Product classification

HS code for PU foam panels: 3921.13

Plastics, plates, sheets, film, foil and strip, of polyurethanes, cellular.

Classification of PU foam panels under HS 3921.13

Polyurethane (PU) foam panels are classified under HS code 392113. This classification is determined by the material's chemical nature and its physical structure. Chapter 39 covers plastics, and heading 3921 is used for other plates, sheets, film, foil, and strip of plastics. The subheading 392113 specifically identifies products made of polyurethanes that are cellular. Cellular plastics are those that contain numerous cells (either open, closed, or both) distributed throughout the mass, which is the defining characteristic of foam. These panels are typically used for thermal insulation in buildings, refrigeration units, or as structural components in composite panels. The classification requires that the product remains in a relatively simple form (plates or sheets) and has not been further worked into a specific finished article classified elsewhere. The cellular nature of the polyurethane is the primary factor that distinguishes this code from non-cellular polyurethane sheets.

Covers
  • Rigid polyurethane insulation boards
  • Flexible polyurethane foam sheets
  • Cellular PU panels for cold storage construction
  • Polyurethane foam strips for industrial sealing
  • Acoustic PU foam panels in sheet form
Also under 3921.13
  • BASF Elastopur
  • Covestro Baydur
  • Dow VORANOL
  • Recticel (various foams)
  • Kingspan (insulation panels)

Codes often confused with 3921.13

Common mistake. PU foam panels are often confused with HS code 392190, which is a residual category for other plastics. However, because polyurethanes have a specific subheading (392113), the specific code must take precedence. Another common error is using 9404 for foam panels intended for mattresses; if the panels are imported as raw material sheets rather than finished mattress supports, 392113 is the correct classification. Furthermore, non-cellular PU sheets should be classified under 392099 or 392190 depending on their reinforcement.

3921.90Plastics; plates, sheets, film, foil and strip, other than cellular94.04Mattress supports; articles of bedding (e.g. mattresses, quilts, eiderdowns, cushions pouffes and pillows), fitted with springs or stuffed, whether or not covered3920.99Plastics; plates, sheets, film, foil and strip (not self-adhesive), of plastics n.e.c. in heading no. 3920, non-cellular and not reinforced, laminated, supported or similarly combined with other materials

Top exporters and importers of HS 392113 (the code used for PU foam panels), 2025

In 2025, the largest exporter of HS 392113 (the code used for PU foam panels) in UN Comtrade data was the United States, with 14% of world exports; the largest importer in UN Comtrade data was Mexico, with 9.8% 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 392113, not only PU foam panels.

Top exporters 2025 · share of world exports

  1. 1 United States $708M
  2. 2 China $704M
  3. 3 Germany $552M

World total: $5.0B Reported figures on UN Comtrade ↗

Top importers 2025 · share of world imports

  1. 1 Mexico $470M
  2. 2 United States $318M
  3. 3 Germany $263M

World total: $4.8B 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.

Brazil NCM codes for PU foam panels

Brazil splits HS 3921.13 into 2 NCM codes. Pick the one that matches your product:

  • 3921.13.10Open-cell polyester polyurethane foam sheets
  • 3921.13.90Other cellular polyurethane plates and sheets

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

Questions about PU foam panels

What is the HS code for PU foam panels?

The HS code for PU foam panels is 392113 (Plastics; plates, sheets, film, foil and strip, of polyurethanes, cellular). The HS code for cellular polyurethane plates, sheets, and panels is 392113.

How do I classify PU foam panels for customs?

PU foam panels is classified under HS code 392113 — Plastics; plates, sheets, film, foil and strip, of polyurethanes, cellular. This is a 6-digit subheading level code.

Does this code include panels with metal facings?

No, if the panel is a sandwich panel with metal skins and a PU core, it is typically classified under 7308 or 7610 depending on the metal used.

Which countries are the top exporters of PU foam panels (HS 392113)?

In 2025, the top exporters of HS 392113 (the code used for PU foam panels) in UN Comtrade data were the United States ($708M, 14% of world exports), China ($704M) and Germany ($552M). World exports came to about $5.0B, 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.

Which countries are the top importers of PU foam panels (HS 392113)?

In 2025, the top importers of HS 392113 (the code used for PU foam panels) in UN Comtrade data were Mexico ($470M, 9.8% of world imports), the United States ($318M) and Germany ($263M). World imports came to about $4.8B, 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 PU foam panels the same in all countries?

The base HS code 392113 for PU foam panels 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 PU foam panels in Brazil?

Brazil splits HS 392113 into 2 NCM codes, so the right one for PU foam panels depends on the product's details: 3921.13.10 (Open-cell polyester polyurethane foam sheets), 3921.13.90 (Other cellular polyurethane plates and sheets).