Frosted Film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3919905040 | 40.8% | CN | US | Official Doc |
| 3920991000 | 41.0% | CN | US | Official Doc |
| 3919905060 | 40.8% | CN | US | Official Doc |
| 3920511000 | 41.0% | CN | US | Official Doc |
| 3919102055 | 40.8% | CN | US | Official Doc |
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AI Analysis
π«οΈ Frosted Film (磨η θ)
π HS Code Reference & Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: What Exactly is "Frosted Film"?
"Frosted Film" refers to plastic or polymer sheets/films that have been treated (physically, chemically, or mechanically) to create a translucent, diffuse surface texture. In international trade, it is primarily classified as Plastic Films and Sheets.
Key Distinctions for Classification: * Self-Adhesive Nature: Does the film have an adhesive backing? If yes, it leans towards Heading 3919 (Self-adhesive plates/sheets/film). * Structure: Is it a single layer, or is it laminated/compound? If it is a multi-layer compound not classified elsewhere, it leans towards Heading 3920 (Other plates, sheets, film, foil and strip, of plastics). * Material: Is it PVC or PET? This affects specific sub-codes within 3920.
β οΈ Critical Classification Point:
- If it is Self-Adhesive β Look at 3919.
- If it is Non-Adhesive (Standalone) β Look at 3920.
- "Frosted" is a surface treatment, not a material change. It does not change the chemical nature of the plastic but affects the visual property (translucency vs. transparency).
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Cross-Reference)
Based on the provided data, here are the precise HS Codes and their logical justifications for Frosted Film.
| HS Code | Product Description | Logical Justification & Scenario | Tax Rate |
|---|---|---|---|
3919.90.50.40 |
Frosted Film, Self-Adhesive, Other | Justification: The summary states "Morphology: Film/Sheet, Material: Plastic/Polymer." It falls under "Other self-adhesive plastic plates, sheets, film, tape." It is a generic self-adhesive frosted film. | 40.8% |
3920.99.10.00 |
Frosted Film, Non-Adhesive, Composite/Laminated | Justification: Material is plastic; morphology is film/sheet. It is classified as a non-cellular, unreinforced composite/laminated product. This is for standalone films that are not self-adhesive and not single-layer PVC/PET. | 41.0% |
3919.90.50.60 |
Frosted Film, Self-Adhesive, Specific Polymer Type | Justification: Fits the characteristics of plastic self-adhesive films. Like 3919.90.50.40, it is self-adhesive, but this specific code may target a slightly different polymer composition or manufacturing standard under the "Other" category. | 40.8% |
3920.51.10.00 |
Frosted Film, PET/PVC Based, Non-Adhesive | Justification: Material is polymer (specifically implied PET or PVC). Morphology is film. It fits the description of non-foamed, non-reinforced plates, sheets, film, foil, and strip. This is likely a high-clarity or specific-grade frosted sheet. | 41.0% |
3919.10.20.55 |
Anti-Wear Sticker (Frosted Variant) | Justification: Specifically described as an Anti-Wear Sticker. Morphology is self-adhesive flat shape. Material is likely plastic/film. Classified under Other plastic self-adhesive tapes. Note: This is specifically for stickers with wear resistance, not just plain film. | 40.8% |
π Key Reminder:
- Self-Adhesive vs. Non-Adhesive is the biggest divider between 3919 and 3920.
- Composite/Laminated status pushes non-adhesive films into 3920.99.
- Specific Materials (PET/PVC) may have dedicated sub-codes under 3920.51.
- "Anti-Wear" implies a functional coating or specific application, which may trigger the 3919.10 (Tapes/Stickers) category.
π° III. 2026 Latest Tariff Rate Breakdown (Including Additional Taxes)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: Post-November 2025 (Includes subsequent imports)
All HS Codes listed above attract the same tax structure due to the China-US trade context.
π― Unified Tariff Structure for All Frosted Film HS Codes
| Tax Component | Rate | Legal Basis / Description |
|---|---|---|
| Base Tariff | 5.8% - 6.0% | Standard Most Favored Nation (MFN) rate for plastic films/stickers. - 3919.90.50.x: 5.8% - 3920.99.10.00 / 3920.51.10.00: 6.0% |
| Section 301 Tariff | +25.0% | USITC Footnote 9903.88.01. This is the "Trade War" tariff on Chinese goods. Applies to almost all plastic films from China. |
| IEEPA Tariff (Section 122 / EO 14070) | +10.0% | International Emergency Economic Powers Act. Additional 10% tariff on Chinese imports, effective from late 2025. |
| Total Effective Rate | 40.8% - 41.0% | Sum of Base + 301 + IEEPA. |
| Calculation Base | CIF Value | (Cost, Insurance, and Freight) |
| De Minimis Exemption | β NO | Not eligible for Section 321 (De Minimis) exemption. High-value industrial materials are excluded. |
| Legal Path | IEEPA:9903.01.25 β USITC:[HS Code] β FOOTNOTE:9903.88.01 |
π Explanation:
- The 25% is the standard Section 301 duty on Chinese plastics.
- The 10% is the additional IEEPA tariff targeting Chinese goods.
- The Base Duty varies slightly (5.8% vs 6.0%) depending on the specific HS sub-code precision.
- Total Tax is extremely high (~41%). This significantly impacts profit margins. Clearance accuracy is vital to avoid over-taxation or audits.
π οΈ IV. Clearance Operational Advice (Practical Pitfall Avoidance)
β 1. Documentation Checklist (Mandatory)
| Document | Required? | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must detail: Material (e.g., PET, PVC, PE), Thickness, Width, Roll Length, Surface Treatment (Frosted/Matte), Adhesive Type (if applicable). |
| β Composition Statement | βοΈ | If laminated, list each layer. "Composite/Laminated" classification requires proof of structure. |
| β Product Photos | βοΈ | Clear images showing the frosted texture, edge cross-section, and any adhesive backing. |
| β Commercial Invoice | βοΈ | Must specify: "Frosted Plastic Film" or "Self-Adhesive Frosted Film", Not just "Film". Include HS Code. |
| β Packing List | βοΈ | Weight, dimensions, number of rolls/boxes. |
| β Certificate of Origin | βοΈ | Required for US Customs to apply the correct Section 301 rate. |
β 2. Declaration Tips (Critical Keywords)
π₯ "Material + Form + Function + Adhesion"
| Scenario | Correct Declaration | Wrong Declaration | Risk |
|---|---|---|---|
| Self-Adhesive Film | "Frosted Self-Adhesive Plastic Film, PET, No Adhesive Backing" (Wait, it IS adhesive) β "Frosted Self-Adhesive Plastic Film, PET, with Pressure-Sensitive Adhesive" | "Plastic Film" | Ambiguity leads to inspection. |
| Non-Adhesive Film | "Frosted Non-Adhesive Plastic Sheet, Laminated, PET/PVC" | "Plastic Film" | Might be misclassified as simpler film (lower tax) or rejected. |
| Anti-Wear Sticker | "Frosted Anti-Wear Plastic Sticker, Self-Adhesive" | "Plastic Sticker" | Needs specific functional description. |
| Generic "Film" | "Frosted Matte Finish Plastic Film" | "Film" | Too vague. Customs will detain. |
β 3. Special Handling
| Situation | Advice |
|---|---|
| Laminated Films | If the film is laminated (e.g., PET + PE), declare as Composite. Use 3920.99.10.00. Do not declare as single-layer PET. |
| OEM/Custom Size | Provide order specs. If cut to specific sizes for a machine, ensure it doesn't look like a "part" of machinery (which might have different duties). |
| High Value | Given the 41% tax, ensure the CIF value is accurate. Undervaluation triggers severe penalties. Overvaluation is also risky. |
| Pre-Ruling | Strongly Recommended: Apply for an Advance Ruling from US CBP to confirm the HS Code (3919 vs 3920) and tax liability before shipment. |
π V. Global Market Comparison (2026)
| Market | Recommended HS Code | Total Tariff (China Origin) | Notes |
|---|---|---|---|
| πΊπΈ USA | 3919.90.50.40 / 3920.99.10.00 |
40.8% - 41.0% | High Tax. Section 301 + IEEPA 10%. No de minimis. |
| π¨π³ China | 3919.90.50 / 3920.99 |
5% - 6% | Import duty only. No additional tariffs. |
| πͺπΊ EU | 3920.62.10 (if PET) / 3919.90 |
~4.5% - 6.5% | Standard MFN. No Section 301 equivalent. |
| π¬π§ UK | 3920.62.10 |
~4.5% - 6.5% | Post-Brexit tariff. No US-style additional tariffs. |
π Conclusion:
- USA is the most expensive market due to political tariffs.
- EU/UK are significantly cheaper (~5-6% vs ~41%).
- If importing into the US, cost optimization is critical. Consider supply chain diversification (e.g., sourcing from Vietnam or Thailand) if volume is high, to avoid Section 301.
π VI. Common Errors & Pitfalls (Lessons Learned)
β Error 1: Declaring "Self-Adhesive" films as "Non-Adhesive" to avoid 3919.
π Consequence: Customs will inspect, find adhesive, and reclassify with penalties + back taxes.
β Error 2: Declaring "Laminated" films as single-layer PET.
π Consequence: Misclassification. Single-layer PET might have a different base rate, but the Section 301 tax remains 25%. However, accuracy is required to avoid fines.
β Error 3: Ignoring the 10% IEEPA Tariff.
π Consequence: Budget miscalculation. Many importers forget the 10% and only plan for 25%+Base. Total is 41%.
β Error 4: Using generic terms like "Decorative Film".
π Consequence: Customs will ask for detailed specs. Delays.
β Correct Approach:
"Frosted Self-Adhesive Plastic Film, 0.1mm thick, PET material, with Pressure-Sensitive Adhesive, Roll Format, HS Code 3919.90.50.40"
π― VII. Conclusion: Professional Declaration, Cost Control
π― Key Takeaway:
πΉ "Frosted" is just a finish. Adhesion and Layering define the Code.
πΉ "Self-Adhesive" = 3919. "Non-Adhesive/Laminated" = 3920.
πΉ "Total Tax ~41%". Budget accordingly. No De Minimis.
π Action Item:
- Verify Adhesion: Does it stick?
- Verify Layers: Is it one material or laminated?
- Apply for Pre-Ruling: Confirm HS Code with US CBP.
- Calculate Landed Cost: Include 41% tax in your pricing model.
β¨ Precise Classification, Smooth Clearance, Protected Margins!
πΌ Every percent of tax saved is pure profit earned!
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.