Film Roll X ray Film
CN β USAI Analysis
ποΈ Film Roll & X-Ray Film (Industrial/Medical)
π HS Code Reference & Customs Clearance Guide | 2026 Updated Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: What is "X-Ray Film"?
X-Ray film refers to photographic film specifically designed for capturing images using X-ray radiation. In international trade, it is primarily categorized based on its support base material and intended use (Medical vs. Industrial). The critical distinction lies in whether the film is mounted on a rigid support (like a cassette) or supplied as a flexible roll/leaf.
Core Categories: 1. Medical X-Ray Film: Used for diagnosing human/animal conditions. Often requires specific certifications (FDA, CE). 2. Industrial X-Ray Film (Non-Destructive Testing - NDT): Used for inspecting welds, castings, and structural integrity in pipelines, aircraft, and construction.
β οΈ Key Distinction Point:
- If the film is mounted on a rigid cardboard or plastic frame (single sheets in cassettes), it may be classified under Chapter 37 or treated as a "prepared film" depending on packaging.
- If the film is supplied as rolls, sheets, or unmounted leaves, it is typically classified under 3702.
- Do NOT confuse with digital X-ray sensors (which are electronic devices, usually HS 9022.29 or 8543.70).
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority)
| HS Code | Product Description | Application Scenario | Support Base |
|---|---|---|---|
3702.54.00 |
X-ray film, in rolls, strips, or cut shapes, unperforated, coloured (e.g., blue-tinted medical film) | Medical diagnostic films, standard industrial NDT film | Flexible (Rolls/Sheets) |
3702.55.00 |
X-ray film, in rolls, strips, or cut shapes, unperforated, not coloured (Black/White) | High-contrast industrial NDT, specialized medical | Flexible (Rolls/Sheets) |
3702.56.00 |
X-ray film, perforated | Rare, specific archival or high-speed scanning applications | Flexible (Perforated) |
3702.57.00 |
X-ray film, on a support other than plastic (e.g., paper/cardboard mount) | Single-sheet medical films in cassettes | Rigid/semi-rigid |
3702.58.00 |
Other X-ray film | Miscellaneous formats | Various |
π Key Reminder:
- Most bulk X-ray film imported for industrial or medical labs comes in rolls or cut sheets β Classify under 3702.54 or 3702.55.
- If the film is mounted on a rigid frame for immediate use in a cassette, it may fall under 3702.57.
- Digital sensors are NOT film. Do not misdeclare digital detectors as "X-ray film."
π° III. 2026 Latest Tariff Rate Details (Including Surtaxes)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: November 10, 2025 (including subsequent imports)
π― 1. 3702.54.00 / 3702.55.00 ββ X-Ray Film (Rolls/Sheets)
| Item | Content |
|---|---|
| Base Rate | 5.6% (General MFN Rate) |
| USITC Surtax (Section 301) | +7.5% (Footnote 9903.88.01 applies to many photographic products, but check specific footnote for film) |
| IEEPA Surtax | +10% (Targeting Chinese/HK products, effective Nov 10, 2025) |
| Total Tariff Rate | ~23.1% (5.6% + 7.5% + 10%) |
| Tax Calculation | CIF Value Γ 23.1% |
| De Minimis Eligibility | β No (Photographic materials are generally excluded from de minimis exemption for Chinese goods) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3702.54.00/55.00 β FOOTNOTE:9903.88.01 (Verify specific footnote) |
π Explanation:
- "Base Rate 5.6%" is the standard MFN rate for Chapter 37 photographic films.
- "Section 301 Surtax 7.5%" applies to many industrial and consumer goods from China; verify if photographic film is explicitly listed in the exclusion list (unlikely for standard NDT film).
- "IEEPA 10%" is the new blanket surcharge on Chinese-origin goods.
- Total ~23.1% is a significant cost increase. Must be factored into pricing.
π― 2. 3702.57.00 ββ X-Ray Film on Rigid Support
| Item | Content |
|---|---|
| Base Rate | 5.6% |
| USITC Surtax | +7.5% (Subject to same Section 301 rules) |
| IEEPA Surtax | +10% |
| Total Tariff Rate | ~23.1% |
| Tax Calculation | CIF Value Γ 23.1% |
| De Minimis Eligibility | β No |
π Note:
- Whether rolled or mounted, if it is Chinese-origin, the surtaxes apply.
- If the film is originating from Vietnam, India, or Mexico, you may qualify for IEEPA exemption or lower Section 301 rates.
π οΈ IV. Customs Clearance Practical Advice (Pitfall Avoidance Guide)
β 1. Required Documentation Checklist (Non-Negotiable)
| Document | Mandatory? | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must specify: Film type (Color/Black-White), Base (Plastic/Paper), Size, Sensitivity, Manufacturer. |
| β Composition Analysis | βοΈ | If asked by CBP: "Emulsion on flexible plastic support." Helps confirm Chapter 37. |
| β Commercial Invoice | βοΈ | Clearly state "X-Ray Film for Industrial/Medical Use," NOT "Digital Sensor" or "Camera Film." |
| β Certificate of Origin (CO) | βοΈ | CRITICAL: If non-China origin, use CO to claim IEEPA exemption or lower Section 301 rates. |
| β FDA Registration (Medical Only) | βοΈ | If medical, ensure the manufacturer is FDA-registered and the product is 510(k) cleared if required. |
| β Safety Data Sheet (SDS) | βοΈ | Some X-ray films contain silver nitrate or other chemicals; SDS may be required for hazardous goods classification. |
β 2. Declaration Tips (Key Mnemonic)
π₯ "Roll/Sheet = 3702, Mounted = 3702.57, Digital β Film, Origin = Key to Tax!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Bulk X-Ray Film Rolls | 3702.54.00 / 3702.55.00 |
Misdeclare as "Camera Film" (3702.31) β Wrong rate/usage |
| Single Sheets in Cassette | 3702.57.00 |
Declaring as "Roll" β Potential misclassification |
| Digital X-Ray Sensor | 9022.29 or 8543.70 |
Declaring as "X-Ray Film" β Fraud/Seizure Risk |
| Film for Industrial NDT | 3702.54 + "Industrial Use" |
"Medical Use" β Triggers FDA scrutiny if not intended |
β 3. Special Case Handling
| Situation | Handling Advice |
|---|---|
| OEM/White Label Film | Provide client agreement. Ensure HS Code matches the actual product, not the brand. |
| Mixed Container (Film + Sensors) | Separate Line Items! Film under 3702, Sensors under 9022/8543. Do not lump together. |
| Non-China Origin (e.g., China-owned plant in Vietnam) | Ensure Substantial Transformation occurs. Provide full supply chain documentation to claim VN origin. |
| Medical vs. Industrial | Label clearly. Medical films may face FDA delays. Industrial films are faster. |
π V. Global Main Market Customs Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3702.54.00 |
~23.1% (5.6% + 7.5% + 10%) | FDA (Medical), ISO (Industrial) | High surtax. Check for exclusions. |
| π¨π³ China | 3702.54.00 |
5.6% | CCC (Some medical devices) | No IEEPA surtax. |
| πͺπΊ EU | 3702.54.00 |
4.3% (Standard) | CE (Medical), EN Standards | No additional surtaxes like US. |
| π¦πΊ Australia | 3702.54.00 |
5.0% | TGA (Medical), SAA (Industrial) | Moderate tariffs. |
| π―π΅ Japan | 3702.54.00 |
3.2% | PMDA (Medical) | Low tariff. |
π Conclusion:
- USA is the most expensive market due to stacked surtaxes (Section 301 + IEEPA).
- EU/Asia/Japan are more cost-effective for exporting Chinese X-ray film.
- Consider third-country manufacturing (e.g., Vietnam, India) to mitigate US tariffs.
π VI. Common Errors & Pitfall Guide (Lessons Learned)
β Error 1: Declaring Digital X-Ray Detectors as "X-Ray Film"
π Consequence: Seizure, fraud investigation, heavy penalties. Digital sensors are electronic, not chemical film.
β Error 2: Ignoring FDA Registration for Medical Film Imports
π Consequence: Detention by CBP, refusal of entry, destruction of goods.
β Error 3: Using "Camera Film" HS Code (3702.31) for X-Ray Film
π Consequence: Misclassification, potential back taxes + penalties. X-ray film has different technical specs and uses.
β Error 4: Failing to Declare Origin Correctly for Non-China Goods
π Consequence: Paying 10% IEEPA surtax unnecessarily if goods are from Vietnam/India/Mexico.
β Correct Practice:
"X-Ray Film, Plastic Base, Rolls, 12x16 inch, Black and White, Non-Destructive Testing Use, Manufacturer: [Name], Origin: [Country]"
π― VII. Conclusion: Professional Declaration Saves Money!
π― Remember the Mnemonic:
πΉ "Roll/Sheet = 3702, Mounted = 3702.57, Digital β Film, Origin = Key to Tax!"
πΉ "USA Tariff = Base + 301 + IEEPA, Total ~23%+ Declare Accurately to Avoid Fines!"
π Pro Tip:
If your X-ray film is originating from Vietnam, India, or Mexico, you can avoid the 10% IEEPA surtax. Ensure your supplier provides a valid Certificate of Origin and proof of substantial transformation.
Consider applying for an Advance Ruling from CBP if your product format is unusual (e.g., perforated film).
π£ Immediate Action:
π Contact a licensed customs broker + Provide Product Specs + Verify Origin Document
π Ensure your X-Ray Film clears customs smoothly, efficiently, and cost-effectively!
β¨ Professional clearance starts with accurate classification!
πΌ Your every dollar of cost is worth precise calculation!
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.