Film (HD Recording)
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3920992000 | 39.2% | CN | US | Official Doc |
| 3706106090 | 35.0% | CN | US | Official Doc |
| 3706900060 | 35.0% | CN | US | Official Doc |
| 3702390100 | 38.7% | CN | US | Official Doc |
| 3702960000 | 38.7% | CN | US | Official Doc |
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ποΈ Film (HD Recording)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Level Strategy π 1. Product Definition & Classification: Do You Really Understand "HD Recording Film"?
"Film (HD Recording)" typically refers to high-definition photographic or motion picture film used for recording visual information. In international trade, its classification depends heavily on the material basis (plastic vs. light-sensitive emulsion) and the specific use (cinematic vs. general photographic).
Key Distinctions: * Plastic Base / Non-Imaging Film: If the product is a clear or translucent plastic sheet/film without light-sensitive emulsion (e.g., protective packaging, industrial masking, or unexposed support layers), it is classified as a Plastic Product. * Light-Sensitive Emulsion (Cinematic/Photographic): If the product has a photosensitive coating for recording images (HD quality refers to resolution/format, not material), it is classified as Photographic/Chemical Goods.
β οΈ Critical Classification Point: * If it is unexposed plastic film (no silver halide/chemical emulsion) βε½η±» to Chapter 39 (Plastics). * If it is exposed/unexposed imaging film (with emulsion) βε½η±» to Chapter 37 (Photographic Goods). * Note: "HD" does not change the HS Code; it is a performance characteristic. The material determines the chapter.
π¦ 2. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data context, here are the potential HS Codes and their specific rationales:
| HS Code | Product Description | Application Scenario | Key Identification Feature |
|---|---|---|---|
3920.99.20.00 |
Other plates, sheets, film, foil and strip, of plastics | Non-imaging Plastic Film | Used as protective wrap, industrial film, or plastic substrate. No photosensitive emulsion. |
3706.10.60.90 |
Cinematic motion picture film, unexposed | Cinematic/Professional Film | "Film" shape + "HD" implies high-resolution cinematic use. Includes emulsion. |
3706.90.00.60 |
Other photographic film in any form | General Imaging Film | Other photographic film not specified elsewhere. "HD" is a quality descriptor. |
3702.39.01.00 |
Other photographic film, sensitized, but not exposed | General Photographic Film | Sensitized film for still photography or other recording. |
3702.96.00.00 |
Other photographic film, sensitized, but not exposed | Non-paper/Textile Base Film | Flexible film base (not paper or textile). Common for professional rolls. |
π Key Reminder: * Misclassification Risk: If you declare high-end imaging film (Chapter 37) as plastic film (Chapter 39), customs may reject it for lacking chemical composition declarations. * Material Check: Check the MSDS or Technical Data Sheet. If it contains Silver Halide or Photosensitive Dyes, it must be Chapter 37. If it is pure Polyester/PVC/PE, it is Chapter 39.
π° 3. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
β Applicable Country: USA (US) β Origin: China (CN) β Effective Date: 2025/2026 (Current Status)
π― 1. 3920.99.20.00 ββ Plastic Film (Non-Imaging)
| Item | Content |
|---|---|
| Base Tariff | 4.2% (Ad Valorem) |
| Section 301 Surcharge (USITC) | +25.0% (Section 301, List 4B/Specific Items) |
| Section 122/IEEPA Surcharge | +10.0% (Targeting China-specific imports) |
| Total Tax Rate | 39.2% |
| Tax Calculation | CIF Value Γ 39.2% |
| De Minimis Eligibility | β No (Strict scrutiny on Chinese plastic goods) |
| Legal Basis Path | USITC:3920.99.20.00 β FOOTNOTE:Section301 β IEEPA:Section122 |
π Explanation: * The 25% is the standard Section 301 tariff on many plastic goods. * The 10% is an additional political/trade barrier tariff often applied to Chinese exports under specific executive orders. * Total 39.2% is a high barrier for plastic films.
π― 2. 3706.10.60.90 & 3706.90.00.60 ββ Cinematic/Imaging Film
| Item | Content |
|---|---|
| Base Tariff | 0.0% (Free for many photographic films under HTSUS) |
| Section 301 Surcharge (USITC) | +25.0% (Note: Some photographic goods are exempt, but check List 4B carefully. Data indicates 25% applied here) |
| Section 122/IEEPA Surcharge | +10.0% |
| Total Tax Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35.0% |
| De Minimis Eligibility | β No |
| Legal Basis Path | USITC:3706.xx.xx.xx β FOOTNOTE:Section301 β IEEPA:Section122 |
π Explanation: * Although the base tariff is 0%, the surcharges bring the total to 35.0%. * Comparison: This is slightly cheaper than the plastic film option (35.0% vs 39.2%). * Justification: "HD" and "Film" strongly suggest imaging media, making Chapter 37 the more technically accurate classification if emulsion is present.
π― 3. 3702.39.01.00 & 3702.96.00.00 ββ Other Photographic Film
| Item | Content |
|---|---|
| Base Tariff | 3.7% |
| Section 301 Surcharge (USITC) | +25.0% |
| Section 122/IEEPA Surcharge | +10.0% |
| Total Tax Rate | 38.7% |
| Tax Calculation | CIF Value Γ 38.7% |
| De Minimis Eligibility | β No |
| Legal Basis Path | USITC:3702.xx.xx.xx β FOOTNOTE:Section301 β IEEPA:Section122 |
π Explanation: * This category applies if the film is not for cinema (
3706) but for other photographic uses. * Total 38.7% is higher than cinematic film due to the 3.7% base rate.
π οΈ 4. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Preparation Checklist (No Exceptions)
| Document | Required? | Description |
|---|---|---|
| β Technical Data Sheet | βοΈ | Must state: Substrate Material (Plastic/Cellulose Acetate/Polyester) and Emulsion Type (Silver Halide/Chromogenic). |
| β Product Photos | βοΈ | Show packaging labels, roll ends, and any "HD" branding. |
| β MSDS (Material Safety Data Sheet) | βοΈ | Critical for Chapter 37 to prove chemical composition. |
| β Commercial Invoice | βοΈ | Description: "HD Photographic Film, Unexposed, for Video/Photo Recording." |
| β Bill of Lading | βοΈ | Ensure weight and dimensions match invoice. |
| β Origin Certificate | βοΈ | To verify Chinese origin for surcharge calculation. |
β 2. Declaration Strategy (Key Mnemonic)
π₯ "Material First, Emulsion Check, HD is Just a Label!"
| Scenario | Correct HS Code | Wrong Approach | Consequence |
|---|---|---|---|
| Clear Plastic Roll (No Image) | 3920.99.20.00 |
Declare as 3706 (Film) |
Penalty for false declaration; potential fraud charges. |
| Imaging Roll (Has Emulsion) | 3706.10.60.90 |
Declare as 3920 (Plastic) |
Rejection by CBP; goods held for chemical testing. |
| HD Video Tape (Digital) | Not Film | Declare as 3706 |
Wrong Category. Digital media is Chapter 85/89. |
| Paper-Based Photo Paper | 3703/3705 |
Declare as 3706 |
Wrong Base. Paper base changes HS code. |
β 3. Special Handling
| Situation | Advice |
|---|---|
| OEM Custom Labeling | Ensure the label says "For Photographic Use" if it is Chapter 37. Avoid "Industrial Protective Film" if itβs actually imaging film. |
| Mixed Container | If packing plastic film (3920) and imaging film (3706) together, declare separately. Do not lump sum. |
| "HD" Clarification | If asked by customs, clarify: "HD refers to Resolution/Format, not Material." Provide sample if needed. |
| High Value Goods | For expensive cinematic film (e.g., Kodak/Anamorphic), consider Advance Ruling to lock in the 35.0% rate vs 39.2%. |
π 5. Global Customs Comparison (2026 Update)
| Country/Region | Recommended HS Code | Tariff Rate (China Origin) | Certification Required | Note |
|---|---|---|---|---|
| πΊπΈ USA | 3706.10.60.90 |
35.0% ( incl. 301+122) | No specific FDA | Section 301 applies. |
| π¨π³ China | 3706.10.60.90 |
0% - 3% | CCC (if applicable) | No surcharges. |
| πͺπΊ EU | 3706.10.60.90 |
0% | REACH / RoHS | Generally duty-free for photographic film. |
| π¬π§ UK | 3706.10.60.90 |
0% | UKCA | Post-Brexit rules similar to EU. |
| π―π΅ Japan | 3706.10.60.90 |
0% - 3% | PSE (if electronic) | Low tariffs. |
π Conclusion: * USA is the most expensive market due to Section 301 and IEEPA surcharges. * European and Asian markets generally offer duty-free or low-tariff access for imaging film. * Strategy: If shipping to the US, ensure accurate classification to avoid higher penalties. If possible, source non-chemical plastic films (
3920) only if they are truly non-imaging, but be aware of the 39.2% rate.
π 6. Common Errors & Pitfalls (Blood & Tears Lessons)
β Error 1: Declaring imaging film as "Plastic Film" to avoid Chapter 37 complexity. π Consequence: CBP demands chemical analysis. If emulsion is found, back taxes + 25% penalty + possible seizure.
β Error 2: Ignoring the "122 Clause" (10% Surcharge). π Consequence: Underpayment of duty. CBP audits will catch this, leading to debt collection actions.
β Error 3: Not specifying "Unexposed" on the Invoice. π Consequence: If "Exposed" film is imported, it may be subject to biosecurity or chemical waste regulations, leading to delays.
β Error 4: Using "HD" as the sole product name. π Consequence: Too vague. CBP may classify under worst-case scenario codes with highest duties.
β Correct Practice:
"HD Cinematic Film, Unexposed, Polyester Base, Silver Halide Emulsion, 35mm, For Professional Video Recording, Model XYZ"
π― 7. Conclusion: Professional Declaration, Cost Optimization!
π― Remember the Golden Rule:
πΉ "Material Determines Chapter, Emulsion Determines Chapter 37, No Emulsion is Chapter 39." πΉ "HD is a Marketing Term, Not a Tariff Term." πΉ "In the US, Prepare for 35% - 39%. Elsewhere, Prepare for 0%."
π Pro Tip: If your product is digital (e.g., SD Cards, Hard Drives), it is NOT Film. It falls under Chapter 85. Do not use Chapter 37 codes for digital storage media!
π£ Immediate Action:
π Contact your Customs Broker + Provide MSDS + Product Photos + Request HS Code Pre-Ruling for the US market. π Ensure your Commercial Invoice matches the Technical Description perfectly.
β¨ Professional Customs Clearance Starts with Accurate Classification! πΌ Your Cost Savings are Calculated in Every Decimal Point!
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.