NCS/ARS/CL/10412

You have applied for the tariff classification of KRONES COLFIX S 4045, a water-based adhesive, imported in 32 kg hobbocks and 1,000 kg containers.

PRODUCT ANALYSIS

According to the Product Technical Data Sheet and Safety Data Sheet submitted, KRONES COLFIX S 4045 is a water-based prepared adhesive formulated from a combination of natural and synthetic polymeric binders. It is specifically designed for the industrial labelling of returnable glass containers and is suitable for application on both treated and untreated glass surfaces.

The adhesive exhibits high initial wet tack, rapid setting characteristics, excellent adhesion during service, and good resistance to ice and condensate water. It is also formulated to be readily removable during bottle recycling using conventional bottle-washing systems with an appropriate caustic soda solution, making it particularly suitable for returnable beverage bottle applications.

The product is presented as a white to slightly yellowish viscous liquid with the following typical physical properties:

• Appearance: White to slightly yellowish viscous liquid
• Viscosity: Approximately 105,000 mPa·s
• Density: Approximately 1.0 g/cm³
• Solid content: Approximately 37%
• Recommended processing temperature: 28–32°C

Based on the documentation submitted, the product has the following approximate composition:

The additive package includes preservatives present in very small quantities to maintain product stability, namely:

• 2-Methyl-2H-isothiazol-3-one (MIT): Less than 0.10% by weight.
• 5-Chloro-2-methyl-4-isothiazolin-3-one and 2-methyl-2H-isothiazol-3-one (CMIT/MIT) (3:1): Approximately 0.0015% by weight.

The composition demonstrates that KRONES COLFIX S 4045 is a prepared adhesive consisting of water, polymeric binders, starch, casein, and minor functional additives formulated to achieve the required bonding performance for industrial bottle-labelling applications.

It is noted, however, that CAS No. 103-11-7, as stated in the supporting documentation, corresponds to 2-Ethylhexyl acrylate (a primary ingredient in pressure-sensitive adhesives), which is an acrylic monomer rather than a polymer. This apparent discrepancy does not alter the nature of the imported product as a prepared adhesive.

TARIFF CLASSIFICATION

Part (B) of the Explanatory Notes to heading 35.06 provides that the heading covers prepared glues and other prepared adhesives not covered by a more specific heading of the Nomenclature.

Based on the above, the product falls under heading 3506 – 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.

Accordingly, by application of General Rules for the Interpretation (GRIs) 1 and 6, together with the terms of heading 35.06 and the relevant Explanatory Notes, the product is properly classified under Tariff Subheading: 3506.99.00.00 – Other prepared glues and other prepared adhesives, not elsewhere specified or included – Other, attracting a 10% Rate of Duty and 0% VAT in accordance with the ECOWAS Common External Tariff (CET).

LEGAL JUSTIFICATION

• GIR 1 & 6