Color Film 220 Specification
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3707906000 | 35.0% | CN | US | Official Doc |
| 3701910060 | 38.7% | CN | US | Official Doc |
| 3701910030 | 38.7% | CN | US | Official Doc |
| 3707903290 | 35.0% | CN | US | Official Doc |
| 3702310100 | 38.7% | CN | US | Official Doc |
AI Analysis
ποΈ Color Film 220 Specification (Photographic Film)
π HS Code Reference & Customs Clearance Guide | 2026 Updated Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Really Understand "Color Film 220"?
Color Film 220 refers to color photographic film formatted in the 220 roll specification. In international trade, it is categorized as a light-sensitive material used for photography.
Key Distinction: - 220 Roll vs. 120 Roll: Both are medium format films, but 220 has no paper backing (liner), allowing more exposures per roll. - Material Nature: It is a flexible plastic base (cellulose acetate or polyester) coated with light-sensitive emulsion. It is not paper, fabric, or digital media. - Usage: Strictly for photographic purposes (analog photography).
β οΈ Critical Classification Point:
- If it is exposed or unexposed photographic film β Falls under Chapter 37 (Photographic Goods).
- It must be distinguished from "photographic plates" or "digital sensors."
- The "220" designation is a format/specification, not a material change.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, there are 5 potential HS Codes for "Color Film 220." The correct code depends on the specific state (exposed/unexposed), packaging, and precise material inference by customs.
| HS Code | Product Description | Matching Logic & Summary | Total Tax Rate (China Origin to US) |
|---|---|---|---|
3707.90.60.00 |
Other photographic chemical preparations / materials | β Match: 'Color Film' fits photographic materials; '220' is a spec. No material conflict. Classified under "other photographic materials." | 35.0% |
3701.91.00.60 |
Color photographic plates, films, paper, paperboard & other flat sensitized materials (Disc-shaped films excluded) | β Match: 'Color Film' indicates color photography; '220' is a specific non-disc film format. Assumed non-paper/non-fabric light-sensitive film. | 38.7% |
3701.91.00.30 |
Color photographic plates, films, paper, paperboard & other flat sensitized materials (Disc-shaped films) | β Match: 'Color Film' = Color photography; '220' = specific film spec. Inferred as "Disc-shaped" or similar category due to classification nuance. | 38.7% |
3707.90.32.90 |
Other photographic chemical preparations (Other) | β Match: 'Color Film' is a light-sensitive material for photography. Since couplers/emulsions aren't specified, it falls under the "Other" catch-all category. | 35.0% |
3702.31.01.00 |
Other color photographic film, roll form, width β€ 105mm, unexposed, on a non-paper base | β Match: 'Color Film' = Color roll film; '220' = Spec. Fits "non-paper base, unexposed, color photographic film" (inferred from common sense). | 38.7% |
π Key Insight:
- The main difference lies in Chapter 37.01 (Sensitized plates/films) vs. Chapter 37.07 (Chemical preparations).
- 3702.31.01.00 is the most precise fit for unexposed roll film on a non-paper base.
- 3701.91.xxxxxx codes are often used when the film is not strictly "roll form" or when customs interprets "220" as a specific plate-like format.
- 3707.xxxxxx codes are used if the product is considered a "preparation" or "material" rather than a finished film roll.
π° III. 2026 Latest Tariff Rate Breakdown (Including Additional Duties & Policy Surcharges)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: From November 10, 2025 (and onwards)
π― 1. Codes with 35.0% Total Tax Rate (3707.90.60.00 & 3707.90.32.90)
| Item | Content |
|---|---|
| Base Tariff | 0.0% (ad valorem) |
| USITC Additional Tariff | +25.0% (Under USITC Footnote 9903.88.01 / Section 301) |
| IEEPA Additional Tariff | +10.0% (Under International Emergency Economic Powers Act, targeting China/HK products) |
| Total Tax Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35.0% |
| De Minimis Exemption Available? | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3707.90.60.00 β FOOTNOTE:9903.88.01 |
π Explanation:
- "USITC 25%" is the Section 301 additional duty.
- "IEEPA 10%" is the newε―Ήε (China-specific) emergency tariff.
- Total 35% is high, but lower than the 38.7% tier.
π― 2. Codes with 38.7% Total Tax Rate (3701.91.00.60, 3701.91.00.30, 3702.31.01.00)
| Item | Content |
|---|---|
| Base Tariff | 3.7% (ad valorem) |
| USITC Additional Tariff | +25.0% |
| IEEPA Additional Tariff | +10.0% |
| Total Tax Rate | 38.7% |
| Tax Calculation | CIF Value Γ 38.7% |
| De Minimis Exemption Available? | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3702.31.01.00 β FOOTNOTE:9903.88.01 |
π Note:
- The 3.7% base tariff applies to most photographic films.
- Add 25% (301) + 10% (IEEPA) = 35% additional duty.
- Total: 38.7%.
- Even if the base rate is 3.7%, the final burden is heavier than the 35% tier.
π οΈ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Avoidance Guide)
β 1. Required Documentation Checklist (All Required)
| Document | Mandatory? | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must state: Format (220), Type (Color), Base Material (Non-paper), Exposure Status (Unexposed/Exposed) |
| β Product Photos (Packaging & Label) | βοΈ | Clear image of roll end, label info, brand, model |
| β Commercial Invoice | βοΈ | Must describe as "Photographic Film, Color, 220 Roll, Unexposed" |
| β Packing List | βοΈ | Detail quantity per roll, number of rolls per box |
| β Certificate of Origin (CO) | βοΈ | If origin is not China, may qualify for lower rates (but IEEPA may still apply) |
| β Third-Party Test Report | βοΈ | Optional but helpful: Safety data, material composition |
β 2. Declaration Tips (Key Mantra)
π₯ "Specify Format, State Exposure, Clarify Base β Avoid 38.7% Traps!"
| Situation | Correct Declaration | Incorrect Practice |
|---|---|---|
| Unexposed Color Film 220 | 3702.31.01.00 (38.7%) |
Declare as "Camera Accessories" β Risk of penalty |
| Exposed Film (Used) | 3707.90.60.00 (35.0%) |
Declare as "New Film" β Wrong classification |
| Film with Paper Backing | May fall under 3701.91 (38.7%) |
Claim as "Non-paper" without proof β Audit risk |
| Bulk Roll (Not Retail Pack) | Check if it fits "Retail Form" | Generic description "Film" β Delayed clearance |
β 3. Special Case Handling
| Scenario | Handling Advice |
|---|---|
| OEM Custom Film | Provide client order + design specs. Do not claim "generic" if it's custom-branded. |
| Mixed Shipment (Film + Camera) | Declare separately. Camera = 8525/8528, Film = 3702/3707. Do not bundle under one HS Code. |
| Film for Medical/Industrial X-ray | If itβs X-ray film, it may still be 3702, but ensure "Photographic" is not misleading if used for non-photographic imaging. |
| Origin: Vietnam/Mexico | May qualify for IEEPA Exemption (0-5% tax). Ensure CO is valid and supply chain is traceable. |
π V. Global Market Comparison for "Color Film 220" (2026)
| Country/Region | Recommended HS Code | Tariff Rate (China Origin) | Certification Requirements | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3702.31.01.00 |
38.7% | No special cert. | High due to 301+IEEPA. |
| π¨π³ China | 3702.31.01.00 |
~3.7% | No special cert. | Low import tax. |
| πͺπΊ EU | 3702.31.00 |
0% | CE (if packaging claims) | No additional tariffs for analog film. |
| π¬π§ UK | 3702.31.00 |
0% | UKCA (if applicable) | Post-Brexit, 0% for many goods. |
| π―π΅ Japan | 3702.31.00 |
0% | PSE (if electronic components) | No tariff for photographic film. |
π Conclusion:
- USA is the most expensive market for Color Film 220 due to the 38.7% total rate.
- EU/UK/Japan are tariff-free (0%), making them more competitive for Chinese exports.
- Strategy: Consider transshipment or final assembly in a third country (Vietnam/Mexico) to mitigate IEEPA duties, if feasible and compliant with rules of origin.
π VI. Common Mistakes & Pitfall Guide (Lessons Learned)
β Mistake 1: Declaring "Color Film 220" as "Photographic Paper"
π Consequence: Wrong HS Code β 3707 vs 3702 mismatch β Audit & Penalty.
β Mistake 2: Omitting "Unexposed" in the description
π Consequence: Customs may assume it's "exposed" (3707) or reject as "sensitive material" β Delay.
β Mistake 3: Claiming "Retail Packaging" when it's bulk
π Consequence: If the code requires "retail form," bulk shipment may be misclassified β Rejection.
β Mistake 4: Ignoring IEEPA 10% Surtax
π Consequence: Underestimating cost by 10% β Profit Margin Erosion.
β Correct Declaration Example:
"Photographic Film, Color, 220 Roll Format, Unexposed, on Non-Paper Base, for Analog Cameras, Model XYZ, Origin: China"
π― VII. Conclusion: Professional Declaration, Cost Efficiency, Risk Mitigation
π― Remember the Mantra:
πΉ "Specify 220, State Unexposed, Choose 3702 for Accuracy!"
πΉ "Base 3.7% + 35% Add-ons = 38.7% β Plan Ahead!"
πΉ "China Origin to US? Budget for 38.7% or Re-route!"
π Pro Tip:
If your Color Film 220 is produced in Vietnam, Mexico, Thailand, or Malaysia, you may qualify for IEEPA Exemption, reducing the rate to 0%~5%.
Recommend Advance Ruling (Pre-classification) with US CBP to confirm the exact HS Code and avoid post-import audits.
π£ Immediate Action:
π Contact a Licensed Customs Broker + Provide Product Specs + Apply for Pre-Classification
π Ensure Smooth Clearance, Minimize Duties, Maximize Profit!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every Percent of Tax Matters in Global Trade!
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.