 6.5%
Chemical preparations with 5% or more aromatic substances: other
From Japan: forced-labor 301 tops up to 12.5%; from China, List 3 25% plus 12.5%
2916.12.5050HTS rate 3.7%
Esters of acrylic acid: other
Only if it ships as the compound, with no more than a needed inhibitor
Deciding rule Chapter 29 Note 1 keeps a compound in Chapter 29 only with impurities, a transport solvent or a needed stabilizer; Degussa Corp. v. United States, 508 F.3d 1044 (Fed. Cir. 2007), moved a deliberately modified product to 3824.
A Classification Researcher conversation with demo data. Ginger asks: Besides the monomer, what is in the drum by weight band: only impurities and a storage inhibitor, or added oligomer, photoinitiator or solvent? From the answer it picks HTS 3824.99.2900 over 2916.12.5050.
What does this mean across fourteen entities?
One product, one record: a conflicting code, a new end use or a new order each opens a recheck.
GingerOSDo our fourteen entities give one answer for one resin, and how do we classify without the formula?
Open rechecks3
3907.30.00003 of 14 entitiesTwo entities filed different codesReconcile to one code, with the reasoningRuns in Classification ResearcherReview3824.99.2900Coatings entity, USR&D will not share the formulaAsk for weight bands, not the recipeRuns in Classification ResearcherNeeds answer3907.30.0000Pharma solutions entity, USNew customer making pharmaceuticalsKeep the end-use record with the partRuns in Parts LibraryNeeds answerA GingerOS window with demo data. Someone asks: "Do our fourteen entities give one answer for one resin, and how do we classify without the formula?" It lists 3 open rechecks, each with the part, HTS code, trigger, tool and status.
Questions about chemical compliance
What duty does an epoxy resin imported from Japan pay in October 2026?
Most Japanese resins pay a combined 12.5%. Since July 24, 2026, heading 9903.05.49 tops any Japanese good with a Column 1 rate below 12.5% up to that total, so epoxide resin in 3907.30.00 at 6.1% pays 6.4 points of Section 301 forced-labor duty (91 FR 47318). MPF of 0.3464% and ocean HMF of 0.125% apply, and AD or CVD orders apply separately where in scope.
Are chemicals exempt from the Section 301 forced-labor duty?
Only listed chemicals sold for pharmaceutical use. U.S. note 52(e) exempts specified Chapter 28, 29, 38 and 39 provisions only when the article is for use in pharmaceutical applications (heading 9903.05.89), and USTR said it deliberately limited the chemical exemption to pharmaceutical applications (91 FR 47318). The same resin sold into coatings or electronics pays the duty, so end-use records decide the entry.
Does the Section 232 pharmaceutical tariff reach chemical intermediates?
Yes, when the intermediate is an active ingredient or key starting material for a patented drug and falls in a provision listed in U.S. note 40(c). Proclamation 11020 sets 100% combined by default, 15% combined for Japan, the EU, Korea and Switzerland, and zero for generics, for all companies since September 29, 2026. Excipients are not covered, and drawback is available.
How do we classify a chemical when the formula is confidential?
Classify from the composition facts that decide the heading, not the full recipe. Chapter 29 Note 1 asks whether the product is one chemically defined compound, with only impurities, a transport solvent or a needed stabilizer; deliberate additions for a specific use move it to Chapter 38, as Degussa Corp. v. United States (Fed. Cir. 2007) held. Ruling requests can mark formula data confidential (19 CFR 177.2(b)(7)).
Can our fourteen U.S. entities classify the same resin differently?
They can, but each importer of record owes reasonable care under 19 U.S.C. 1484, so conflicting codes for one product invite CBP questions. A ruling letter binds CBP only for the transaction it describes (19 CFR 177.9). One classification record per product, with its reasoning, keeps every entity on the same answer.
Which new antidumping orders affect resin and coating inputs in 2026?
Commerce issued orders on certain acrylate monomers and epoxy-acrylate oligomers from Taiwan on March 11, 2026, with AD of 130.23% and CVD of 103.43%, and an AD order on Korea on July 28, 2026, at 65.72% to 155.42% (91 FR 11951; 91 FR 47214). Scope includes blends with at least 20% of these chemicals and product processed in a third country.
Is citric acid from India or Canada subject to antidumping duty now?
Not under final orders yet, but cash deposits apply. Commerce's preliminary CVD rates are 63.88% for India and 16.50% for Canada (June 26, 2026), and its preliminary AD rate for India is 100.21% for all others, while Canada's preliminary AD result was negative (August 26, 2026). Final determinations are postponed (91 FR 38664, 38666, 55083, 55081).
