HS Code 39.04 – Polymers of vinyl chloride or of other halogenated olefins, in primary forms

HS code 3904 is a 4-digit heading in the Harmonized System that covers: Polymers of vinyl chloride or of other halogenated olefins, in primary forms. Heading 3904 covers "Polymers of vinyl chloride or of other halogenated olefins, in primary forms." This critical classification includes one of the most widely used plastics globally: Polyvinyl chloride (PVC), along with its copolymers and other halogenated olefin polymers like polytetrafluoroethylene (PTFE) and polyvinylidene fluoride (PVDF). The defining characteristic for inclusion here is that these polymers must be in "primary forms," meaning they are raw materials such as powders, granules, liquids, pastes, blocks, or lumps, intended for further processing. This explicitly excludes semi-finished products (like sheets, films, or pipes, which fall under 3918-3926) or finished articles. This distinction is paramount for trade compliance, as it dictates tariff rates, import/export regulations, and documentation requirements. PVC and other halogenated polymers are prized for their durability, chemical resistance, flame retardancy, and versatility, making them indispensable in construction, medical devices, electrical insulation, and automotive industries. Their historical development and widespread adoption have made them cornerstones of the modern materials economy. As a core component of Chapter 39, "Plastics and articles thereof," this heading provides the fundamental building blocks for a vast array of high-performance plastic products, underscoring its significance for global trade and manufacturing supply chains.

Polyvinyl chloride (PVC) resin K-value 67, suspension PVC powder, emulsion PVC paste, chlorinated polyvinyl chloride (CPVC) pellets, vinyl chloride-vinyl acetate copolymers, polyvinylidene chloride (PVDC) resin, polytetrafluoroethylene (PTFE) powder (Teflon), polyvinyl fluoride (PVF) granules, fluorinated ethylene propylene (FEP) resin, perfluoroalkoxy (PFA) resin, ethylene tetrafluoroethylene (ETFE) copolymer, polychlorotrifluoroethylene (PCTFE) resin, polyvinylidene fluoride (PVDF) pellets, vinyl chloride-ethylene copolymers, vinyl chloride-propylene copolymers, PVC plastisols (in primary forms), rigid PVC compounds, flexible PVC compounds, PVC micropowder, PVC paste resin, recycled PVC pellets.

A frequent misclassification arises when distinguishing between primary forms and semi-finished products. For instance, PVC sheets, films, or profiles are often incorrectly classified under 3904 instead of headings like 3920 or 3921. Another common error involves complex copolymers; if vinyl chloride is a minor component, traders might mistakenly classify it under other polymer headings (e.g., 3905 for vinyl acetate copolymers if vinyl acetate predominates). Similarly, the specific type of halogenated olefin (e.g., PTFE vs. PVDF) must be precisely identified, as subtle differences can impact sub-heading classification. Accurate chemical analysis and adherence to the "primary forms" definition are crucial to avoid customs penalties and ensure compliance.

In 2025, the top exporters of HS code 3904 in UN Comtrade data were China ($3.9B, 20% of world exports), the United States ($3.9B) and Germany ($1.7B). World exports came to about $20.0B, 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.

In 2025, the top importers of HS code 3904 in UN Comtrade data were India ($2.8B, 13% of world imports), Germany ($1.2B) and the United States ($1.1B). World imports came to about $21.1B, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Vietnam did not report 2025 data, and its estimate from partner records misses its trade with other countries that did not report: in 2024 that was 23% of its imports here ($227M, CEPII BACI), so it may also belong among the top importers.

HS code 3904 is a 4-digit heading under Chapter 39 of the Harmonized System. The first 2 digits (39) identify the chapter, and digits 3-4 (04) specify the heading. This code contains multiple 6-digit subheadings for precise product classification.