Last Friday, Mr. Wang, an exporter of textile dyeing auxiliaries in Shaoxing, called me for the third time this month. His problem was quite typical: the "even dyeing agent" samples sent to his clients in Bangladesh failed to pass the quality inspection.Global ExpressWe arrived successfully, and the client was satisfied with the test results. However, when he ordered a 40-foot container to prepare for shipment,Maritime transportWhen the cargo volume was high, the shipping company made changes at the last minute before the deadline for order confirmation.Refuse to carry passengersThe reason is that the MSDS (Material Safety Data Sheet) shows that the product contains environmentally hazardous substances and is classified as an "ocean pollutant", while Mr. Wang declared it as "general cargo" when booking the shipping space.

As a result, not only did the shipment miss the sailing schedule, but also high demurrage and amendment fees were incurred. Mr. Wang was very frustrated: "I've been engaged in domestic trade for ten years. How could these goods, which can be easily shipped by logistics companies domestically, become dangerous goods for export?"

In theforeign tradeIn the field of chemical engineering,"Dyes" and "auxiliary agents" are the most easily confused pitfalls in customs classification and transportation appraisalThe concept of "general cargo" in China often faces a significant information gap compared to the IMDG (International Maritime Dangerous Goods Code) standards for international shipping. Today, we will thoroughly analyze the export compliance process and classification logic for such products.

I. "Identity Crisis" of Dye and Auxiliary Export: Commercial Perception vs. Customs Logic

The pain points of dyes and auxiliaries lie in the following aspects:The product names are too diverse, and the ingredients are too confusing. Salespeople are used to calling them "fixing agents" and "finishing agents", but customs and shipping companies only look at their chemical components.

The following table shows the common conflicts between corporate declarations and regulatory requirements:

II. Core Dry Goods: Customs Classification (HS Code) Practical Rules

The classification of dyes and auxiliaries is the "deep water zone" of customs affairs. The core principle is:See if it's "for coloring for someone else" or "to assist with coloring".

1. Textile dyes

Core Tax Code: 3204 Chapter (Synthetic organic coloring matter)

• Disperse Dyes
  • HS Code: 3204.1100
  • Categorization Reason: It has extremely low water solubility and is mainly used for dyeing hydrophobic fibers such as polyester.
  • Declaration Attention: It is necessary to specify the "C.I. generic name" (such as C.I. Disperse Blue 56).
• Reactive Dyes
  • HS Code: 3204.1600
  • Categorization Reason: It can react chemically with fibers to form covalent bonds, and is mainly used for cotton and linen.
  • Pitfall Avoidance Points: Many "compound dyes" (mixed types) are easily misidentified, and it is necessary to confirm whether the added non-coloring ingredients exceed the proportion required by the "standardization" standard.
• Pigments vs Dyes
  • Difference: Dyes dissolve in water/solvent; pigments are insoluble and are attached with adhesives.
  • Classification: Pigments are usually classified into 3204.17(Pigment-type coloring matter) or 3206(Inorganic pigment). Printing paste (Pigment Paste) is often misclassified as 3204 due to containing binders, but may actually belong to 3206 or 3212.

2. Textile auxiliaries

Core Tax Code: Chapter 3402 vs Chapter 3809 (This is the most easily confused)

• Surfactants
  • HS Code: 3402.42 (Non-ionic) / 3402.41 (Anionic)
  • Typical Products: Concentrated detergent, penetrating agent, washing agent, and leveling agent.
  • Categorization Reason: The main functions of such additives are "cleaning, wetting, and emulsifying", and they meet the definition of surfactants in Chapter 34 (reducing surface tension).
• Finishing Agents/Post-processing Agents
  • HS Code: 3809.9100 (For textile industry use)
  • Typical Products: Softeners, waterproofing agents, color-fixing agents, and stiffening agents.
  • Categorization Reason: These products are mainly used to "change the feel, appearance, or provide special functions", and they do not fall under the category of detergents in 3402.
  • Determination of the penalty fee standard: If a product has both washing and softening functions, it is usually classified according to its "main function". If the main purpose is softening, it is classified under code 3809; if the main purpose is washing, it is classified under code 3402.

III. Standard Procedures for the Entire Export Process

Don't wait until the customs broker asks you for the HS code before you start looking for the information. Compliance must be proactive.

Step 1: Conduct a comprehensive review of the MSDS document

• Action: Obtain the MSDS provided by the factory (it must be in English or with an English-Chinese bilingual version).
• Checkpoint:
  • Section 3 (Ingredients): Confirm whether there are solvents (such as methanol and isopropanol) listed in the Catalogue of Hazardous Chemicals.
  • Section 14 (運(yùn)輸)： Check if there is UN Number (UN Number) and Class (Hazard Class). Only if "Not Regulated" can it be booked as general cargo.
  • Section 9 (Physical and Chemical Properties): Check Flash Point (閃點(diǎn))If the closed-cup flash point is ≤ 60℃, it must be handled as a Class 3 dangerous good.

Step 2: Transportation Inspection Certificate

• Action: Even if the MSDS indicates that the goods are non-hazardous, shipping companies usually require a "Cargo Transportation Conditions Appraisal Certificate" issued by domestic authoritative institutions (such as the Shanghai Chemical Industry Institute and DGM).
• Time Limit: Updated once a year, it usually requires sending samples, which takes 3-5 working days.

Step 3: Book a shipping space and make a declaration

• General cargo: Provide MSDS, Certificate of Analysis, and a Non-Dangerous Guarantee Letter.
• Dangerous chemicals: It is necessary to obtain a "Dangerous Packaging Certificate" (a document certifying the results of the inspection of the packaging used for the transportation of dangerous goods for export).
  • Note: Many dye auxiliaries are liquids and are packaged in plastic drums. The drums must have a UN steel stamp, otherwise, it will be impossible to obtain a dangerous goods packaging certificate, and the goods will not be able to be shipped out.

Step 4: Declaration according to the single-window standard

• Required elements:
  1. Product Name: It is recommended to use the format "commercial name (chemical name)", such as "softener (fatty acid derivative)".
  2. Ingredient content: It must be expressed in percentages with absolute accuracy.
  3. Purpose: It needs to be specific to "used in the textile finishing process".
  4. C.I. Index Number: Mandatory for dyes under item 3204.

IV. Risk warnings from experts

1. The classification trap of "mixture"
Many textile auxiliaries are compound formulations (for example, surfactants + solvents + water). When the Customs Inspection Center conducts testing, if it finds that they contain a large amount of ethanol or organic solvents, they may be classified as 3814(Organic composite solvent), tariffs and supervision conditions are completely different. Be sure to verify if solvent content exceeds 50%.

2. A Storm of Inspections of GHS Labels
Don't think that if it's not a dangerous product, you don't need to put on a label! Starting from 2024, the customs will strictly inspect the packaging of chemical products. Even for ordinary chemicals, it is recommended to put on a label that meets the GHS standard.Public announcement label(Including ingredients, safety measures, emergency phone). If it is a hazardous chemical,Chinese labelThis is a mandatory requirement. Otherwise, the relevant party will be directly ordered to make corrections or have the goods returned to the sender.

3. Brand authorization issues
Some dye names (such as "Reactive Red") may involve the trademark rights of specific manufacturers. If your product packaging features logos or models similar to those of well-known brands, you must confirm whether you have obtained authorization before customs declaration and register them in the customs intellectual property system to prevent infringement and seizure of goods.

5. Quick Action List

Before shipping your batch of dyes/auxiliaries, please immediately conduct the following three inspections:

Flash Point Test: Don't just look at the data in the MSDS (much of which is copied). If it's a liquid additive, bring a lighter with you or go to the lab to measure its flash point. If it's below 60 degrees, immediately stop handling it as general cargo.

Packaging check: Go to the warehouse to take a look at the actual goods. If they are hazardous chemicals, check whether there are clear UN markings on the barrels; if they are general cargo, ensure that the packaging is clean and there are no residual old hazardous labels (many factories reuse old barrels, which is a big no-no).

Ingredient list consistency: Compare the ingredients list in the MSDS with the declaration elements in the customs declaration form. The CAS number and percentage must be completely consistent. The customs system now has logical verification, and any conflicting data will result in the rejection of the declaration.