Color Film Custom Length
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3920991000 | 41.0% | CN | US | Official Doc |
| 4823906700 | 35.0% | CN | US | Official Doc |
| 4823400000 | 35.0% | CN | US | Official Doc |
| 3921904090 | 39.2% | CN | US | Official Doc |
| 3920992000 | 39.2% | CN | US | Official Doc |
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AI Analysis
ποΈ Custom Length Color Film & Optically Clear Adhesives (2026 Customs Guide)
π HS Code Reference & Clearance Strategy | Latest Tariff Analysis | Professional Compliance Guide
π I. Product Definition & Classification: What is "Custom Length Color Film"?
In international trade, "color film custom length" is a broad term that usually falls into two distinct categories based on its material and application. The HS Code classification depends entirely on whether the item is optical adhesive materials for manufacturing screens or plastic film materials for general packaging/industrial use.
Category A: High-Tech Optical Adhesives (Optically Clear Adhesives - OCA)
These are specialized polymer-based adhesives (from headings 3901β3913) used solely or principally for manufacturing Flat Panel Displays (FPD) or Touch-Sensitive Screens. If the product is a liquid adhesive or free-film adhesive designed for screen lamination, it is not treated as a standard plastic film.
Category B: General Plastic Films & Strips
These are non-cellular plastic plates, sheets, films, or strips that are flexible. If the product is a generic color plastic film (e.g., for packaging, lamination, or industrial covering) cut to a specific length, it falls under Chapter 39. The thickness and roll vs. cut status determine the exact subheading.
β οΈ Key Distinction Point:
- If the product is an adhesive used for making phone/computer screens β Go to 3506.91 (Prepared Glues).
- If the product is a plastic sheet/film (color or transparent) cut to size β Go to 3920.99 or 3921.90 (Plastics).
- Do not confuse "optical clear adhesive" with "colored plastic film."
π¦ II. HS Code Classification Details (2026 Latest Tariff Alignment)
Based on the provided data, here are the specific HS Codes for products that might fit the description of "color film," "custom length," or related optical materials.
| HS Code | Product Description | Application Scenario | Material Type |
|---|---|---|---|
3506.91.10.00 |
Optically clear free-film adhesives and curable liquid adhesives for Flat Panel Displays or Touch Screens | Smartphone screens, LCD monitors, Touch panels (used solely for display manufacturing) | Adhesive (Polymer-based) |
3506.91.50.00 |
Other prepared adhesives based on polymers (not exceeding 1kg retail) | General industrial glues, small retail packs of specialized adhesives | Adhesive (General) |
3920.99.10.00 |
Other plastic plates/sheets/film, flexible, over 0.152 mm thickness, not in rolls (cut to custom length) | Industrial plastic sheets, protective films cut to specific sizes, non-roll plastic films | Plastic Film (Thick) |
3920.99.20.00 |
Other plastic plates/sheets/film, flexible, other thicknesses (not in rolls) | Generic color plastic films cut to length, industrial sheeting | Plastic Film (Various) |
3921.90.50.50 |
Other plastic plates/sheets/film, flexible, other | Laminated films, supported plastics, colored flexible films | Plastic Film (Other) |
3921.90.40.90 |
Other plastic plates/sheets/film, flexible (non-cellular, not reinforced) | Standard flexible plastic films (packaging, covering) | Plastic Film (Standard) |
4823.40.00.00 |
Rolls, sheets, dials, printed for self-recording apparatus | Thermal paper, chart paper (if "color film" refers to recording paper) | Paper |
4823.90.67.00 |
Other articles of paper/paperboard, coated | Coated paper products (if "film" refers to coated paper strips) | Paper |
π Critical Note:
- Adhesives (3506.91): If your "custom length color film" is actually an adhesive tape or film used to bond display layers, it belongs here.
- Plastics (3920/3921): If your product is a raw plastic material (colored or clear) cut to a custom length for wrapping, covering, or assembly, it belongs here.
- Thickness Matters: For HS3920.99, whether the film is >0.152mm or <0.152mm changes the code significantly.
π° III. 2026 Latest Tariff Rate Breakdown (Detailed Analysis)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: 2025/2026 Tariff Regime
π― 1. 3506.91.10.00 β Optically Clear Adhesives for Displays
| Item | Details |
|---|---|
| Base Duty Rate | 0.0% |
| Additional Tariff (Section 301) | +25.0% |
| Total Tax Rate | 25.0% |
| Calculation | CIF Value Γ 25% |
| De Minimis Exemption? | β NO (Deny de minimis) |
| Legal Basis | Section 301 Tariffs on Chinese Products |
π Explanation:
- Although the base duty is 0%, the 25% Section 301 tariff applies heavily to high-tech adhesives from China.
- This is a high-cost item for importers. Ensure the product is clearly defined as "for Flat Panel Displays" to avoid misclassification into higher-tariff general adhesive codes.
π― 2. 3920.99.10.00 β Thick Plastic Film (Not in Rolls, >0.152mm)
| Item | Details |
|---|---|
| Base Duty Rate | 0.0% |
| Additional Tariff | 0.0% |
| Total Tax Rate | 0.0% |
| Calculation | Free |
| De Minimis Exemption? | β Yes (if under threshold) |
| Legal Basis | No Section 301 penalty for this specific subheading |
π Advantage:
- If your custom-length film is thick (>0.152mm) and not in rolls, it enjoys 0% total duty. This is the most cost-effective classification for thick plastic sheets.
π― 3. 3920.99.20.00 β Other Plastic Films (Not in Rolls)
| Item | Details |
|---|---|
| Base Duty Rate | 4.2% |
| Additional Tariff | +25.0% |
| Total Tax Rate | 29.2% |
| Calculation | CIF Value Γ 29.2% |
| De Minimis Exemption? | β No (on the additional portion) |
π Risk:
- If the film is thin (<0.152mm) or classified as "other," the tax jumps to 29.2%. Be precise about thickness measurements in your commercial invoice.
π― 4. 3921.90.50.50 β Other Flexible Plastic Films
| Item | Details |
|---|---|
| Base Duty Rate | 4.8% |
| Additional Tariff | +25.0% |
| Total Tax Rate | 29.8% |
| Calculation | CIF Value Γ 29.8% |
π Warning:
- This is the highest tax rate in the dataset. Avoid this code unless the product is clearly "other" plastic film (e.g., laminated or reinforced). Use3920series if itβs non-laminated.
π― 5. 3921.90.40.90 β Standard Flexible Plastic Film
| Item | Details |
|---|---|
| Base Duty Rate | 0.0% |
| Additional Tariff | 0.0% |
| Total Tax Rate | 0.0% |
| Calculation | Free |
π Opportunity:
- If the product is a standard flexible plastic film (non-laminated, non-cellular) and fits this specific "other flexible" description, it is tax-free. This is often the best case for generic color films.
π― 6. 4823.40.00.00 & 4823.90.67.00 β Paper-Based Products
| Item | Details |
|---|---|
| Total Tax Rate | 25.0% |
| Base Duty | 0.0% |
| Additional Tariff | 25.0% |
π Note:
- Only applies if "color film" is actually printed paper (e.g., thermal paper for charts). High tariff applies due to Section 301.
π οΈ IV. Customs Clearance Practical Advice (Pitfall Avoidance)
β 1. Document Preparation Checklist
| Document | Required? | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must specify Material (Plastic vs. Adhesive), Thickness (critical for 3920), and Form (Roll vs. Cut Sheet). |
| β Commercial Invoice | βοΈ | Clearly state "Custom Cut Plastic Film" or "Optically Clear Adhesive for Displays." Avoid vague terms like "Color Film." |
| β Photos of Product | βοΈ | Show the cross-section (for thickness), packaging, and any labels indicating adhesive vs. plastic. |
| β Certificate of Origin | βοΈ | To prove origin and apply correct Section 301 rates. |
| β Third-Party Test Report | βοΈ | If claiming 0% duty, proof of material composition may be requested. |
β 2. Classification Strategy (Key Mantra)
π₯ "Adhesive for Screens = 3506 (25%); Thick Plastic Cut = 3920.99.10 (0%); Thin Plastic Cut = 3920.99.20 (29.2%); Generic Film = 3921.90.40 (0%)"
| Scenario | Correct HS Code | Tax Rate | Risk Level |
|---|---|---|---|
| OCA Tape for iPhone Screen | 3506.91.10.00 |
25% | β Accurate |
| Thick PVC Sheet (>0.152mm), Cut to 1m | 3920.99.10.00 |
0% | β Low Risk |
| Thin PET Film (<0.152mm), Cut to 1m | 3920.99.20.00 |
29.2% | β οΈ High Cost |
| Standard Flexographic Film Roll | 3921.90.40.90 |
0% | β Low Risk |
| Laminated Color Film | 3921.90.50.50 |
29.8% | β οΈ High Cost |
β 3. Special Handling Tips
| Situation | Advice |
|---|---|
| "Custom Length" Claim | Customs may view "custom length" as "cut to size." If itβs not in rolls, ensure itβs classified under the "not in rolls" subheadings (e.g., 3920.99.10.00). |
| Adhesive vs. Plastic | If the product has a sticky side, it is an adhesive (3506), not a plastic film (3920). Misclassification leads to penalties. |
| Thickness Verification | For 3920.99, the 0.152mm threshold is critical. Provide micrometer test results if challenged. |
| Origin Marking | Ensure all products and packaging clearly state "Made in China" to avoid anti-circumvention investigations. |
π V. Global Market Comparison (2026)
| Region | Recommended HS Code | Est. Duty (China Origin) | Key Certification |
|---|---|---|---|
| πΊπΈ USA | 3506.91.10.00 / 3920.99.10.00 |
25% / 0% | None specific |
| πͺπΊ EU | 3506.91 / 3920 |
0% / 6.5% | REACH, RoHS |
| π¨π³ China | 3506.91 / 3920 |
2% / 5-6% | CCC (if applicable) |
π Conclusion:
- The US market is highly sensitive to the 25% Section 301 tariff on many of these items.
- Strategy: If possible, classify under 0% duty codes (3920.99.10.00or3921.90.40.90) by ensuring the product is plastic (not adhesive) and fits the specific physical descriptors (thickness, roll status).
- For Optical Adhesives, the 25% tax is unavoidable for Chinese origin; factor this into pricing.
π VI. Common Mistakes & Pitfalls
β Mistake 1: Calling an OCA adhesive "Plastic Film"
π Consequence: Customs reclassifies to 3506.91.10.00 β 25% tax instead of potential 0%.
β Mistake 2: Ignoring Thickness for Plastic Films
π Consequence: Misclassifying thin film as thick film β 29.2% tax vs 0%.
β Mistake 3: Vague Description "Color Film"
π Consequence: Customs delays for inspection β Port fees & demurrage costs.
β Correct Approach:
"Optically Clear Adhesive Film, 100um thickness, for LCD Assembly, 1m Length"
OR
"PVC Plastic Sheet, 0.2mm Thickness, Cut to 1m Length, Color Blue"
π― VII. Conclusion: Precision Saves Money!
π― Key Takeaway:
πΉ Adhesives for Screens = 25% Tax (High Cost)
πΉ Thick Plastic Sheets (>0.152mm) = 0% Tax (Low Cost)
πΉ Thin Plastic Films = 29.2% Tax (High Cost)
π Pro Tip:
If you are importing custom length films, ensure your commercial invoice explicitly states the material type, thickness, and form (roll vs. cut). This precision is your best defense against high tariffs.
π£ Action Item:
π Consult a Customs Broker to verify if your "color film" qualifies for the 0% duty categories (
3920.99.10.00or3921.90.40.90).
π Save up to 29.8% in taxes by correct classification!
β¨ Smart Classification, Smarter Profits!
πΌ Every percentage point in duty impacts your bottom line!
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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.