Colored Dye Film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3919905060 | 40.8% | CN | US | Official Doc |
| 3919905040 | 40.8% | CN | US | Official Doc |
| 3921905050 | 39.8% | CN | US | Official Doc |
| 3921904090 | 39.2% | CN | US | Official Doc |
| 3921904090 | 39.2% | CN | US | Official Doc |
AI Analysis
π¨ Colored Dye Film (Anti-UV Plastic Membranes)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional-Level Compliance Strategy
π I. Product Definition & Classification: What Exactly is "Colored Dye Film"?
Colored Dye Film refers to plastic-based films or membranes that have been infused with colorants and functional additives (specifically UV inhibitors). In international trade, these products are primarily classified under Chapter 39 (Plastics and Articles Thereof). The critical distinction lies in whether the product possesses self-adhesive properties (sticky back) or is a non-adhesive plain film.
Key Distinctions: * Self-Adhesive Films (HS 3919): Products with an adhesive layer on one or both sides, ready for application (e.g., window tinting films, decorative stickers). * Non-Adhesive Films/Sheets (HS 3921): Plain plastic films without adhesive, often used for lamination, packaging, or industrial protection.
β οΈ Critical Identification Point:
- If the film has a pressure-sensitive adhesive layer β Classify under 3919 (Self-adhesive plates, sheets, film...).
- If the film is plain plastic with no adhesive β Classify under 3921 (Other plates, sheets, film, foil and strip...).
- Color and UV Resistance are product attributes, not primary classification drivers, but they confirm the material composition as plastic/polymer.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authoritative Comparison)
Based on the provided data, here is the detailed breakdown for Colored Dye Film. Note that all listed codes carry significant additional tariffs due to current trade policies (Section 301 & IEEPA).
| HS Code | Product Description | Classification Logic | Total Tax Rate |
|---|---|---|---|
3919.90.50.60 |
Colored Dye Film, Self-Adhesive | Self-adhesive plastic film. Classified under "Other self-adhesive plastic films/sheets." | 40.8% |
3919.90.50.40 |
Colored Dye Film, Self-Adhesive | Self-adhesive plastic sheet/film. Inferred as plastic/polymer, colored/UV-resistant. | 40.8% |
3921.90.50.50 |
Colored Dye Film, Non-Adhesive | Other plastic plates, sheets, films. Non-adhesive plastic film, colored/UV-resistant. | 39.8% |
3921.90.40.90 |
Colored Dye Film, Non-Adhesive | Other plastic films, foils, strips. Non-adhesive, plain plastic film. | 39.2% |
π Key Reminder:
- Self-Adhesive (3919) vs. Non-Adhesive (3921) is the primary sorting line.
- All codes listed above are subject to High Additional Tariffs.
- Color and Anti-UV features do not exempt the product from these high duties.
π° III. 2026 Latest Tariff Rate Breakdown (Including Additional Taxes & Policy Surcharges)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Time: Current applicable rates (Section 301 & IEEPA measures)
π― 1. 3919.90.50.60 & 3919.90.50.40 ββ Self-Adhesive Plastic Films
| Item | Content |
|---|---|
| Base Tariff | 5.8% |
| Section 301 Surcharge | +25.0% |
| 122 Clause Tariff | +10.0% |
| Total Tax Rate | 40.8% |
| Tax Calculation | CIF Value Γ 40.8% |
| De Minimis Exemption? | β NO (Deny de minimis) |
| Legal Basis Path | Base Tariff 5.8% + Section 301: 25% + 122 Clause: 10% |
π Explanation:
- 5.8% Base Tariff: Standard MFN rate for other self-adhesive plastic films.
- 25% Section 301: Additional tariff on Chinese-origin plastics under USTR List 4.
- 10% 122 Clause: Specific surcharge applicable to certain Chinese imports (likely referencing specific trade enforcement clauses).
- Total 40.8%: This is a very high effective rate. Importers must budget accordingly.
π― 2. 3921.90.50.50 ββ Other Plastic Plates, Sheets, Films (Non-Adhesive)
| Item | Content |
|---|---|
| Base Tariff | 4.8% |
| Section 301 Surcharge | +25.0% |
| 122 Clause Tariff | +10.0% |
| Total Tax Rate | 39.8% |
| Tax Calculation | CIF Value Γ 39.8% |
| De Minimis Exemption? | β NO |
| Legal Basis Path | Base Tariff 4.8% + Section 301: 25% + 122 Clause: 10% |
π Explanation:
- 4.8% Base Tariff: Standard MFN rate for other plastic films/plates.
- 25% Section 301: Same additional tariff as above.
- 10% 122 Clause: Same surcharge.
- Total 39.8%: Slightly lower than self-adhesive due to lower base rate.
π― 3. 3921.90.40.90 ββ Other Plastic Films, Foils, Strips (Non-Adhesive)
| Item | Content |
|---|---|
| Base Tariff | 4.2% |
| Section 301 Surcharge | +25.0% |
| 122 Clause Tariff | +10.0% |
| Total Tax Rate | 39.2% |
| Tax Calculation | CIF Value Γ 39.2% |
| De Minimis Exemption? | β NO |
| Legal Basis Path | Base Tariff 4.2% + Section 301: 25% + 122 Clause: 10% |
π Explanation:
- 4.2% Base Tariff: Lowest base rate among the options, often for generic "other" plastic films.
- 25% Section 301: Fixed additional tariff.
- 10% 122 Clause: Fixed surcharge.
- Total 39.2%: The lowest total rate in this dataset, but still extremely high.
π οΈ IV. Customs Clearance Practical Advice (Pitfall Avoidance Guide)
β 1. Required Documentation Checklist (All Items Mandatory)
| Document | Required? | Notes |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must clearly state: "Plastic Film," "Colored," "UV Resistant," and Adhesive Status (Yes/No). |
| β Material Composition Statement | βοΈ | Confirm polymer type (e.g., PET, PVC, PE). All are "Plastic." |
| β Commercial Invoice | βοΈ | Must describe as "Colored Dye Film, Plastic, Adhesive/Non-Adhesive." Avoid vague terms like "Decorative Material." |
| β Packing List | βοΈ | Weight and dimensions must match invoice. |
| β HS Code Pre-Ruling (Optional but Recommended) | βοΈ | Given the 40%+ tax rate, securing a pre-ruling can prevent disputes at customs. |
β 2. Declaration Tips (Key Mnemonics)
π₯ "Adhesive? 3919! No Adhesive? 3921! Color Doesn't Change Tariff, Base Rate Does!"
| Situation | Correct Declaration | Wrong Practice |
|---|---|---|
| Film has sticky backing | 3919.90.50.60 or 3919.90.50.40 |
Declare as 3921 β Risk of misclassification penalty |
| Plain film, no sticky layer | 3921.90.50.50 or 3921.90.40.90 |
Declare as 3919 β Risk of over-declaration or penalty |
| Product is "Window Tint" | Usually 3919 (if self-adhesive) |
Declare as general "plastic" β May trigger further inspection |
β 3. Special Cases Handling
| Situation | Handling Advice |
|---|---|
| OEM Custom Colors | Provide color swatches and formulation if requested. Does not change HS code. |
| Composite Materials | If the film has multiple layers (e.g., adhesive + film + liner), the primary function (plastic film) usually dictates 3919 or 3921. |
| Small Sample Shipments | β No De Minimis Exemption. Even small shipments are subject to the full 39-40% tariff. Do not use "gift" or "sample" labels to evade. |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Notes |
|---|---|---|---|
| πΊπΈ USA | 3919.90.50.60 / 3921.90.40.90 |
39.2% - 40.8% | Includes 25% Section 301 + 10% 122 Clause. High Cost. |
| π¨π³ China | 3919.90.50.60 / 3921.90.40.90 |
~5-8% | Standard import duties. No Section 301. |
| πͺπΊ EU | 3920.62.00 / 3919.90.00 |
~6.5% | VAT varies by country. No similar US-style surcharges. |
| π¦πΊ Australia | 3920.62.00 |
~5% | GSP or FTA benefits may apply depending on origin. |
π Conclusion:
- USA is the most expensive market for these goods due to the 35%+ additional tariffs.
- EU and Asia offer significantly lower duty burdens.
- For US-bound shipments, cost optimization is critical. Consider supply chain adjustments or duty drawback programs if eligible.
π VI. Common Mistakes & Pitfall Guide (Lessons Learned)
β Mistake 1: Declaring Self-Adhesive Film as Non-Adhesive (3921)
π Consequence: Misclassification penalty + Potential evasion suspicion.
β
Fix: Clearly state "Self-Adhesive" in the description.
β Mistake 2: Ignoring the "122 Clause" Surcharge
π Consequence: Underestimating landed cost by 10%.
β
Fix: Always calculate Base + 25% + 10%.
β Mistake 3: Using "Textile" or "Paper" for Plastic Film
π Consequence: If material is actually plastic (PET/PVC), customs will reclassify and assess higher duties.
β
Fix: Confirm material is Plastic and use Chapter 39.
π― VII. Conclusion: Precision in Classification, Savings in Cost!
π― Remember the Mantra:
πΉ "Adhesive = 3919, No Adhesive = 3921"
πΉ "Base Rate + 25% + 10% = Total Cost"
πΉ "Color and UV Resistance are Attributes, Not Classification Keys"
π Pro Tip:
Given the ~40% total tax rate, it is highly recommended to:
1. Apply for an Advance Ruling from US Customs if importing large volumes.
2. Verify the 122 Clause applicability with a licensed customs broker.
3. Consider alternative origins (e.g., Vietnam, Thailand) if possible, to avoid US-specific surcharges.
π£ Immediate Action:
π Contact a Certified Customs Broker
π Provide Material Safety Data Sheet (MSDS) & Product Specs
π‘ Calculate Landed Cost Including All Surcharges
π Ensure Smooth Clearance and Maximize Profit Margins!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every Percentage Point 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.