NCS/ARS/CL/10297

You have applied for the tariff classification of POLYOL - PPG 3601, imported in 210kg drums.

PRODUCT ANALYSIS

According to the CAS numbers presented in your documentation, the product constitute the following chemicals: -

1. GLYCEROL PROPOXYLATE-B-ETHOXYLATE (Polyether polyol) > 80%
2. 2-Propenenitrile, polymer with ethenylbenzene and 2-methyloxirane polymer with oxirane ether with 1,2,3-propanetriol (3:1) -  10 – 20%

1. Glycerol Propoxylate-B-Ethoxylate (Polyether Polyol) — >80% 

This substance is a polyether polyol, typically produced by the alkoxylation (chemical reaction that adds an epoxide (like ethylene oxide or propylene oxide) to a compound containing an active hydrogen atom, such as an alcohol or fatty acid) of glycerol using propylene oxide (PO) and ethylene oxide (EO).

A glycerol core with multiple PO/EO repeating units will Acts as a non-ionic surfactant or polymeric additive (a substance mixed with a polymer to improve its performance, processability, or longevity). It is commonly used in polyurethane systems, resins, coatings, and specialty chemical formulations (mixtures of specific molecules designed to achieve particular effects or high performance in a given application, rather than just their chemical composition).

It has High molecular weight polyether, good solubility in organic phases and provides viscosity, flexibility, and emulsification properties. At >80%, this is the major component and defines the essential character of the mixture.

1.  2-Propenenitrile, polymer with ethenylbenzene and 2-methyloxirane polymer with oxirane ether with 1,2,3-propanetriol (3:1) — 10–20%

This is a complex copolymer consisting of:

• 2-Propenenitrile (Acrylonitrile) – provides strength and chemical resistance.
• Ethenylbenzene (Styrene) – contributes rigidity and stability.
• 2-Methyloxirane (Propylene oxide) and Oxirane (Ethylene oxide) polymerized with glycerol – contributes flexibility and polyether character.

This ingredient is essentially a styrene–acrylonitrile (SAN) modified polyether polymer, commonly used as a compatibilizer, viscosity modifier, stabilizing polymer in polyol blends and a reactive polymeric additive in polyurethane production. At 10–20%, it enhances physical properties but does not dominate the mixture's essential character.

Consequently, given that Polyether Polyol constitute 80% and SAN-modified polyether polymer is between 10–20%, the mixture is essentially a polyether polyol blend, typically used for Polyurethane foam production (flexible or semi-rigid), Specialty polyurethane systems and an adhesives, elastomers, and coatings.

Furthermore, the product is not a surfactant mixture for detergents, but rather a polymeric chemical intermediate (substance that forms during the synthesis of a polymer but is not the final product).

TARIFF CLASSIFICATION 

In line with the provisions of the Subheading Notes to Chapter 39, Note (1) specifies that within any heading of Chapter 39, polymers (including copolymers) and chemically modified polymers are to be classified according to defined rules.

Sub-note (a)(3) further provides that, where there is a subheading titled “Other” within the same series, chemically modified polymers shall be classified under that “Other” subheading, provided they are not more specifically covered elsewhere.

Based on the above analysis, and given that the essential character of the product is polyether polyol, the product is classified under heading 3907 – Polyacetals, other polyethers and epoxide resins, in primary forms; polycarbonates, alkyd resins, polyallyl esters and other polyesters, in primary forms and specifically falls under subheading 3907.29.00.00 – Other Polyethers, Others, attracting a 5% rate of duty and 7.5% VAT in accordance with the ECOWAS CET 2022–2027.

LEGAL FRAMEWORK

GIR 1 & 6