Color Film Roll (High Definition)
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3921905050 | 39.8% | CN | US | Official Doc |
| 4811904090 | 35.0% | CN | US | Official Doc |
| 3921904090 | 39.2% | CN | US | Official Doc |
| 3920992000 | 39.2% | CN | US | Official Doc |
| 3701910060 | 38.7% | CN | US | Official Doc |
AI Analysis
ποΈ Color Film Roll (High Definition)
π HS Code Reference & Clearance Guide | 2026 Latest Tariff Analysis | Professional Customs Strategy
π I. Product Definition & Classification: What Exactly Is "Color Film Roll"?
"Color Film Roll" refers to flexible, roll-shaped photosensitive materials used for capturing color images. In international trade, the classification hinges on material composition and specific photographic use.
Key Distinction:
- Plastic-based Films: The vast majority of modern "roll films" (including high-definition, photo, or industrial rolls) are made of polymers/plastics (e.g., polyester base). These fall under Chapter 39 (Plastics).
- Cellulose-based Films: Older or specialized non-plastic films fall under Chapter 48 (Paper/Paperboard).
- Professional Cinematic/Still Photography: Specific uses for color photography may trigger Chapter 37 (Photographic Films).
β οΈ Critical Classification Logic:
- If the film is plastic-based and not specifically for professional cinematography/still photography defined in Ch 37 β HS 3921 or 3920.
- If the film is non-plastic (e.g., cellulose) β HS 4811.
- If the film is explicitly for color photography (still or motion picture) and meets Ch 37 criteria β HS 3701.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, here are the most likely HS Code candidates for "Color Film Roll (High Definition)":
| HS Code | Product Description | Match Logic | Material/State |
|---|---|---|---|
3921.90.50.50 |
Other plates, sheets, film, foil, and strip, of plastics | High Confidence: "Film" + "Roll" implies plastic polymer base. Matches "Other" plastic films. | Plastic (Polymers) |
3921.90.40.90 |
Other plates, sheets, film, foil, and strip, of plastics | High Confidence: Similar to above; specific subheading for plastic films not elsewhere specified. | Plastic (Polymers) |
3920.99.20.00 |
Other plates, sheets, film, foil, and strip, of plastics, non-cellulosic | High Confidence: "Wide Width Roll Film" often falls here. Plastic-based, no specific other classification. | Plastic (Non-cellulosic) |
4811.90.40.90 |
Other paper and paperboard, coated, painted, covered, impregnated | Medium Confidence: If the film is cellulose-based (not plastic), it fits here. "Roll" state matches. | Cellulose/Paper-based |
3701.91.00.60 |
Photographic plates and film, sensitized, unexposed: Other color plates and film | Specific Use Match: If the product is specifically for color photography (still or motion), this is the precise category. | Photographic Material |
π Key Reminder:
- Most common consumer/industrial "Color Film Rolls" are plastic-based and may be classified under HS 3921 or 3920 unless they are explicitly sensitized photographic film (which falls under 3701).
- HS 3701 is the most accurate if the film is light-sensitive and for photography.
- HS 3921/3920 applies if it is a general-purpose plastic film (e.g., packaging, protective) with color, not for photography.
- HS 4811 applies only if it is cellulose-based (rare for modern HD films).
π° III. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: From November 10, 2025 onwards (for subsequent imports)
π― 1. 3921.90.50.50 & 3921.90.40.90 & 3920.99.20.00 ββ Plastic Films (General/Photographic)
| Item | Details |
|---|---|
| Base Tariff | 4.2% - 4.8% (Ad Valorem) |
| Section 301 Tariff | +25.0% (USITC Footnote 9903.88.01 / 9903.88.02) |
| IEEPA Surcharge | +10.0% (Against China/HK products, effective Nov 10, 2025) |
| Total Tax Rate | 39.2% - 39.8% |
| Tax Calculation | CIF Value Γ (39.2% ~ 39.8%) |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3921.90.50.50 / 3920.99.20.00 β FOOTNOTE:9903.88.01 |
π Explanation:
- "Section 301 Tariff 25%": Comes from U.S. Trade Law Section 301, targeting Chinese imports.
- "IEEPA 10%": Additional surcharge under the International Emergency Economic Powers Act for Chinese-origin goods.
- Total ~39.8%: This is a high tariff bracket. Must be factored into cost calculations immediately.
π― 2. 4811.90.40.90 ββ Cellulose/Paper-based Rolls
| Item | Details |
|---|---|
| Base Tariff | 0.0% |
| Section 301 Tariff | +25.0% |
| IEEPA Surcharge | +10.0% |
| Total Tax Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35.0% |
| De Minimis Eligibility | β Not Eligible |
| Legal Basis Path | IEEPA:9903.01.24 β USITC:4811.90.40.90 β FOOTNOTE:9903.88.01 |
π Note:
- Slightly lower total rate (35%) due to 0% base tariff, but still subject to all surcharges.
- Only applicable if the film is non-plastic (cellulose/paper-based).
π― 3. 3701.91.00.60 ββ Color Photographic Film
| Item | Details |
|---|---|
| Base Tariff | 3.7% |
| Section 301 Tariff | +25.0% |
| IEEPA Surcharge | +10.0% |
| Total Tax Rate | 38.7% |
| Tax Calculation | CIF Value Γ 38.7% |
| De Minimis Eligibility | β Not Eligible |
| Legal Basis Path | IEEPA:9903.01.24 β USITC:3701.91.00.60 β FOOTNOTE:9903.88.01 |
π Note:
- If the film is sensitized and unexposed for color photography, this is the correct classification.
- Rate is 38.7%, very close to the plastic film rates.
π οΈ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)
β 1. Required Documentation Checklist (All Must Be Provided)
| Document | Mandatory? | Notes |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must specify: Material (Plastic/Cellulose), Usage (Photographic/General), Width, Length, HD Resolution. |
| β Material Composition Proof | βοΈ | Lab test or manufacturer declaration confirming Plastic vs. Cellulose base. |
| β Photos of Product & Label | βοΈ | Clear images of the roll, label, and any "Sensitized/Unexposed" markings. |
| β Commercial Invoice | βοΈ | Must clearly state "Color Film Roll, High Definition, [Material Type]". |
| β Packing List | βοΈ | Detail dimensions, weight, and roll count. |
| β Certificate of Origin (CO) | βοΈ | If applicable for non-China origin (to avoid surcharges). |
| β Third-Party Test Report | βοΈ | If claiming specific photographic standards. |
β 2. Declaration Tips (Key Mantra)
π₯ "Identify Material First, Then Use. Plastic β Ch39, Photo β Ch37, Paper β Ch48."
| Scenario | Correct Declaration | Common Mistake |
|---|---|---|
| Plastic Color Roll (General Use) | 3921.90.50.50 / 3921.90.40.90 / 3920.99.20.00 |
Misdeclare as "Photographic Film" β May trigger Ch37 scrutiny. |
| Plastic Color Roll (Photographic Use) | 3701.91.00.60 |
Misdeclare as "Plastic Film" β May be rejected if sensitized. |
| Cellulose Film Roll | 4811.90.40.90 |
Misdeclare as "Plastic" β Customs may demand proof, causing delays. |
| Unidentified "Film" | Provide Material Declaration | Ambiguous description β Leads to random inspection & delays. |
β 3. Special Cases Handling
| Case | Handling Advice |
|---|---|
| OEM Custom Film | Provide customer order + design specs to prove intended use. |
| Film for Medical/X-Ray | Must declare explicitly as "Non-Photographic/Industrial" to avoid Ch37 complexity. |
| Mixed Shipments (Plastic + Paper) | Declare separately with distinct HS Codes to avoid confusion. |
| High-Definition Marketing | "HD" is a marketing term; ensure technical specs support the chosen HS Code (material/use). |
π V. Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3701.91.00.60 or 3921.90.50.50 |
38.7% ~ 39.8% | None Specific | High tariffs due to Section 301 + IEEPA. |
| π¨π³ China | 3701.91.00.60 or 3921.90.50.50 |
Low/Moderate | CCC (if electronic) | No surcharges. |
| πͺπΊ EU | 3701.91.00 or 3920.99.00 |
0% ~ 4.2% | CE (if applicable) | No US-style surcharges. |
| π¦πΊ Australia | 3701.91.00 or 3920.99.00 |
5% ~ 10% | RCM | Moderate tariffs. |
| π―π΅ Japan | 3701.91.00 or 3920.99.00 |
0% ~ 3.5% | PSE (if electronic) | Low tariffs. |
π Conclusion:
- USA is the most challenging market for film imports from China due to the ~40% total tariff.
- EU/Asia offer significantly lower tariff burdens.
- Accurate material declaration (Plastic vs. Cellulose) is critical to avoid misclassification penalties.
π VI. Common Errors & Pitfall Guide (Lessons Learned)
β Mistake 1: Declaring "Color Film" as "Plastic Sheet" without specifying photographic use
π Consequence: May be accepted but could be reclassified by customs if found to be sensitized, leading to back-taxes.
β Mistake 2: Using "Photographic Film" for non-sensitized plastic rolls
π Consequence: Customs may reject Ch37, forcing reclassification to Ch39, causing delays.
β Mistake 3: Omitting material composition (Plastic vs. Cellulose)
π Consequence: Customs will request additional documentation, delaying clearance by weeks.
β Mistake 4: Ignoring IEEPA Surcharge
π Consequence: Underestimating landed cost by 10%. Budget accurately!
β Correct Practice:
"Color Film Roll, High Definition, Polyester Base, 35mm Width, [Sensitized/Unexposed], For [Photographic/Industrial] Use, Model XYZ."
π― VII. Conclusion: Professional Declaration, Save Time & Cost!
π― Remember the Mantra:
πΉ "Material First, Use Second. Plastic/Ch39, Photo/Ch37, Paper/Ch48."
πΉ "US Tariffs ~40%, Always Check IEEPA & Section 301."
πΉ "Ambiguous Declares = Delays & Penalties."
π Pro Tip:
If your film is not for photography but for packaging or protection, ensure it is declared as "Plastic Film" under HS 3921/3920 to avoid unnecessary Ch37 scrutiny.
If it is photographic, ensure it is sensitized and unexposed to fit HS 3701.
π£ Immediate Action:
π Contact a professional customs broker + Provide material specs + Apply for Advance Ruling if high volume.
π Ensure your film clears customs smoothly, avoids unexpected tariffs, and maximizes profit!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every cent of cost is worth precise calculation!
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.