NCS/ARS/CL/10351

You have applied for the tariff classification of colour masterbatch, imported in 25 kg bags.

PRODUCT ANALYSIS

Colour masterbatch is a concentrated mixture of pigments (or dyes) dispersed in a carrier resin, used for colouring plastic materials during manufacturing processes. It is typically supplied in pellet (granule) and is added in small proportions into natural (uncoloured) polymers, ensuring consistent and uniform colouration in the final product. 

A standard colour masterbatch consists of:

• Pigments or dyes – which provide the colour; 
• Carrier resin (such as polyethylene or polypropylene) – which ensures compatibility with the base polymer; and  
• Additives (optional) – which enhance dispersion, stability, and processing performance. 

During plastic processing operations such as extrusion, injection moulding, or blow moulding, the masterbatch is blended with the base polymer. The pigment is evenly dispersed throughout the material, resulting in a uniform and consistent colour in the finished product.

Colour masterbatch is available in different variants, including:

• White masterbatch – typically containing titanium dioxide; 
• Black masterbatch – generally containing carbon black; and 
• Custom colour masterbatch – formulated to achieve specific shades for branding or product design purposes. 

Based on the Safety Data Sheet (SDS) submitted, the product consists of:

• CAS No. 9002-88-4 (Linear Low-Density Polyethylene – LLDPE): 52–60%, serving as the carrier resin; and 
• CAS No. 13463-67-7 (Titanium Dioxide): 40 – 48%, functioning as the primary white pigment, valued for its high refractive index, brightness, and UV-resistant properties. 

The composition indicates that the product is not merely a polymer, but a preparation consisting of pigments dispersed in a plastic medium, specifically designed for use as a colouring agent in plastics processing.

Colour masterbatch is an essential intermediate in the plastics industry, enabling efficient, clean, and consistent colouring of plastic products while improving production control and reducing material waste.

It is widely used in the manufacture of Packaging materials (films, bags, containers), Household plastic products; Automotive components; Pipes and construction materials; and Agricultural films.

TARIFF CLASSIFICATION

Based on the product analysis above, and in accordance with the provisions of Note 3 to Chapter 32—which provides that Heading 32.06 also covers preparations based on colouring matter (including pigments of heading 25.30 or Chapter 28, as well as metal flakes and powders) of a kind used for colouring any material or as ingredients in the manufacture of colouring preparations—the following classification position is established:

The product under consideration is a colour masterbatch, comprising approximately 40–48% titanium dioxide (a colouring pigment of Chapter 28) dispersed in a polyethylene (LLDPE) carrier resin. Its principal function is to impart colour to plastic materials during manufacturing processes. The polyethylene component serves solely as a carrier medium to facilitate uniform dispersion of the pigment within the base polymer.

In view of the above, the product is classifiable under Heading 32.06, which covers “Other colouring matter; preparations as specified in Note 3 to this Chapter, other than those of heading 32.03, 32.04 or 32.05; inorganic products of a kind used as luminophores, whether or not chemically defined.”

Furthermore, in line with the Explanatory Notes to subheading 3206.19, which state that preparations containing less than 80% titanium dioxide include concentrated dispersions in plastics, natural or synthetic rubber, or plasticisers—commonly referred to as masterbatches and used for colouring plastics or rubber—the product clearly falls within this scope.

Accordingly, the product is properly classified under subheading 3206.19.00.00 - Pigments and preparations based on titanium dioxide – Other at 5% Rate of Duty, and 7.5% VAT in accordance with ECOWAS Common External Tariff (CET) 2022- 2027.

LEGAL JUSTIFICATION

• GIR 1&6, 
• Note 3 to Chapter 32 and 
• Explanatory Note to subheading 3206.19