Product classification
HS code for XPS foam: 3921.11
Plastics, plates, sheets, film, foil and strip, of polymers of styrene, cellular.
Classification of XPS foam under HS 3921.11
XPS foam, or Extruded Polystyrene foam, is classified under HS code 3921.11. This classification is governed by the material composition and the physical state of the product. Chapter 39 of the Harmonized System covers plastics and articles thereof. Heading 3921 specifically addresses other plates, sheets, film, foil, and strip of plastics. Within this heading, the code 3921.11 is reserved for products that are cellular and made from polymers of styrene. XPS is manufactured through a continuous extrusion process where the plastic resin and other ingredients are combined and then forced through a die. As the plastic exits the die, it expands and hardens into a dense, closed-cell structure. This "cellular" nature is the primary reason for its placement in the 3921.11 subheading. The closed-cell structure provides high compressive strength and superior thermal resistance, making it a staple in the construction industry for insulation. Because it is not "expanded" in a mold like EPS (Expanded Polystyrene), but rather extruded, it maintains a distinct classification profile under the styrene polymer category. The classification applies to XPS in the form of rigid boards or sheets commonly used for wall, roof, and foundation insulation.
- Covers
- Extruded polystyrene insulation boards
- XPS rigid foam sheets
- Cellular styrene polymer plates
- XPS foam underlayment
- Closed-cell polystyrene thermal insulation
- Also under 3921.11
- Dow Styrofoam (XPS)
- BASF Neopor (EPS)
- Knauf Insulation (EPS/XPS)
- Owens Corning Foamular (XPS)
- Kingspan (insulation panels)
Codes often confused with 3921.11
Common mistake. XPS foam is often confused with EPS (Expanded Polystyrene), which is also a cellular styrene polymer. While both may fall under 3921.11 in some jurisdictions, EPS in the form of raw beads is classified under 3903.11. Furthermore, if the foam is made of polyurethane rather than styrene, it must be classified under 3921.13. It is also important not to confuse these sheets with non-cellular plastic plates, which fall under heading 3920.
Top exporters and importers of HS 392111 (the code used for XPS foam), 2025
In 2025, the largest exporter of HS 392111 (the code used for XPS foam) in UN Comtrade data was Germany, with 20% of world exports; the largest importer in UN Comtrade data was Germany, with 10% 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 392111, not only XPS foam.
Top exporters 2025 ยท share of world exports
- 1 Germany $312M 20% of world exports
- 2 China $124M 7.9% of world exports
- 3 United States $117M 7.5% of world exports
World total: $1.6B Reported figures on UN Comtrade โ
Top importers 2025 ยท share of world imports
- 1 Germany $166M 10% of world imports
- 2 United States $129M 8.0% of world imports
- 3 France $91M 5.6% of world imports
World total: $1.6B Reported figures on UN Comtrade โ
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 code for XPS foam
Brazil classifies XPS foam under NCM 3921.11.00: HS 3921.11 with 00 added.
Source: Siscomex NCM table, updated Oct 2026. The Portuguese text on each NCM page is the official one.
Questions about XPS foam
What is the HS code for XPS foam?
The HS code for XPS foam is 392111 (Plastics; plates, sheets, film, foil and strip, of polymers of styrene, cellular). The HS code for XPS (Extruded Polystyrene) foam in plates or sheets is 3921.11.
How do I classify XPS foam for customs?
XPS foam is classified under HS code 392111 โ Plastics; plates, sheets, film, foil and strip, of polymers of styrene, cellular. This is a 6-digit subheading level code.
Is XPS foam classified differently if it is used for packaging?
No, the classification is based on the material (cellular styrene polymer) and form (sheets/plates), so 3921.11 remains the correct code regardless of the end-use in construction or packaging.
Which countries are the top exporters of XPS foam (HS 392111)?
In 2025, the top exporters of HS 392111 (the code used for XPS foam) in UN Comtrade data were Germany ($312M, 20% of world exports), China ($124M) and the United States ($117M). World exports came to about $1.6B, 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 XPS foam (HS 392111)?
In 2025, the top importers of HS 392111 (the code used for XPS foam) in UN Comtrade data were Germany ($166M, 10% of world imports), the United States ($129M) and France ($91M). World imports came to about $1.6B, 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 XPS foam the same in all countries?
The base HS code 392111 for XPS foam 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 XPS foam in Brazil?
In Brazil, XPS foam (HS 392111) is classified under NCM 3921.11.00.