HS code · 4-digit heading
HS Code 38.25 – Residual products of the chemical or allied industries, not elsewhere specified or included; municipal waste; sewage sludge; other residual products.
What HS 38.25 covers
Heading 3825 is dedicated to residual products of the chemical or allied industries, alongside municipal waste, sewage sludge, and other miscellaneous residual products not specified elsewhere. This heading acts as a crucial classification for waste streams and by-products, particularly those from chemical processes, that are either destined for disposal, treatment, or potential recovery, but are not yet refined into usable raw materials with specific HS classifications. Its scope explicitly includes mixed municipal waste and sewage sludge, highlighting its role in managing environmental waste streams. The 'not elsewhere specified or included' clause is fundamental, ensuring that only residual products without more specific HS classifications are placed here. This classification is increasingly important for trade compliance due to growing global environmental regulations, such as the Basel Convention on the control of transboundary movements of hazardous wastes and their disposal. Accurate classification ensures compliance with international waste shipment rules, permits, and tracking requirements, preventing illegal waste trade and environmental dumping. This heading reflects a global shift towards responsible waste management and the circular economy, even for materials that currently lack direct economic value as primary raw materials, emphasizing their 'residual' status within Section VI.
- Covers
- Chemical waste (unspecified mixtures)
- Industrial sludge (non-hazardous)
- Municipal waste (mixed, non-recyclable)
- Sewage sludge (treated or untreated)
- Spent catalysts (not containing precious metals, for disposal)
- Pharmaceutical waste (non-specific, non-hazardous)
- Photographic waste
- Waste acids (mixed, for disposal)
- Waste alkalis (mixed, for disposal)
- Ash and residues from chemical processes
- Mixed waste solvents (unrecoverable)
- Waste dyes and pigments (mixtures)
- Laboratory waste (mixed, for disposal)
- Contaminated soils (for treatment/disposal)
- Certain hazardous waste streams (as per national regulations)
- Spent activated carbon (for disposal)
- Waste oils (non-petroleum, not elsewhere specified)
- Mixed plastic waste (for disposal, not recycling)
- Mixed rubber waste (for disposal, not recycling)
- Discarded electronic components (mixed, for disposal).
- Examples
A European waste management company exports treated sewage sludge from the Netherlands to agricultural regions in France for use as fertilizer, transported by specialized trucks or river barges. In another scenario, a US chemical plant ships a specific industrial process residue, classified as non-hazardous chemical waste, to a specialized treatment facility in Canada for safe disposal, typically moved by truck. An Asian country imports mixed municipal solid waste from a neighboring island nation for energy recovery at a waste-to-energy plant, utilizing dedicated cargo ships. Furthermore, a Brazilian refinery exports spent catalysts, after initial recovery of valuable metals, to a specialized waste processing facility in Germany for further treatment and safe disposal, using ocean freight. Finally, a Japanese electronics manufacturer disposes of mixed electronic waste (not suitable for immediate recycling) to a processing plant in Southeast Asia under strict environmental protocols.
Subheadings under 38.25 9
Codes often confused with 38.25
Common mistake. A frequent misclassification occurs when waste products that have a clear economic value as secondary raw materials (e.g., metal scrap, specific plastic regrinds) are incorrectly placed here instead of more specific headings (e.g., Chapter 72 for iron and steel scrap, Chapter 39 for plastic waste for recycling). Another common error is failing to distinguish between hazardous and non-hazardous waste, as hazardous waste often falls under more stringent national and international regulations, even if its chemical nature might initially suggest 3825. Confusion also arises with residues from petroleum refining (2713) or specific types of ash and slag (2620), which have their own classifications. Proper chemical analysis and understanding of the waste's end-use (disposal vs. recycling) are crucial to avoid misclassification and non-compliance with environmental regulations.
Top exporters and importers of HS code 3825, 2025
In 2025, the largest exporter of HS code 3825 in UN Comtrade data was the United Kingdom, with 20% of world exports; the largest importer in UN Comtrade data was Japan, with 15% of world imports. Countries that did not report 2025 data are estimated from partner records, which can understate them.
Top exporters 2025 · share of world exports
- 1 United Kingdom $57M 20% of world exports
- 2 United States $55M 19% of world exports
- 3 Germany $23M 8.0% of world exports
World total: $290M Reported figures on UN Comtrade ↗
Top importers 2025 · share of world imports
- 1 Japan $44M 15% of world imports
- 2 Mexico $33M 11% of world imports
- 3 Sweden $31M 11% of world imports
World total: $296M Reported figures on UN Comtrade ↗
How these figures are built
109 countries reported 2025 trade to UN Comtrade in HS 2022, and their own totals are used. Countries that did not report are estimated from what other countries recorded trading with them. Those estimates miss trade with other non-reporting countries, so they can be low, and a non-reporting country can rank higher than shown or be missing from the list. World totals add both and leave out trade between two non-reporting countries. Figures are in current US dollars; reported imports are mostly valued CIF and exports FOB, and exports include re-exports. The UN Comtrade links show the underlying records; they can also list a few reporters left out here (regional groups and older HS editions).
Source: UN Comtrade (United Nations Statistics Division), 2025 annual data.
Questions about HS 38.25
What is HS code 3825?
HS code 3825 is a 4-digit heading in the Harmonized System that covers: Residual products of the chemical or allied industries, not elsewhere specified or included; municipal waste; sewage sludge; other residual products.. Heading 3825 is dedicated to residual products of the chemical or allied industries, alongside municipal waste, sewage sludge, and other miscellaneous residual products not specified elsewhere. This heading acts as a crucial classification for waste streams and by-products, particularly those from chemical processes, that are either destined for disposal, treatment, or potential recovery, but are not yet refined into usable raw materials with specific HS classifications. Its scope explicitly includes mixed municipal waste and sewage sludge, highlighting its role in managing environmental waste streams. The 'not elsewhere specified or included' clause is fundamental, ensuring that only residual products without more specific HS classifications are placed here. This classification is increasingly important for trade compliance due to growing global environmental regulations, such as the Basel Convention on the control of transboundary movements of hazardous wastes and their disposal. Accurate classification ensures compliance with international waste shipment rules, permits, and tracking requirements, preventing illegal waste trade and environmental dumping. This heading reflects a global shift towards responsible waste management and the circular economy, even for materials that currently lack direct economic value as primary raw materials, emphasizing their 'residual' status within Section VI.
What products fall under HS code 3825?
Chemical waste (unspecified mixtures), industrial sludge (non-hazardous), municipal waste (mixed, non-recyclable), sewage sludge (treated or untreated), spent catalysts (not containing precious metals, for disposal), pharmaceutical waste (non-specific, non-hazardous), photographic waste, waste acids (mixed, for disposal), waste alkalis (mixed, for disposal), ash and residues from chemical processes, mixed waste solvents (unrecoverable), waste dyes and pigments (mixtures), laboratory waste (mixed, for disposal), contaminated soils (for treatment/disposal), certain hazardous waste streams (as per national regulations), spent activated carbon (for disposal), waste oils (non-petroleum, not elsewhere specified), mixed plastic waste (for disposal, not recycling), mixed rubber waste (for disposal, not recycling), discarded electronic components (mixed, for disposal).
What are common misclassifications for HS code 3825?
A frequent misclassification occurs when waste products that have a clear economic value as secondary raw materials (e.g., metal scrap, specific plastic regrinds) are incorrectly placed here instead of more specific headings (e.g., Chapter 72 for iron and steel scrap, Chapter 39 for plastic waste for recycling). Another common error is failing to distinguish between hazardous and non-hazardous waste, as hazardous waste often falls under more stringent national and international regulations, even if its chemical nature might initially suggest 3825. Confusion also arises with residues from petroleum refining (2713) or specific types of ash and slag (2620), which have their own classifications. Proper chemical analysis and understanding of the waste's end-use (disposal vs. recycling) are crucial to avoid misclassification and non-compliance with environmental regulations.
Which countries are the top exporters of goods under HS code 3825?
In 2025, the top exporters of HS code 3825 in UN Comtrade data were the United Kingdom ($57M, 20% of world exports), the United States ($55M) and Germany ($23M). World exports came to about $290M, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Countries that did not report 2025 data are estimated from partner records, which can understate them.
Which countries are the top importers of goods under HS code 3825?
In 2025, the top importers of HS code 3825 in UN Comtrade data were Japan ($44M, 15% of world imports), Mexico ($33M) and Sweden ($31M). World imports came to about $296M, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Countries that did not report 2025 data are estimated from partner records, which can understate them.
How is HS code 3825 structured?
HS code 3825 is a 4-digit heading under Chapter 38 of the Harmonized System. The first 2 digits (38) identify the chapter, and digits 3-4 (25) specify the heading. This code contains multiple 6-digit subheadings for precise product classification.