Product classification

HS code for Flexible PVC: 3904.22

Vinyl chloride, other halogenated olefin polymers, plasticised poly(vinyl chloride), in primary forms, mixed with other substances.

Classification of flexible PVC under HS 3904.22

Flexible PVC in primary forms is classified under HS code 3904.22. This code specifically covers poly(vinyl chloride) that has been plasticized. Plasticizers are additives that increase the fluidity or plasticity of a material, making the resulting PVC flexible rather than rigid. According to the Chapter 39 notes of the Harmonized System, primary forms include liquids, pastes, blocks, irregular lumps, powders, granules, and flakes. The distinction between 3904.21 (non-plasticized) and 3904.22 (plasticized) is critical for regulatory compliance. If the PVC resin has been mixed with plasticizers to a degree that it is intended for flexible applications like cable sheathing, flooring, or flexible tubing production, it must be declared under 3904.22. This classification does not include finished articles like sheets or pipes, but rather the raw material used in manufacturing. The presence of plasticizers must be verifiable through chemical analysis if challenged by customs authorities, as it significantly impacts the material's physical properties and end-use.

Covers
  • Plasticized PVC granules for extrusion
  • Flexible PVC resin compounds
  • PVC pellets for electrical cable insulation
  • Liquid PVC plastisols for dipping
  • Plasticized vinyl chloride powders
  • Soft PVC compounds for footwear soles
Also under 3904.22
  • Teknor Apex PVC compounds
  • AlphaGary PVC compounds
  • Aurora Plastics PVC compounds
  • PolyOne (Avient) PVC compounds
  • Benvic PVC compounds

Codes often confused with 3904.22

Common mistake. A common error is classifying flexible PVC under 3904.10, which is for non-plasticized PVC in its pure form. Another frequent misclassification is 3904.21, which covers other mixed PVC that is not plasticized. Furthermore, if the PVC is already formed into tubes or hoses, it should be classified under heading 3917, and if it is in plates or sheets, heading 3920 or 3921 is more appropriate. Importers must also ensure they do not use 3904.30 or 3904.40, which are reserved for vinyl chloride copolymers.

3904.10Vinyl chloride, other halogenated olefin polymers; poly(vinyl chloride), not mixed with any other substances, in primary forms3904.21Vinyl chloride, other halogenated olefin polymers; non-plasticised poly(vinyl chloride), in primary forms, mixed with other substances39.17Tubes, pipes and hoses and fittings thereof (for example, joints, elbows, flanges), of plastics39.20Plastics; plates, sheets, film, foil and strip (not self-adhesive); non-cellular and not reinforced, laminated, supported or similarly combined with other materials, n.e.c. in chapter 3939.21Plastic plates, sheets, film, foil and strip n.e.c. in chapter 393904.30Vinyl chloride, other halogenated olefin polymers; vinyl chloride-vinyl acetate copolymers, in primary forms3904.40Vinyl chloride, other halogenated olefin polymers; vinyl chloride copolymers, in primary forms n.e.c. in heading no. 3904

Top exporters and importers of HS 390422 (the code used for flexible PVC), 2025

In 2025, the largest exporter of HS 390422 (the code used for flexible PVC) in UN Comtrade data was China, with 22% of world exports; the largest importer in UN Comtrade data was Mexico, with 11% of world imports. Countries that did not report 2025 data are estimated from partner records, which can understate them.

Figures cover everything classified under HS 390422, not only flexible PVC.

Top exporters 2025 · share of world exports

  1. 1 China $506M
  2. 2 United States $426M
  3. 3 Germany $219M

World total: $2.3B Reported figures on UN Comtrade ↗

Top importers 2025 · share of world imports

  1. 1 Mexico $234M
  2. 2 Vietnam* ~$134M
  3. 3 Germany $98M

World total: $2.2B 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 marked * did not, so their figures add up what other countries recorded trading with them, and their exports are valued at buyers' CIF prices. 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.

Brazil NCM code for flexible PVC

Brazil classifies flexible PVC under NCM 3904.22.00: HS 3904.22 with 00 added.

Source: Siscomex NCM table, updated Oct 2026. The Portuguese text on each NCM page is the official one.

Questions about flexible PVC

What is the HS code for Flexible PVC?

The HS code for Flexible PVC is 390422 (Vinyl chloride, other halogenated olefin polymers; plasticised poly(vinyl chloride), in primary forms, mixed with other substances). The HS code for plasticised poly(vinyl chloride) in primary forms is 3904.22.

How do I classify Flexible PVC for customs?

Flexible PVC is classified under HS code 390422 — Vinyl chloride, other halogenated olefin polymers; plasticised poly(vinyl chloride), in primary forms, mixed with other substances. This is a 6-digit subheading level code.

What defines a primary form in this classification?

Primary forms refer to raw materials like granules, pellets, powders, or liquids used for further manufacturing, not finished plastic goods like pipes or sheets.

Which countries are the top exporters of flexible PVC (HS 390422)?

In 2025, the top exporters of HS 390422 (the code used for flexible PVC) in UN Comtrade data were China ($506M, 22% of world exports), the United States ($426M) and Germany ($219M). World exports came to about $2.3B, 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 flexible PVC (HS 390422)?

In 2025, the top importers of HS 390422 (the code used for flexible PVC) in UN Comtrade data were Mexico ($234M, 11% of world imports), Vietnam (about $134M) and Germany ($98M). World imports came to about $2.2B, 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.

Is the HS code for Flexible PVC the same in all countries?

The base HS code 390422 for Flexible PVC is internationally standardized for the first 6 digits across 200+ countries. Individual countries may add additional digits for national tariff lines and specific classifications.

What is the NCM code for flexible PVC in Brazil?

In Brazil, flexible PVC (HS 390422) is classified under NCM 3904.22.00.