Trade & Compliance Insight

Importing Plastics & Polymers: Complete HTS Classification, Section 301 & Raw Material Duty Guide 2026

By PoliteDraft Editorial Team Published: 2026-06-23

Plastics: Low Duties But High Section 301 Exposure

Plastic raw materials (polymers in primary forms) enter the US at very low MFN rates — typically Free to 6.5%. But finished plastic products face Section 301 tariffs at 25% when sourced from China. The classification line between 'raw material' (Chapter 39, low duty) and 'article of plastic' (also Chapter 39, but subject to S301) is critical and frequently contested.

Key HTS Codes

ProductHTSMFNS301
Polyethylene (PE) — primary form3901.10Free-6.5%Excluded (List 4A)
PVC — primary form3904.10Free-6.5%Excluded
Plastic film/sheets (non-cellular)3920.10Free-6.5%25% (List 3)
Plastic containers/bottles3923.303%25% (List 3)
Plastic household articles3924.103.4%25% (List 3)

The Primary Form vs Article Distinction

The most valuable classification decision for plastic importers: is the product in primary form (pellets, granules, flakes, powder, liquid resin — HTS 3901-3914, MFN Free-6.5%, mostly S301-excluded) or is it a manufactured article (film, sheet, container, household item — HTS 3916-3926, MFN Free-6.5%, S301 25%)? The distinction: has the polymer undergone processing beyond what is necessary for transport? Cutting pellets into smaller pellets = still primary form. Extruding into film = article. Importers who import pre-production plastic pellets pay almost nothing. Importers who import finished plastic products from China pay 28-31% effective duty. The tariff engineering opportunity: import Chinese polymer in primary form (excluded from S301), manufacture the article in Mexico or US (no S301), and claim USMCA preference.

Disclaimer: Verify HTS codes and Section 301 applicability with a licensed customs broker.

Frequently Asked Questions

Are plastic raw materials from China subject to Section 301?

Most plastic polymers in primary form (pellets, granules, powder) are excluded from Section 301 under List 4A. However, finished plastic articles (film, containers, household goods) ARE subject to 25% additional duty under List 3. The classification distinction between primary form and article is critical.

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References & Official Sources

  • US International Trade Commission (USITC). Harmonized Tariff Schedule — 2026 Revision 19. hts.usitc.gov
  • US Customs and Border Protection (CBP). Informed Compliance Publications & ACE Entry Guidance. cbp.gov
  • Office of the US Trade Representative (USTR). Section 301 Investigation & Federal Register Notices. ustr.gov
  • World Trade Organization (WTO). Tariff Data & Trade Statistics. wto.org
  • International Chamber of Commerce (ICC). Incoterms & Trade Finance Rules. iccwbo.org
  • IRS. Form W-8BEN Instructions & Publication 515. irs.gov