Film Roll (Low Contrast Color)
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3702390100 | 38.7% | CN | US | Official Doc |
| 3702980000 | 38.7% | CN | US | Official Doc |
| 3919102055 | 40.8% | CN | US | Official Doc |
| 3920100000 | 39.2% | CN | US | Official Doc |
| 3920200055 | 39.2% | CN | US | Official Doc |
| 3919905060 | 40.8% | CN | US | Official Doc |
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AI Analysis
ποΈ Film Roll (Low Contrast Color)
π HS Code Reference & Customs Clearance Guide | 2026 Taxation Full Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Really Know "Film Roll"?
The term "Film Roll (Low Contrast Color)" refers to photographic film characterized by a specific optical property: low contrast. This suggests a specialized product for artistic photography, scientific imaging, or medical/diagnostic applications where subtle tonal gradations are required.
In international trade, the classification hinges on two critical factors: 1. Form: Unexposed, roll-shaped (θΆε·). 2. Function: Light-sensitive (photographic) material. 3. Material: Inferred as non-paper, non-textile, likely plastic-based or chemically treated gelatin emulsion on a plastic/acetate base.
β οΈ Key Distinction:
- If the product is light-sensitive photographic film (regardless of contrast) β Chapter 37 (Chemical Products). - If the product is merely a transparent plastic film (with no light-sensitive chemicals) β Chapter 39 (Plastics). - Crucial Logic: "Low Contrast Color" implies it is a functional photographic product, not a raw plastic sheet. Therefore, HS Codes 3702.39.01.00 and 3702.98.00.00 are the primary candidates.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority)
Based on the input data, here is the precise breakdown of potential classifications for Film Roll (Low Contrast Color):
| HS Code | Product Description | Logic & Application | Total Tax Rate |
|---|---|---|---|
| 3702.39.01.00 | Roll Film (Non-Silver Halide) Matching form (Roll) & use (Photo/Photo-sensitive). Material inferred as non-paper/non-textile. |
Best fit for color roll film that is not "silver halide" specific or falls under sub-category "other". Fits "Low Contrast Color" as a specialized photographic roll. | 38.7% |
| 3702.98.00.00 | Other Sensitized Film Matching form (Roll) & use (Photo/Photo-sensitive). Material inferred as non-paper, non-textile, other photographic material. |
The "ε εΊ" (catch-all) for specialized photographic films not covered by specific sub-headers. Ideal for unique low-contrast formulas. | 38.7% |
| 3919.10.20.55 | Self-Adhesive Plastic Films Matching form (Film) & material (Plastic). Sub-category for "Others". |
Risk: Only if the product is a plastic film without light-sensitive chemicals. If it is truly "photo film," this is an error. | 40.8% |
| 3920.10.00.00 | Sheets/ Rolls of Polyethylene Matching form (Roll) & material (Polymer). No material conflict. |
Risk: Only if the product is a pure plastic liner or protective film. Not suitable for light-sensitive "Color Film". | 39.2% |
| 3920.20.00.55 | Plastic Films (Polypropylene) Matching form (Film) & material (Plastic). Consistent with Polypropylene catch-all logic. |
Risk: Similar to above. Applies if the product is a plastic substrate rather than the functional photographic medium. | 39.2% |
π Critical Analysis:
- Primary Choice: 3702.39.01.00 or 3702.98.00.00.
Why? The description "Film Roll" with a quality attribute "Low Contrast Color" strongly indicates a photographic product (Chapter 37). Classifying it as plastic (Chapter 39) is incorrect unless the light-sensitive layer is absent. - Tax Impact: Both correct photographic codes carry a 38.7% total tax rate. - Warning: Do not use 3919 or 3920 unless the product is explicitly a clear plastic film used for packaging or display, NOT for photography.
π° III. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
β Target Market: United States (US)
β Origin: China (CN)
β Effective Date: From Nov 10, 2025 (including subsequent imports)
π― 1. Primary Classification: 3702.39.01.00 & 3702.98.00.00 (Photographic Film)
| Item | Detail |
|---|---|
| Base Tariff | 3.7% (ad valorem) |
| Section 301 Surcharge (Add-on) | +25.0% (USITC 301 List) |
| "122 Clause" Surcharge | +10.0% (Specific China-related add-on) |
| Total Effective Tax | 38.7% |
| Tax Calculation | CIF Value Γ 38.7% |
| De Minimis Exemption | β NOT Applicable (Deny De Minimis for Section 301 items) |
| Legal Path | Section 301:3702 β Add-on: 25% β 122 Clause: 10% |
π Detailed Explanation:
- Base Tariff (3.7%): Standard MFN rate for photographic rolls. - Add-on 25%: Applied under Section 301 of the Trade Act of 1974. This is the standard penalty for Chinese-origin goods in this category. - "122 Clause" (10%): This refers to a specific administrative or tariff list add-on (often linked to List 4A or similar specific enforcement measures targeting China). It is applied on top of the 301 rate. - Result: A 38.7% total cost significantly impacts the competitiveness of low-margin photographic products.
π― 2. Incorrect Classification Risk: 3919.10.20.55 / 3920.10.00.00 (Plastic Films)
| Item | Detail |
|---|---|
| Base Tariff | 4.2% - 5.8% |
| Section 301 Surcharge | +25.0% |
| "122 Clause" | +10.0% |
| Total Effective Tax | 39.2% - 40.8% |
| Risk Warning | β οΈ Severe Penalty Risk: If a Customs Officer determines the item is photographic film but declared as plastic film, you face: |
| > - Re-classification to Chapter 37 (Tax difference is minor here, but...) | |
| > - Underpayment Penalties (if the base rate was lower). | |
| > - Seizure for misdeclaration of a chemical product (Chapter 37 is chemically regulated). |
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Documentation Checklist (Non-negotiable)
| Document | Required? | Purpose |
|---|---|---|
| β Technical Data Sheet | Yes | Must explicitly state: "Light-sensitive emulsion," "Low contrast color," "Photographic use." |
| β Composition Analysis | Yes | Prove the presence of silver halides or color couplers (Chapter 37 material). |
| β Product Photos | Yes | Show packaging with "Photographic Film" or "Exposure Sensitive" warnings. |
| β Safety Data Sheet (SDS) | Yes | Required for chemical products (photographic film is often classified as chemical). |
| β Commercial Invoice | Yes | Must use term "Photographic Film Roll" or "Color Film", NOT "Plastic Film". |
| β HS Code Pre-Ruling | Highly Recommended | Apply for a Binding Ruling from US CBP to confirm the 3702 classification. |
β 2. Declaration Strategy (The Golden Rule)
π₯ Mantra: "Chemical Base, Light Sensitive, Declare as Photo, Not Plastic!"
| Scenario | Correct Declaration | Incorrect (High Risk) |
|---|---|---|
| Low Contrast Color Film | 3702.39.01.00 (Photographic) |
3919.10.20.55 (Plastic) |
| Unexposed Film Roll | 3702.98.00.00 (Other Photo) |
3920.10.00.00 (Polymer) |
| Packaging Label | "Photographic Film", "Keep in Dark" | "Plastic Film", "Protective Cover" |
β 3. Special Handling Cases
| Situation | Advice |
|---|---|
| "Low Contrast" Ambiguity | If the "low contrast" is due to toning (chemical) vs base density (physical), emphasize the chemical nature in the description to justify Chapter 37. |
| Medical/Diagnostic Use | If used for X-ray or medical imaging, it is still 3702 (X-ray film), not Chapter 90. Ensure the HS Code reflects "Sensitized" material. |
| Sample Shipments | Even samples of photographic film are subject to the 38.7% tax if the value exceeds $800 (de minimis threshold). Do not claim "no value" if it is a commercial sample. |
π V. Global Market Comparison (2026 Update)
| Market | Recommended HS Code | Tariff (China Origin) | Notes |
|---|---|---|---|
| πΊπΈ USA | 3702.39.01.00 / 3702.98.00.00 |
38.7% | High Section 301 & 122 Clause penalties. |
| πͺπΊ EU | 3702.39 / 3702.98 |
~4-5% | No Section 301. Standard duty only. |
| π¨π³ China | 3702.39 / 3702.98 |
~5-10% | Standard import duty. |
| π―π΅ Japan | 3702.39 / 3702.98 |
~4-6% | Low duty, no major surcharges. |
π Conclusion: The USA is the only major market imposing the ~35% surcharge on this product. If targeting the US, cost must be factored in. For other markets, the tax burden is significantly lower.
π VI. Common Mistakes & How to Avoid Them (Lessons Learned)
β Mistake 1: Calling it "Plastic Film" to avoid chemical regulations.
π Consequence: CBP may seize the shipment for "Misdeclaration of Chemical Goods" + fines. Risk > Tax Savings.
β Mistake 2: Using 3920 (Plastics) because it looks like a roll.
π Consequence: Rejection at customs. You must prove the light-sensitive layer exists to qualify for Chapter 37.
β Mistake 3: Ignoring the "122 Clause" in cost calculation.
π Consequence: Underestimating landed cost by 10%, leading to price war failures or loss of profit.
β Correct Action:
"Color Photographic Film, Low Contrast, Roll Format, Light Sensitive, Silver Halide/Color Coupler Emulsion."
π― VII. Conclusion: Precision Matters for Photo Film!
π― Key Takeaway:
πΉ "Low Contrast" = Optical Property, NOT Material Type.
πΉ Chapter 37 (Photo) > Chapter 39 (Plastic) for any light-sensitive film.
πΉ Total Tax = 38.7% (USA).
πΉ Never try to classify photo film as plastic to save tax; the risk of penalties is too high.
π Pro Tip:
If you are importing for commercial photography in the US, apply for an Advance Ruling from CBP to lock in the 3702 classification and avoid surprise audits.
π£ Immediate Action:
π Consult a Customs Broker + Provide Composition Analysis + Apply for Pre-Ruling
π Ensure your "Low Contrast Color Film" is declared correctly to avoid 38.7% tax shock!
β¨ Professional Classification, Smoother Customs, Better Margins!
πΌ Don't let a wrong HS Code cost you your profit margin.
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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.