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Classifying Chemical Products: Composition Is the Starting Point

1. Why chemicals are hard

Three variables decide the classification at once: chemical composition, purity, and use or packing form.

2. The relevant chapters

Chapter 28

Inorganic chemicals, compounds of precious metals and rare earths, inorganic acids, bases and salts.

Chapter 29

Organic chemicals. Hydrocarbons, alcohols, phenols, aldehydes, ketones, acids, esters, amines.

Chapter 30

Pharmaceutical products.

Chapter 31

Fertilisers.

Chapter 32

Dyes, pigments, paints and varnishes.

Chapter 33

Essential oils, cosmetics.

Chapter 38

Miscellaneous chemical products.

3. The deciding factors

Composition determines the chapter and heading.

Purity matters where a heading sets a threshold.

Retail packing matters where a heading is defined by presentation.

Use matters where headings are use-based.

4. The 28 / 29 boundary

Inorganic in 28, organic in 29.

A frequent error is placing organic salts in chapter 28. They belong in 29 on the basis of their organic character.

Both chapters carry notes that exclude specific products. Those notes decide more cases than the heading text.

5. Dangerous goods

Certain chemicals are regulated as dangerous goods, which brings additional documentation such as safety data sheets and transport papers.

The classification and the dangerous goods assessment should be done together.

6. The common errors

Classifying by trade name when the composition differs.

Ignoring purity thresholds.

Ignoring the packing form.

Overlooking dangerous goods status.

7. A working habit

Chemical classification needs composition data.

For each product, keep a composition sheet: chemical name, CAS number, content, impurities.

That sheet supports classification and the dangerous goods determination at the same time.

8. Closing view

Chemicals are among the most technical categories in the tariff.

For anything uncertain, an advance ruling or a specialist opinion is cheaper than a correction later.

*This article is based on the notes to chapters 28 to 38 of the Harmonized System. Exporters should confirm classification with China Customs.*

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