Full Process Analysis of Thermal Conductive Adhesive Import Customs Declaration Agency and Summary of 2026 Compliance Key Points

Background of Thermal Conductive Adhesive Import and Common Difficulties

In 2026,the domestic production capacity of new energy vehicles,5G communication equipment and photovoltaic inverter manufacturing continues to release.As a core heat dissipation material,the annual import volume of thermal conductive adhesive has exceeded 120,000 tons.The main sources of supply are concentrated in three major chemical groups: Shin-Etsu of Japan,Henkel of Germany,and Dow Corning of the United States.The product forms cover one-component silicone,two-component epoxy resin and acrylic esters.According to the import data of Huanggang Port in Shenzhen,the number of thermal conductive adhesive declaration forms increased by 23% year-on-year,but the rejection rate remains at a high level of 8.7%.

When the Yangtze River Delta electronic manufacturing enterprise where Mr.Zhong works declared a batch of Japanese-made thermal conductive adhesive at the beginning of the year,it was detained at the port for 17 days due to the customs laboratory instruction caused by the error in component content declaration.Such situations expose three common problems: first,HS code classification disputes,the tax rate difference between heading 3824 and heading 3506 reaches 5.5%; second,the MSDS and the public elements of Chinese GHS label do not match; third,the standardization of the certification statement for products outside the 3C catalogue.After receiving the consultation,the chemical team of Zhongshen completed the document review and launched the pre-classification application within 48 hours,shortening the overall clearance cycle to the normal level.

Core Roles of Zhongshen in Thermal Conductive Adhesive Import

Zhongshen has been deeply engaged in the field of chemical customs clearance for 20 years,and has handled more than 4000 declaration forms for the thermal conductive adhesive segment,and is familiar with the operation rules of eight major ports including Waigaoqiao in Shanghai,Yangshan Port,and Yantian in Shenzhen.The core roles are reflected in three levels: pre-risk identification,avoiding prohibited,restricted and controlled substances through component pre-audit; dynamic tax rate optimization,reducing tax burden by using the origin rules of free trade agreements; emergency plan reserve,launching the alternative port rapid transit mechanism for inspection abnormalities.After the implementation of the new version of Catalogue of Hazardous Chemicals in 2026,the team completed the re-identification of hazardous chemical attributes of 168 thermal conductive adhesive SKUs at the first time,ensuring that customers’ goods are not detained due to regulatory changes.

Step-by-Step Breakdown of Thermal Conductive Adhesive Import Procedure

Document Pre-review Stage: Component Compliance Inspection

The core of this stage is to confirm whether the product falls into the supervision scope of Catalogue of Hazardous Chemicals (2026 Edition) and Regulations on the Administration of Precursor Chemicals.The documents to be submitted include: original MSDS (the 16th section of transport information must be marked with UN number),component percentage analysis report (accurate to 0.1%),sample of Chinese GHS safety label (must include 24-hour emergency contact number).The document team of Zhongshen will focus on checking three types of risk substances: curing agent containing isocyanate group,whether the toluene content in solvent-based products exceeds 0.3%,and whether metal fillers involve rare element control.There was once a batch of German-made thermal conductive adhesive that was judged as an environmental hazardous substance because it contained 0.05% dibutyltin dilaurate catalyst.The team advised the customer to replace it with bismuth organic catalyst formula at the pre-review stage,avoiding subsequent return risks.

Port Declaration Stage: Accurate Matching of Declaration Elements

The declaration form shall be filled in strictly in accordance with the 2026 revised version of Explanatory Notes to the Commodities and Headings of the Import and Export Tariff.Common declaration elements for thermal conductive adhesive include: component content (by weight ratio),brand,model,purpose,whether it is retail packaging.The classification specialist of Zhongshen will submit the Pre-classification Opinion to the customs in advance,especially for high-performance products with thermal conductivity greater than 3.0W/m·K,it is necessary to clearly distinguish between code 3824999990 (other unspecified chemical industrial products) and code 3506919090 (other unspecified adhesives).In 2026,the customs launched a new generation of risk parameter system,which automatically triggers price verification for thermal conductive adhesive with unit price exceeding 50 USD/kg.The team will prepare the original factory invoice,foreign exchange payment slip and concurrent market situation explanation materials in advance to ensure that the price negotiation process is passed at one time.

Inspection and Release Stage: On-site Inspection Response

The inspection rate of port customs is about 15%,focusing on checking the packaging type (whether it has passed UN performance test),label compliance and sampling inspection.The on-site inspection coordinator of Zhongshen will complete the rectification preparation in the supervision warehouse in advance: if the Chinese label is not affixed in advance,carry a portable label printer on site; if the packaging is damaged,prepare replacement barrels meeting UN standards.According to General Administration of Customs Announcement No.38 of 2026,imported chemicals must complete hazardous characteristic classification and identification at the port,which takes about 7 working days.The team has established a green channel with three designated laboratories including Qingdao Customs Technology Center,which can shorten the report issuance time to 3 days.For non-hazardous products,by handling the Non-hazardous Chemical Declaration in advance with an authoritative test report attached,the port inspection link can be exempted and direct release can be realized.

Practical Case: Complete Operation for Avoiding Classification Risks

In March 2026,the Dongguan new energy battery module factory managed by Ms.Yu planned to import 5 tons of two-component polyurethane thermal conductive adhesive from Japan,with a cargo value of 83,000 USD.When the customer declared on its own at the initial stage,the customs system prompted that the product might be classified under code 3214100090 (coating for optical fiber),which involves import license management.After Zhongshen intervened,it launched a three-step error correction procedure: first,retrieve the original technical specification to prove that the hardness of the product after curing is Shore A 85,which does not meet the film-forming characteristics of coating; second,arrange the laboratory to conduct infrared spectrum analysis to confirm that the main component is hydroxyl-terminated polydimethylsiloxane; finally,submit the Supplementary Description of Commodity Attributes to the classification office,with the downstream customer’s use process video attached,to prove that it is used for battery pack gap filling rather than coating.The whole appeal cycle took 9 working days,half shorter than the conventional process,avoiding more than 12,000 RMB of container detention fees caused by license problems for the customer.

Summary of Zhongshen’s Professional Value

Thermal conductive adhesive import declaration is by no means a simple document transfer,but a compliance project running through the front end of the supply chain.Through 20 years of data accumulation,Zhongshen has established a risk feature database covering more than 3000 types of chemicals,and can issue a preliminary risk assessment report within 30 minutes after receiving the order.The Measures for the Safety Administration of Import and Export Hazardous Chemicals implemented in 2026 further enhance the main responsibility of enterprises.Choosing a professional agent means converting uncertain inspection costs into predictable fixed service fees.Calculated from the three dimensions of reducing tax rate cost,avoiding return risk and reducing capital occupation,professional agency services can save an average of 8%-12% of the comprehensive cost for each batch of goods.After three months of cooperation,Mr.Zhong feedback that the labor input of his enterprise’s import department has been reduced by 40%,and the clearance efficiency has been improved by 60%,which is a direct reflection of the value of professional division of labor.

• Core Strengths: 20 years of chemical customs clearance experience,over 4000 special declarations for thermal conductive adhesive
• Risk Management: Identify hazardous chemical attributes in advance,avoid return shipment and administrative penalty
• Cost Optimization: Accurate classification and origin planning,average tax reduction of 5.5%
• Timeliness Guarantee: Port green channel access,24-hour emergency plan for inspection abnormalities
• Data Accumulation: Risk feature database for 3000 types of chemicals,assessment report issued within 30 minutes