NCS/ARS/CL/10395

You have applied for the tariff classification of KRONES Colfix HM 8037, imported in pillow-shaped form and packed in 18 kg cartons.

PRODUCT ANALYSIS

KRONES Colfix HM 8037 is a synthetic polymer-based, yellowish hot-melt adhesive primarily used in high-speed bottling and packaging operations. It is specially formulated for use with the Krones Contiroll labeller, a high-speed rotary wrap-around labelling machine designed to apply reel-fed labels to containers. The product is widely used for bonding paper and film labels to containers made of PET, PP, PE, glass, and metal.

According to the submitted product documentation, KRONES Colfix HM 8037 consists of the following components:

The functions of the constituent components are as follows:

• Resin esters serve as tackifiers and adhesion promoters, enhancing the adhesive properties and bonding performance of the product.
• Hydrocarbon resins (petroleum resins) are low-molecular-weight synthetic thermoplastic polymers derived from petroleum feedstocks. They function primarily as tackifiers and modifiers, improving adhesion, flexibility, thermal stability, and moisture resistance.
• Plasticizer oils are additives used to improve the flexibility, softness, and processing characteristics of polymeric materials. In adhesive formulations, they enhance workability and bonding performance.
• Mineral oil acts as a plasticizer and viscosity modifier, reducing melt viscosity while improving flexibility and surface tack.
• Antioxidants are incorporated to prevent oxidative degradation, thermal breakdown, and discoloration during storage and application. They help maintain viscosity stability and preserve the adhesive's performance throughout its service life.
• SIS (Styrene-Isoprene-Styrene) polymer is a thermoplastic elastomer comprising rigid polystyrene end-blocks and a flexible polyisoprene mid-block. This structure provides an optimal balance of strength, elasticity, and processability, making it a key component in pressure-sensitive and hot-melt adhesive formulations.

Based on its composition and intended use, KRONES Colfix HM 8037 is a prepared hot-melt adhesive consisting of synthetic polymers, tackifying resins, plasticizers, and stabilizing additives formulated for industrial labelling applications.

TARIFF CLASSIFICATION

Based on the above analysis, Part (B), paragraph (4) of the Explanatory Notes to heading 35.06 covers:

"Preparations specially formulated for use as adhesives, consisting of polymers or blends thereof of headings 39.01 to 39.13 which, apart from any permitted additions to the products of Chapter 39 (fillers, plasticisers, solvents, pigments, etc.), contain other added substances not falling in that Chapter (e.g., waxes, rosin esters, unmodified natural shellac)."

The product under consideration is a prepared adhesive composed principally of polymeric materials and tackifying resins, with additional substances such as mineral oil, plasticizer oil, antioxidants, and resin esters incorporated to enhance its adhesive and processing characteristics. As such, it satisfies the terms of heading 35.06.

Accordingly, the product falls under tariff heading 35.06 – Prepared glues and other prepared adhesives, not elsewhere specified or included; products suitable for use as glues or adhesives, put up for retail sale as glues or adhesives, not exceeding a net weight of 1 kg.

More specifically, the product is effectively classified in tariff subheading 3506.91.00.00 – Other; Adhesives based on polymers of headings 39.01 to 39.13 or on rubber at 10% rate of duty and 0% VAT in line with the ECOWAS Common External Tariff (CET) 2022–2027.

LEGAL JUSTIFICATION

 GIR 1 & 6