NCS/ARS/CL/10220

You have applied for the Tariff Classification of the following items: Polyether Polyol Inovol F3645 in 120 IBC drums (120,000 kg), Polyether Polyol Inovol F5631 in 6 flexible bags (138,000 kg) and Wanol F3156A Conventional Polyol in 5x20 flexi-tank containers (119 MT).

PRODUCT ANALYSIS 

Polyether polyols are polymer used in producing polyurethane (PU) materials made by the reaction of epoxides with compounds having active hydrogen atom. Polyester polyols are made by the polycondensation reaction of multifunctional carboxylic acids and polyhydroxyl compounds. They can be further categorized according to their end use.

Polyether Polyol INOVOL F3645 is a polymeric polyol composed of a styrene-acrylonitrile (SAN) copolymer dispersed in an oxyalkylated triol. It is primarily used in the manufacture of flexible slabstock, polyurethane foams to enhance their load-bearing capacity. Polyether polyols are compounds with multiple hydroxyl (OH) groups that react with isocyanates to form polyurethane. They are produced by reacting epoxides like (ethylene oxide or propylene oxide) with compounds containing active hydrogen atoms. 

Polyether Polyol INOVOL F5631 is a polyether polyol based on glycerol (glycerol is a common alcohol which acts as the initiator of the polymerization process). The product is free of Butylated Hydroxytoluene (BHT) and is used for mattress, seat cushion, furniture and other massive soft foam. It is fit for polyurethane foam of low, medium and high density and used in the production of flexible polyurethane foams.

Wanol F3156A is a conventional polyol which is non-reactive on its own but is a crucial component in polyurethane foam formulations when reacted with isocyanates (like TDI or MDI) used in the production of polyurethane foams. It is designed for use in the production of flexible polyurethane foams, typically used in Bedding and mattresses, Furniture cushioning, Automotive seating and Packaging foams.

TARIFF CLASSIFICATION 

Kindly take note that the tariff line 3907.20 was included in previous versions of the WCO Harmonized System but has been delated from the WCO HS 2022 - 2027 version. 

According to the analysis above all the three polyols (INOVOL F3645, INOVOL F5631, and Wanol F3156A) have a polyether backbone which provides flexibility and hydrophobicity, therefore are classifiable under the tariff Heading 3907- Polyacetals, other polyethers and epoxide resins, in primary forms polycarbonates, alkyd resins, polyallyl esters and other polyesters, in primary forms and Subheading 3907.29 -   0ther.

Polyether Polyol is effectively classified under HS code 3907.29.00.00 - other with 5% duty rate and 7.5% VAT in the ECOWAS Common External Tariff (CET) 2022 - 2027. 

Legal Framework and Justification  

GIR 1 and 6