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Color Film Roll (Outdoor)

CN β†’ US
HS Code Tariff Rate Origin Destination Doc
3919102055 40.8% CN US Official Doc
3920992000 39.2% CN US Official Doc
3920200055 39.2% CN US Official Doc
3702980000 38.7% CN US Official Doc
3919905060 40.8% CN US Official Doc
3702390100 38.7% CN US Official Doc

AI Analysis

πŸŽ₯ Color Film Roll (Outdoor) β€” Comprehensive HS Code Guide & Customs Clearance Strategy


🌐 HS Code Reference & Customs Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
πŸ“Œ I. Product Definition & Classification: What is "Color Film Roll (Outdoor)"?

The product "Color Film Roll (Outdoor)" typically refers to flexible, roll-shaped materials used for outdoor applications. In international trade, the classification hinges on two critical factors: 1. Material Composition: Is it plastic/polymer-based (e.g., PVC, PE, PP) or photographic/sensitive emulsion-based? 2. Usage/Purpose: Is it for photography/imaging (sensitized material) or general utility/construction (non-imaging)?

⚠️ Critical Distinction Point:
- If it is a plastic/polymer film (e.g., banners, protective coverings, agricultural mulch) β†’ Chapter 39 (Plastics).
- If it is sensitized photographic film (used for cameras/sensors) β†’ Chapter 37 (Photographic Goods).
Note: Without explicit confirmation of "photographic sensitivity," the default assumption for "Outdoor Film" is often plastic/polymer, but photographic alternatives must be considered if the context implies imaging.


πŸ“¦ II. HS Code Classification Details (Based on Provided Data)

The following HS Codes are derived from the provided dataset, categorized by material and function:

HS Code Product Description Matching Logic (Summary) Tax Category
3919.10.20.55 Self-Adhesive Plastics Plates/Sheets/Film Material: Plastic (inferred).
Form: Film/Foil.
Reason: Fits "Other" fallback for plastic films.
High (40.8%)
3920.99.20.00 Other Plates, Sheets, Film, Non-Adhesive Form: "Film Roll" matches "films/plates".
Material: Plastic (inferred from common sense).
Medium (39.2%)
3920.20.00.55 Polypropylene Plates/Sheets/Film Material: PP (Polypropylene) or similar polymer inferred from outdoor use.
Form: Film.
Medium (39.2%)
3702.98.00.00 Other Sensitized Photographic Film Form: Roll.
Use: Photographic/Imaging (Sensitized).
Material: Non-paper, non-textile (sensitized).
Medium (38.7%)
3919.90.50.60 Other Self-Adhesive Plastic Plates/Sheets Form: Film.
Material: Plastic (inferred for outdoor use).
High (40.8%)
3702.39.01.00 Other Sensitized Photographic Film in Rolls Form: Roll.
Use: Sensitized/Film.
Material: Non-paper/textile (sensitized).
Medium (38.7%)

πŸ” Key Insight:
- Plastic Films (Ch 39): 3919.10.20.55 and 3919.90.50.60 have the highest total tax (40.8%).
- Polypropylene Film: 3920.20.00.55 has a slightly lower tax (39.2%).
- Photographic Film (Ch 37): 3702.98.00.00 and 3702.39.01.00 have the lowest total tax (38.7%).
Decision must be made based on whether the product is plastic (utility) or photographic (imaging).


πŸ’° III. 2026 Latest Tariff Rate Breakdown (Including Surcharges)

βœ… Applicable Country: United States (US)
βœ… Origin: China (CN)
βœ… Effective Date: From November 10, 2025 (and subsequent imports)

🎯 1. Plastic Film Classifications (HS Codes: 3919.10.20.55, 3920.99.20.00, 3920.20.00.55, 3919.90.50.60)

These codes are subject to the standard "Section 301" and "IEEPA" surcharges for Chinese goods.

Item Content
Basic Duty Rate Varies by sub-code:
- 3919.10.20.55: 5.8%
- 3920.99.20.00 / 3920.20.00.55: 4.2%
- 3919.90.50.60: 5.8%
Section 301 Surcharge (USITC) +25.0% (Fixed for these plastic film categories)
IEEPA Surcharge (122 Clause) +10.0% (Specific to Chinese origin)
Total Tax Rate 40.8% (for 3919 codes)
39.2% (for 3920 codes)
Tax Calculation CIF Value Γ— Total Rate
De Minimis Eligibility ❌ Not Eligible (High tax rates typically disqualify de minimis benefits)
Legal Basis Path USITC:3919.10.20.55 β†’ FOOTNOTE:Section 301 β†’ IEEPA:122 Clause

πŸ“Œ Explanation:
- The 25% surcharge is due to the trade war measures (Section 301).
- The 10% surcharge is under the International Emergency Economic Powers Act (IEEPA).
- Total: 39.2% - 40.8%. This is a significant cost burden.

🎯 2. Photographic Film Classifications (HS Codes: 3702.98.00.00, 3702.39.01.00)

If the product is sensitized photographic film, it falls under Chapter 37, which has slightly lower base duties.

Item Content
Basic Duty Rate 3.7% (for both 3702.98.00.00 and 3702.39.01.00)
Section 301 Surcharge (USITC) +25.0%
IEEPA Surcharge (122 Clause) +10.0%
Total Tax Rate 38.7%
Tax Calculation CIF Value Γ— 38.7%
De Minimis Eligibility ❌ Not Eligible
Legal Basis Path USITC:3702.98.00.00 β†’ FOOTNOTE:Section 301 β†’ IEEPA:122 Clause

πŸ“Œ Note:
- While the base duty is lower (3.7% vs 4.2-5.8%), the surcharges remain the same (35%).
- Total: 38.7%. This is the lowest possible rate among the provided options, but only if the product qualifies as "sensitized photographic film."


πŸ› οΈ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)

βœ… 1. Essential Documentation Checklist (All Must Be Provided)

Document Required? Description
βœ… Product Specification Sheet βœ”οΈ Must clearly state: Material (Plastic vs. Gelatin/Emulsion), Dimensions, Roll Diameter, Width.
βœ… Material Composition Proof βœ”οΈ Crucial: Lab report or manufacturer declaration confirming if it is Polymer (Plastic) or Sensitized Photographic Material.
βœ… Product Photos βœ”οΈ Clear images of the roll, labeling, and packaging. Show if it has emulsion coating (for Ch 37) or is plain/printed plastic (for Ch 39).
βœ… Commercial Invoice βœ”οΈ Must accurately describe the product (e.g., "Outdoor Plastic Banner Film" vs. "Sensitized Photographic Film Roll").
βœ… Packing List βœ”οΈ Detail net/gross weight, number of rolls, and dimensions.
βœ… Origin Certificate (CO) βœ”οΈ Proof of Chinese origin to apply correct surcharges.
βœ… Third-Party Test Report βœ”οΈ If claiming specific polymer type (e.g., PP), provide test results.

βœ… 2. Declaration Tips (Key Mantra)

πŸ”₯ "Material Defines Chapter, Usage Defines Sub-code! Plastic = Ch 39, Photo = Ch 37!"

Scenario Correct Declaration Risk of Error
Outdoor Plastic Banner/Tarpaulin Film 3920.99.20.00 or 3919.10.20.55 If declared as Ch 37, customs may reject due to lack of photographic sensitivity.
Outdoor Plastic Protective Film 3920.99.20.00 Ensure it is not "self-adhesive" unless it fits 3919.
Sensitized Photographic Film (for Cameras) 3702.98.00.00 or 3702.39.01.00 If declared as Ch 39, you pay 39.2-40.8% instead of 38.7%. Small difference, but accuracy is key.
Unspecified "Film Roll" Provide Material Proof DO NOT guess. If material is unclear, customs will assign the highest applicable duty or hold the shipment.

βœ… 3. Special Situation Handling

Situation Handling Suggestion
Dual-Use Film (e.g., printed plastic with reflective properties) Classify as Plastic (Ch 39). It is not "sensitized" for imaging.
Photographic Film with Plastic Base Still Ch 37. The base material does not change the classification if the primary function is photographic sensitivity.
Outdoor LED Screen Film If it is a diffuser/optimizer film (plastic), use Ch 39. Do not confuse with Ch 85 (LEDs).
Customs Inquiry on "Outdoor" "Outdoor" is a usage term, not a classification term. Material is king. Provide data sheets to prove material type.

🌍 V. Global Market Customs Comparison (2026 Latest)

Country/Region Recommended HS Code (Plastic) Total Tax (China Origin) Certification Notes
πŸ‡ΊπŸ‡Έ USA 3920.99.20.00 39.2% No specific 301 + IEEPA apply
πŸ‡¨πŸ‡³ China 3920.99.20.00 ~5-6% CCC (if applicable) Low tariff, no surcharges
πŸ‡ͺπŸ‡Ί EU 3920.99.90 ~6.5% CE (if electronic) No 301/IEEPA surcharges
πŸ‡¦πŸ‡Ί Australia 3920.99.90 ~5% RCM Moderate tariff

πŸ“Œ Conclusion:
- The US market imposes the highest effective tax rate (39.2-40.8%) due to political surcharges.
- Material proof is the single most important document to avoid misclassification penalties.


πŸ“Œ VI. Common Errors & Pitfall Guide (Blood-Tested Lessons)

❌ Error 1: Declaring "Plastic Film" as "Photographic Film" to save taxes.
πŸ‘‰ Consequence: Customs inspection reveals no emulsion. Penalty + Back Tax + 1778 Protest.
❌ Error 2: Ignoring the "IEEPA 10%" surcharge.
πŸ‘‰ Consequence: Underpayment of 10% of CIF value. Fines and delays.
❌ Error 3: Vague description "Film Roll" on Invoice.
πŸ‘‰ Consequence: Customs cannot determine Chapter 37 vs. 39. Shipment held for examination.
❌ Error 4: Using "Self-Adhesive" (3919) when the film is not adhesive.
πŸ‘‰ Consequence: Misclassification. Refund process required.

βœ… Correct Approach:

"Outdoor Polypropylene Film Roll, Non-Adhesive, Width 1.2m, Length 100m, Plain White, For Agricultural Covering"
OR
"Sensitized Black and White Photographic Film, Roll, 120mm Width, Not yet Developed, For Professional Photography"


🎯 VII. Conclusion: Precision Declaration Saves Money!

🎯 Remember the Mantra:

πŸ”Ή "Plastic is Ch 39, Photo is Ch 37!"
πŸ”Ή "US Tariff = Basic + 25% + 10%!"
πŸ”Ή "Material Proof is Your Best Friend!"


πŸ“Œ Pro Tip:
If the product is plastic film, try to qualify for 3920.20.00.55 (PP) if it is indeed polypropylene, as it has a slightly lower base duty (4.2% vs 5.8%).
For photographic film, ensure it is sensitized to qualify for 38.7% total tax.


πŸ“£ Immediate Action:

πŸ“ž Contact your customs broker with the Material Data Sheet.
πŸ“ Verify if it is Plastic or Photographic.
πŸš€ Declare accurately to avoid costly delays and penalties!


✨ Professional clearance starts with precise classification!
πŸ’Ό Your profit margin depends on this 1% difference in HS Code!

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.