HTS Code for polychlorobiphenyls and chloroparaffins

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## Common ground Both options cover polychlorobiphenyls (PCBs) and chloroparaffins in solid or liquid forms, grouped by physical state and wax-like properties. ## Options at a glance **3404.90 – Solid waxes** - **Defining trait:** The material has the character of artificial waxes, typically solid, viscous, or greasy with wax-like consistency. - **Typical examples:** Waxy PCB mixtures used in electrical insulation or industrial lubricants. - **Best fit when:** The product feels or behaves like a wax (e.g., pliable, non-fluid, high melting point). **3824.99 – Non-wax solids and liquids** - **Defining trait:** Does not have the character of artificial waxes; includes both solid forms that are brittle or crystalline and liquid forms. - **Typical examples:** Liquid PCBs in transformers, or solid chloroparaffins used as flame retardants. - **Best fit when:** The product is clearly non-waxy—fluid, hard, or granular—or is a liquid. ## Key differences | Feature | 3404.90 (Waxes) | 3824.99 (Non-wax) | |-----------------------|------------------------|----------------------------| | Physical state | Solid | Solid or liquid | | Wax-like character | Yes | No | | Consistency | Greasy, pliable | Brittle, crystalline, or fluid | ## How to choose - Does the product feel like a wax (greasy, soft, moldable)? → 3404.90 - Is it liquid or hard/crystalline (not greasy)? → 3824.99 ## Overlaps & pitfalls A solid product may be borderline if it’s waxy but also brittle—priority should go to **main physical behavior**. If uncertain, use the wax test: rub between fingers—if it feels greasy or leaves a residue, it's likely a wax. The term "artificial waxes" is key; if not applicable, avoid 3404.90



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