Aerospace Film Roll
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3921110000 | 40.3% | CN | US | Official Doc |
| 7607196000 | 13.0% | CN | US | Official Doc |
| 3921905010 | 39.8% | CN | US | Official Doc |
| 3920992000 | 39.2% | CN | US | Official Doc |
| 3920200055 | 39.2% | CN | US | Official Doc |
AI Analysis
π Aerospace Film Roll: HS Code Classification & Tax Strategy Guide (2026)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π 1. Product Definition & Classification: What exactly is an "Aerospace Film"?
In international trade, "Aerospace Film Roll" is a generic term that can refer to vastly different materials depending on their chemical composition and end-use. The customs classification (HS Code) depends entirely on whether the film is made of plastics/polymers or metals (like aluminum).
β οΈ Critical Distinction:
- If the material is a plastic/polymer (e.g., PET, PI, Polyimide, PVC) β It falls under Chapter 39 (Plastics).
- If the material is aluminum/metal foil β It falls under Chapter 76 (Aluminum).
- Mistake Alert: Misclassifying a plastic film as metal foil (or vice versa) can lead to severe penalties, as the tax rates differ significantly (up to 40% vs. 13%).
π¦ 2. HS Code Classification Details (2026 Latest Tariff Authority)
Based on the provided data, here are the specific HS Codes for "Aerospace Film" and "Military Film Rolls," categorized by material inference:
| HS Code | Product Description | Material Inference | Form Factor | Total Tax Rate |
|---|---|---|---|---|
3921.11.00.00 |
Other plates, sheets, film, foil, and strip, of plastics | Plastic | Film/Sheet | 40.3% |
7607.19.60.00 |
Aluminum foil, plain, other than foil of heading 7606 | Aluminum / Metal Composite | Film/Foil | 13.0% |
3921.90.50.10 |
Other plates, sheets, film, etc., of plastics | Plastic/Polymer Base | Film | 39.8% |
3920.20.00.55 |
Other plates, sheets, film, etc., of polymers of ethylene | Polymer | Film | 39.2% |
3920.99.20.00 |
Other plates, sheets, film, etc., of plastics | Plastic | Film/Roll | 39.2% |
π Key Insight:
- Plastic-based films (39xx series) are subject to heavy tariffs (Base ~5% + 25% Section 301 + 10% IEEPA = ~40%).
- Aluminum-based films (76xx series) are subject to lighter tariffs (Base ~3% + 10% IEEPA = 13%).
- Military vs. Aerospace: While "Aerospace" is the user term, the data includes "Military Film Rolls" (3920.99.20.00). Note that military-end-use goods often face stricter scrutiny and potential additional restrictions, though the tariff rate here matches other plastic films.
π° 3. 2026 Latest Tariff Rate Breakdown (Including Surcharges)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: Post-2025 Policy Updates
π― A. Plastic-Based Aerospace Films (HS Codes: 3921.11, 3921.90, 3920.20, 3920.99)
These codes are subject to the maximum burden due to multiple trade remedies.
| Item | Detail |
|---|---|
| Base Duty Rate | 4.2% β 5.3% (Varies by specific subheading) |
| Section 301 Surcharge | +25.0% (Specific to Chinese-made plastic articles) |
| IEEPA 122 Clause | +10.0% (Additional surcharge on Chinese imports) |
| Total Effective Tax | 39.2% β 40.3% |
| Calculation Basis | CIF Value Γ Total Tax Rate |
| De Minimis Exemption | β NOT Available (deny_de_minimis applies) |
π Explanation:
- The 25% Section 301 tariff is the dominant cost driver for plastic films from China.
- The 10% IEEPA tax is an additional layer on top of the 301 tariff.
- Total Impact: For every $10,000 of plastic aerospace film, you will pay ~$4,030 in duties. This is a massive cost increase compared to pre-2018 levels.
π― B. Aluminum-Based Aerospace Film (HS Code: 7607.19.60.00)
Aluminum foil for aerospace use enjoys a significantly lower tax profile.
| Item | Detail |
|---|---|
| Base Duty Rate | 3.0% |
| Section 301 Surcharge | 0.0% (Note: Some aluminum products are exempt or have different rates; data indicates 0%) |
| IEEPA 122 Clause | +10.0% |
| Total Effective Tax | 13.0% |
| Calculation Basis | CIF Value Γ 13% |
| De Minimis Exemption | β NOT Available |
π Explanation:
- Savings Alert: If your "Aerospace Film" is aluminum foil (e.g., for thermal insulation or shielding), classifying it correctly under 7607 saves you ~27 percentage points compared to plastic films.
- Ensure the product is genuinely aluminum and not a plastic film with an aluminum coating (which may still be classified as plastic).
π οΈ 4. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Required Documentation (Non-Negotiable)
| Document | Mandatory? | Purpose |
|---|---|---|
| β Material Composition Certificate | βοΈ | Critical. Must state % of polymer vs. metal. Proves if it's plastic (39xx) or aluminum (76xx). |
| β Product Technical Data Sheet | βοΈ | Shows thickness, width, tensile strength, and intended aerospace application. |
| β Photos (Unpacked & Packed) | βοΈ | Visual confirmation of "Roll" form factor and labeling. |
| β Commercial Invoice | βοΈ | Must clearly state: "Aerospace Film Roll, [Material Name], [Thickness], HS Code: [XXXX]" |
| β Bill of Lading / Air Waybill | βοΈ | Standard shipping doc. |
| β Export License (if applicable) | βοΈ | For military-related films, an Export License from China may be required before US entry. |
β 2. Declaration Strategy (Key Mantra)
π₯ "Material First, Form Second; Plastic is High, Metal is Low!"
| Scenario | Correct HS Code | Risk if Wrong |
|---|---|---|
| Polyimide (Kapton) Film | 3921.11.00.00 or 3921.90.50.10 |
If misdeclared as metal β Smuggling/Undervaluation charge. |
| Aluminum Foil for Insulation | 7607.19.60.00 |
If misdeclared as plastic β Overpay ~27% tax. |
| Military-Grade Plastic Film | 3920.99.20.00 |
High scrutiny for "Military End-Use" β Potential denial of entry if not authorized. |
| Composite (Plastic + Metal) | Check Base Material | If plastic is the structural base β 39xx. If metal is the base β 76xx. |
β 3. Special Situations
| Situation | Advice |
|---|---|
| Double-Sided Coated Film | Declare based on the principal material. If coated plastic, still likely 39xx. |
| Military vs. Civilian Aerospace | If the film is for military aircraft, customs may demand additional End-Use Statements. Ensure you are not violating ITAR/EAR restrictions. |
| Roll vs. Sheet | The data specifies "Roll" (ε·) for some military items. Ensure packaging matches the declaration. If cut into sheets, HS Code may change. |
π 5. Global Market Comparison (2026 Update)
| Market | Recommended HS Code | Approx. Tax (China Origin) | Key Requirement |
|---|---|---|---|
| πΊπΈ USA | 3921.11.00.00 (Plastic) |
~40.3% | Section 301 + IEEPA. High compliance risk. |
| πΊπΈ USA | 7607.19.60.00 (Aluminum) |
13.0% | Proven aluminum content. |
| π¨π³ China | 3921.11.00.00 |
~5% | Domestic consumption. |
| πͺπΊ EU | 3920.62.10 (Similar) |
~3-4% | REACH Compliance for polymers. |
π Conclusion:
- The US market is the most expensive for imported aerospace films from China due to the 301+IEEPA combo.
- Aluminum films are a tax-advantaged alternative if the material allows.
- Plastic films face near-prohibitive taxes (~40%). Consider supply chain diversification (e.g., sourcing from Vietnam/Malaysia) if possible to avoid Section 301.
π 6. Common Mistakes & Pitfalls (Blood Lessons)
β Mistake 1: Declaring all films as "Plastic Film" without material proof.
π Result: If customs inspects and finds aluminum, they may penalize for incorrect declaration. If it's plastic, you pay 40%.
β Mistake 2: Ignoring the "Military" label in the description.
π Result: If the invoice says "Aerospace" but the product is used for military drones, it could be flagged for national security review, leading to detention.
β Mistake 3: Assuming "Film" automatically means "Plastic".
π Result: Missing the 13% aluminum rate. Always verify if the product is metal foil.
β Correct Practice:
"Polyimide Film Roll, 50um, Aerospace Grade, Plastic Material, HS Code: 3921.11.00.00, Made in China"
π― 7. Conclusion: Professional Declaration, Cost Optimization!
π― Remember the Mantra:
πΉ "Plastic pays 40%, Aluminum pays 13%. Material defines the tariff!"
πΉ "No De Minimis for this item. Full valuation required."
πΉ "Aerospace is sensitive. Prove the material, document the use."
π Pro Tip:
If your aerospace film is critical and subject to 40% tax, consider:
1. Pre-Ruling: Apply for an Advance Ruling from CBP to confirm the HS Code.
2. Supply Chain Shift: Source from non-China countries (e.g., South Korea, Japan) to avoid Section 301 duties (check for 0% or low rates).
3. Aluminum Alternative: If performance allows, switch to aluminum foil to reduce tax by 27%.
π£ Immediate Action:
π Contact your customs broker with the Material Safety Data Sheet (MSDS) and Technical Specs.
π Optimize your HS Code to save thousands in duties.
β¨ Precision in classification is your biggest cost-saving tool.
Customer Reviews
About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) β Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) β More specific grouping within the chapter
- Subheading (6 digits) β Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) β Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate β The standard duty rate applied to WTO members
- General rate β Applied to countries without trade agreements
- Trade remedy duties β Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.