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Color Positive Film (Long Roll)

CN β†’ US
HS Code Tariff Rate Origin Destination Doc
3702530060 38.7% CN US Official Doc
3702520160 38.7% CN US Official Doc
3920992000 39.2% CN US Official Doc
3921905050 39.8% CN US Official Doc
4811904090 35.0% CN US Official Doc

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🎞️ Color Positive Film (Long Roll) – The Ultimate Guide to Classification & Customs Clearance


🌐 HS Code Reference & Customs Strategy | 2026 Latest Tariff Analysis | Professional Clearance Guide
πŸ“Œ 1. Product Definition: What is "Color Positive Film (Long Roll)"?

Color Positive Film (often known as Reversal Film or Slide Film) is a type of photographic film that produces a positive image (directly viewable without projection, though usually projected for viewing). Unlike negative film, it records colors in their true tones.

Long Roll refers to the physical format: a continuous, uncut strip of film wound on a spool, rather than pre-cut individual frames in a canister. This format is typically used for: - Large format photography (sheet film or roll film for medium/large format cameras) - Aerial photography - Specialized industrial or scientific imaging

⚠️ Key Distinction:
- If it is photographic film (light-sensitive emulsion on a plastic base) β†’ It falls under Chapter 37 (Photographic/ cinematographic goods).
- If it is transparent plastic sheeting/film with no light-sensitive emulsion β†’ It falls under Chapter 39 (Plastics).
- If it is paper-based photographic paper (rare for "film" but possible if mislabeled) β†’ Chapter 48.


πŸ“¦ 2. HS Code Classification Details (2026 Latest Tariff Alignment)

Based on the product name "Color Positive Film (Long Roll)", here are the potential HS Codes and why they match (or do not match), along with their total tax rates.

HS Code Product Description Match Logic & Summary Total Tax Rate
3702.53.00.60 Color Positive Film (Reversal Film) βœ… BEST MATCH
β€’ "Color Positive Film" directly matches "Color Positive Film" in HS 3702.53.
β€’ "Long Roll" fits the "roll" form factor.
β€’ Material is inferred as light-sensitive photographic material.
β€’ No material conflict.
38.7%
3702.52.01.60 Other Color Negative Film ⚠️ Partial Match (Risk)
β€’ "Color Film" matches, but "Positive" contradicts "Negative" in 3702.52.
β€’ However, if the "Positive" aspect is ignored or misidentified, it falls under "Other Color Film".
β€’ Base material: Non-paper, non-textile.
38.7%
3920.99.20.00 Plastic Film, Other ⚠️ Fallback Option
β€’ Matches "Film" and "Roll" form.
β€’ Assumes material is plastic (common base for film).
β€’ Ignores the "Photographic" aspect. Only valid if it’s unexposed, non-sensitive plastic sheeting.
39.2%
3921.90.50.50 Plastic Plates, Sheets, Film ⚠️ Fallback Option
β€’ Matches "Film" and "Roll".
β€’ Infers plastic material from "Roll Film".
β€’ "Other" category for plastic films. Valid only if not photographic.
39.8%
4811.90.40.90 Paper/Film, Other ⚠️ Low Probability
β€’ Matches "Roll" form.
β€’ Assumes material is cellulose/film-like paper.
β€’ Low tax rate, but unlikely for true "photographic film".
35.0%

πŸ” Critical Note:
- HS 3702.53.00.60 is the most accurate for true photographic positive film.
- If the product is not light-sensitive (e.g., clear plastic sheet for packaging), use 3920.99.20.00 or 3921.90.50.50.
- Misclassifying photographic film as plastic film (Ch. 39) can lead to severe penalties due to duty evasion (38.7% vs. 39.2% is close, but if it’s actually paper, 35% might be tempting but risky if it’s clearly plastic-based).


πŸ’° 3. 2026 Latest Tariff Breakdown (US Import from China)

βœ… Applicable Country: United States (US)
βœ… Origin: China (CN)
βœ… Effective Date: November 10, 2025 onwards

🎯 Option 1: 3702.53.00.60 (Color Positive Film) – Recommended

Item Detail
Base Duty 3.7%
Section 301 Duty (25%) +25.0%
IEEPA Duty (10%) +10.0%
Total Effective Rate 38.7%
Calculation CIF Value Γ— 38.7%
De Minimis Exemption? ❌ NO (Deny de minimis)
Legal Basis IEEPA:9903.01.25 β†’ USITC:3702.53.00.60 β†’ FOOTNOTE:9903.88.01

πŸ“Œ Explanation:
- 3.7% is the standard MFN (Most Favored Nation) rate for photographic film.
- 25% is the Section 301 tariff on Chinese goods.
- 10% is the IEEPA tariff on Chinese goods.
- Total: 38.7%. This is a high-duty item.
- No de minimis exemption: Even small shipments are subject to full duty.

🎯 Option 2: 3702.52.01.60 (Other Color Film) – Alternative

Item Detail
Base Duty 3.7%
Section 301 Duty (25%) +25.0%
IEEPA Duty (10%) +10.0%
Total Effective Rate 38.7%
Calculation CIF Value Γ— 38.7%
De Minimis Exemption? ❌ NO

πŸ“Œ Note: Same tax rate as 3702.53.00.60, but classification risk if the film is explicitly "Positive" (Reversal).

🎯 Option 3: 3920.99.20.00 (Plastic Film) – If Non-Photographic

Item Detail
Base Duty 4.2%
Section 301 Duty (25%) +25.0%
IEEPA Duty (10%) +10.0%
Total Effective Rate 39.2%
Calculation CIF Value Γ— 39.2%
De Minimis Exemption? ❌ NO

πŸ“Œ Note: Slightly higher total duty than photographic film, but safer if the product is not light-sensitive.

🎯 Option 4: 4811.90.40.90 (Paper/Film) – Low Duty Option

Item Detail
Base Duty 0.0%
Section 301 Duty (25%) +25.0%
IEEPA Duty (10%) +10.0%
Total Effective Rate 35.0%
Calculation CIF Value Γ— 35.0%
De Minimis Exemption? ❌ NO

πŸ“Œ Note: Lowest tax rate (35%), but only applicable if the product is paper-based or non-plastic, non-photographic. If it’s clear plastic photographic film, this is incorrect and risky.


πŸ› οΈ 4. Customs Clearance Advice (Practical Pitfall Guide)

βœ… 1. Preparation Checklist (Non-Negotiable)

Document Required? Purpose
βœ… Product Specification Sheet βœ”οΈ Must state: "Light-sensitive emulsion", "Reversal/Positive", "Long Roll format".
βœ… Material Composition Report βœ”οΈ Confirm base material (usually cellulose acetate or PET plastic).
βœ… Product Photos βœ”οΈ Show the roll, packaging, and any labeling indicating "Positive" or "Reversal".
βœ… Commercial Invoice βœ”οΈ Clearly describe as "Color Positive Film (Reversal Film), Long Roll, for Photography".
βœ… HS Code Ruling (Pre-Ruling) βœ”οΈ Highly Recommended to secure 3702.53.00.60.

βœ… 2. Classification Strategy (Key Mnemonics)

πŸ”₯ "Positive Film = Ch 37; Plastic Sheet = Ch 39; Paper = Ch 48"

Scenario Correct HS Code Why?
True Photographic Slide Film 3702.53.00.60 Matches "Color Positive" and "Light-sensitive".
Unexposed Plastic Sheeting 3920.99.20.00 No emulsion, just plastic.
Photographic Paper Roll 4811.90.40.90 If base is paper, not plastic.
Mislabelled as "Plastic Film" 3920.99.20.00 Risky: If customs tests and finds emulsion, you’ll be penalized.

βœ… 3. Special Cases

Situation Advice
OEM/Custom Order Provide customer PO and technical specs to prove "Positive" nature.
Mixed Shipments (Film + Accessories) Declare film separately from lenses/cameras (Ch 90/85).
Small Sample Shipments No de minimis exemption for China-origin goods. Pay full duty.
Origin Marking Must clearly mark "Made in China" on packaging.

🌍 5. Global Market Comparison (2026)

Country/Region Recommended HS Code Duty Rate (China Origin) Notes
πŸ‡ΊπŸ‡Έ USA 3702.53.00.60 38.7% High duties due to Section 301 + IEEPA.
πŸ‡¨πŸ‡³ China 3702.53.00.60 ~6-10% Import duty for Chinese market.
πŸ‡ͺπŸ‡Ί EU 3702.53.00.60 0-6% No Section 301/IEEPA equivalent.
πŸ‡―πŸ‡΅ Japan 3702.53.00.60 ~0-6% No additional punitive tariffs.

πŸ“Œ Conclusion:
- USA is the most expensive market due to 38.7% total duty.
- EU/Japan are more favorable for photographic film imports.
- If targeting the US, consider tariff engineering (e.g., importing components separately if applicable, though rare for film) or supply chain diversification (if possible).


πŸ“Œ 6. Common Mistakes & Pitfalls (Learn from Others’ Errors)

❌ Mistake 1: Classifying Positive Film as Negative Film (3702.52)
πŸ‘‰ Risk: Minor, as tax rate is same (38.7%), but incorrect declaration can lead to audits.

❌ Mistake 2: Classifying Photographic Film as Plastic Film (3920)
πŸ‘‰ Risk: Underpayment of duty if base duty is lower, but higher risk of penalties if customs detects emulsion. Tax difference is small (38.7% vs 39.2%), but compliance risk is high.

❌ Mistake 3: Assuming De Minimis Exemption applies
πŸ‘‰ Risk: Full duty collection on all shipments, including small samples. No de minimis for China-origin goods.

βœ… Best Practice:

Always declare as "Color Positive Film (Reversal Film), Long Roll, Light-Sensitive".
Use HS 3702.53.00.60 for accuracy.
Prepare technical specifications to prove light-sensitive nature.


🎯 7. Final Recommendation

🎯 For "Color Positive Film (Long Roll)":

  1. Primary Classification: 3702.53.00.60 (Color Positive Film)
  2. Tax Rate: 38.7%
  3. Reason: Most accurate match for "Color Positive" and "Roll" format.

  4. Alternative if Non-Photographic: 3920.99.20.00 (Plastic Film)

  5. Tax Rate: 39.2%
  6. Reason: Only if no emulsion is present.

  7. Lowest Duty (Risky): 4811.90.40.90 (Paper/Film)

  8. Tax Rate: 35.0%
  9. Reason: Only if paper-based. Avoid for plastic-based photographic film.

πŸ“£ Action Step:
- Contact a customs broker for a pre-ruling if unsure.
- Label products clearly as "Photographic Film, Positive, Long Roll".
- Budget for 38.7% duty for US imports from China.


✨ Professional Clearance Starts with Accurate Classification!
πŸ’Ό Your cost efficiency depends on every digit of the 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.