Aviation Film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3920620020 | 39.2% | CN | US | Official Doc |
| 3920620050 | 39.2% | CN | US | Official Doc |
| 3921110000 | 40.3% | CN | US | Official Doc |
| 7607196000 | 13.0% | CN | US | Official Doc |
| 7607119090 | 13.0% | CN | US | Official Doc |
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AI Analysis
π©οΈ Aviation Film (Aviation Foil & Plastic Sheeting)
π HS Code Reference & Customs Clearance Guide | 2024/2026 Tariff Analysis | Professional Compliance Strategy
π I. Product Definition & Classification: What Exactly is "Aviation Film"?
"Aviation Film" is a broad commercial term that does not have a single, unique HS Code. In international trade, it refers to thin sheets or foils used in aerospace, aircraft maintenance, or specific high-performance industrial applications. The critical factor for classification is the Base Material:
- Plastic-Based Films (PET/Polymer): Transparent or colored synthetic sheets (e.g., Kapton, Mylar, or general polyester films) used for insulation, covering, or protective layers.
- Metal-Based Films (Aluminum/Metal Composite): Thin sheets of aluminum or metal composites used for heat shielding, structural wrapping, or RF shielding.
β οΈ Key Distinction Point:
- If the material is Polyester (PET) or other Plastic β It falls under Chapter 39 (Plastics).
- If the material is Aluminum or Metal Composite β It falls under Chapter 76 (Aluminum).
- Misclassification leads to severe penalties, especially with current "Section 301" and "Section 122" tariffs on Chinese-origin goods.
π¦ II. HS Code Classification Details (Based on Provided Data)
| HS Code | Product Description | Material/Form Match | Total Tax Rate | Key Tax Components |
|---|---|---|---|---|
| 3920.62.00.20 | Color Aviation Film | Form: Film Material: Polyester (PET) |
39.2% | Base: 4.2% + Sec. 301: 25% + Sec. 122: 10% |
| 3920.62.00.50 | Color Aviation Film | Form: Film Material: Polyester or Composite Plastic |
39.2% | Base: 4.2% + Sec. 301: 25% + Sec. 122: 10% |
| 3921.11.00.00 | Aviation Plastic Film | Form: Film Material: Plastics (General) |
40.3% | Base: 5.3% + Sec. 301: 25% + Sec. 122: 10% |
| 7607.19.60.00 | Aviation Metal Film | Form: Film Material: Aluminum or Metal Composite |
13.0% | Base: 3.0% + Sec. 301: 0% + Sec. 122: 10% |
| 7607.11.90.90 | Aviation Aluminum Semi-Finished | Form: Film/Sheet Material: Aluminum Semi-finished/Intermediate |
13.0% | Base: 3.0% + Sec. 301: 0% + Sec. 122: 10% |
π Critical Insight:
- Plastic Films (39xx) are heavily taxed at ~39-40% due to multiple layers of punitive tariffs.
- Aluminum Films (76xx) are significantly cheaper at 13% because Section 301 tariffs (25%) do not apply to these specific aluminum HS codes in this dataset, leaving only the Base + 122 Tariff.
π° III. Detailed Tariff Breakdown (2024/2026 Context)
β Applicable Market: Likely USA or markets with similar "Section 122" & "Section 301" structures
β Origin: China (CN) implied by the high Section 301 (25%) and Section 122 (10%) components
β Effective Time: Post-2024 trade policies
π― 1. Plastic-Based Aviation Films (HS 3920.62 / 3921.11)
| Item | Detail |
|---|---|
| Base Duty | 4.2% - 5.3% (Standard MFN rate for plastics) |
| Section 301 Duty | +25.0% (Retaliatory tariff on Chinese plastics/chemicals) |
| Section 122 Duty | +10.0% (Special additional tariff, often for strategic sectors or specific trade remedies) |
| Total Effective Rate | 39.2% - 40.3% |
| Calculation | CIF Value Γ 39.2% (approx.) |
| De Minimis Exemption? | β NO. These items are high-value/high-risk and typically excluded from de minimis (Section 321) thresholds. |
| Legal Basis | USITC:3920/3921 β FOOTNOTE:301 β SECTION:122 |
π Explanation:
- The 25% Section 301 is the heaviest burden, applied to most Chinese-origin plastic products.
- The 10% Section 122 is a special levy that stacks on top of 301.
- Total cost impact: Nearly 40% of the item's value is tax. This drastically reduces profit margins for plastic aviation films imported from China.
π― 2. Aluminum-Based Aviation Films (HS 7607.19 / 7607.11)
| Item | Detail |
|---|---|
| Base Duty | 3.0% (Standard MFN rate for aluminum foils) |
| Section 301 Duty | +0.0% (Note: In this specific data set, Sec 301 is 0% for these codes) |
| Section 122 Duty | +10.0% |
| Total Effective Rate | 13.0% |
| Calculation | CIF Value Γ 13.0% |
| De Minimis Exemption? | β NO. Similar to plastics, aluminum products are scrutinized. |
| Legal Basis | USITC:7607 β FOOTNOTE:122 |
π Note:
- The 0% Section 301 for these specific aluminum codes is a significant advantage compared to plastics.
- However, the 10% Section 122 still applies, making aluminum films cheaper but not duty-free.
π οΈ IV. Customs Clearance Practical Advice (Pitfall Avoidance)
β 1. Document Preparation Checklist (Non-Negotiable)
| Document | Required? | Purpose |
|---|---|---|
| β Material Composition Certificate | βοΈ | Crucial! Must explicitly state "100% Polyester" or "Aluminum Alloy". Vague terms like "Aviation Film" will be rejected. |
| β Product Specifications | βοΈ | Thickness, width, color, and thermal resistance ratings. |
| β Commercial Invoice | βοΈ | Must match the HS Code description exactly (e.g., "Polyester Film" vs. "Aluminum Foil"). |
| β Packing List | βοΈ | Ensure no mixed materials in one shipment unless properly declared. |
| β Third-Party Test Report | βοΈ | ISO/ASTM standards for aviation-grade materials. |
| β Country of Origin Certificate | βοΈ | To verify Chinese origin and apply correct Section 301/122 rates. |
β 2. Declaration Strategy (Key Mnemonics)
π₯ "Material Dictates HS, Section 301 Kills Plastic, Section 122 Hits All!"
| Scenario | Correct HS Code | Risk Level | Why? |
|---|---|---|---|
| Colored PET Film | 3920.62.00.20 or .50 |
π΄ High (39.2%) | Plastic = High Sec 301. |
| General Plastic Film | 3921.11.00.00 |
π΄ High (40.3%) | Base duty is higher (5.3%). |
| Aluminum Composite | 7607.19.60.00 |
π‘ Medium (13.0%) | No Sec 301, only Sec 122. |
| Aluminum Semi-Finished | 7607.11.90.90 |
π‘ Medium (13.0%) | Same as above. |
β 3. Special Handling Cases
| Case | Handling Advice |
|---|---|
| Mixed Materials | If the film has a plastic layer and an aluminum layer, classify based on essential character. Usually, the outermost or structural layer dictates. Seek Advance Ruling. |
| "Aviation Grade" Claims | Do not use "Aviation Grade" as the HS description. Use "Polyester Film, Color, for Aerospace Use". "Aviation" is a use case, not a material. |
| Section 122 Impact | This 10% tariff is non-negotiable for most Chinese-origin goods. Factor this into pricing strategies. |
| Origin Substitution | If possible, source from non-China origins (e.g., Vietnam, Malaysia) to potentially avoid Section 301 (25%), but ensure strict compliance with Substantial Transformation rules to avoid customs evasion allegations. |
π V. Global Market Comparison (2024/2026 Snapshot)
| Country/Region | Recommended HS | Estimated Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3920.62 / 7607.19 |
13.0% - 40.3% | FCC, ASTM | Section 122 & 301 apply. Highest risk market. |
| π¨π³ China | 3920.62 / 7607.19 |
0% - 5% | CCC (if applicable) | Import tariffs are low, but export restrictions may apply. |
| πͺπΊ EU | 3920.62 / 7607.19 |
0% - 4% | CE, REACH | No Section 301/122. Standard MFN rates apply. |
| π―π΅ Japan | 3920.62 / 7607.19 |
0% - 3% | JIS | Low tariffs, high quality standards. |
π Conclusion:
- USA is the most expensive market due to the stacking of Section 301 (25%) and Section 122 (10%).
- Plastic films are penalized more heavily than aluminum films.
- EU and Japan offer much lower tariff barriers, making them more attractive for Chinese manufacturers if supply chain allows.
π VI. Common Errors & Pitfalls (Lessons Learned)
β Error 1: Declaring "Aviation Film" without specifying material.
π Consequence: Customs will assign a default high-duty code or request additional duties + fines.
π Fix: Always specify "Polyester" or "Aluminum".
β Error 2: Assuming all "Aviation" products are duty-free.
π Consequence: Surprise bills for 40% tax.
π Fix: Check Section 301 and 122 lists for your specific HS code.
β Error 3: Mixing plastic and aluminum films in one container without proper segregation.
π Consequence: If mixed, customs may apply the highest tariff rate to the entire shipment.
π Fix: Ship separately or declare each material distinctly with clear packing lists.
β Correct Practice:
"Polyester Film, Color, 0.05mm, ASTM D3359 Certified, for Aerospace Insulation. HS: 3920.62.00.20"
π― VII. Conclusion: Professional Declaration, Cost Control, Compliance
π― Remember the Mantra:
πΉ "Material First, Tariff Second. Plastic Suffers, Aluminum Survives."
πΉ "Section 301 Hits Plastic, Section 122 Hits All. Declare Clear, Pay Less."
π Pro Tip:
If your aluminum film qualifies as "Semi-finished" (7607.11.90.90), ensure your documentation proves it is not a "finished product" to maintain the 13% rate. For plastics, consider Supply Chain Diversification to non-China origins to mitigate the 25% Section 301 tariff.
π£ Immediate Action:
π Consult a licensed customs broker.
π Obtain Material Safety Data Sheets (MSDS) and Composition Certificates.
π Apply for Advance Ruling if the material composition is complex (e.g., laminated films).
β¨ Precision in Classification is Profit in Logistics!
πΌ Don't let hidden tariffs eat your margins.
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.