Industrial Grade PE Plastic Film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3921190090 | 41.5% | CN | US | Official Doc |
| 3921905050 | 39.8% | CN | US | Official Doc |
| 3919102055 | 40.8% | CN | US | Official Doc |
| 3920991000 | 41.0% | CN | US | Official Doc |
| 3919905060 | 40.8% | CN | US | Official Doc |
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AI Analysis
π¬ Industrial Grade PE Plastic Film (High-Density/Low-Density Polyethylene)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional-Levelιε
³ Strategy
π I. Product Definition & Classification: Do You Really Know βPE Filmβ?
Industrial Grade PE (Polyethylene) Film is a versatile packaging and protective material used in agriculture, construction, logistics, and manufacturing. In international trade, PE films are classified based on their form (rolls, sheets, foil) and specific material properties (density, presence of backing/absorbent layers).
Key Distinction Points:
* Peeling/Backing Layer: Does the film have an absorbent backing (e.g., for medical or specific industrial use)? If yes, it may fall under 3920 or 3919.
* Form Factor: Is it rolled (self-adhesive or non-adhesive) or just loose sheets/folds?
* Rolled + Self-Adhesive/Peeling: Tends toward Chapter 3919 (Self-adhesive plates/sheets/film).
* Rolled/Flat + Non-Adhesive/Standard Industrial: Tends toward Chapter 3920 or 3921.
* Material Specificity: Is it a generic plastic film (3921) or a specific polymer type with defined backing?
β οΈ Critical Note for PE Film:
- Pure PE film without backing/absorbent layer usually falls under 3921 or 3920.
- If it has a "peeling" property or is supplied in rolls ready for immediate application (like masking tape base or protective film with adhesive), customs often scrutinize 3919.
- The 5-digit HS code dictates the base duty rate, which significantly impacts the Total Tax due to the additional 25% + 10% tariffs.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Mapping)
Based on the provided data, here are the 5 possible HS Code entries for Industrial PE Plastic Film, ranked by tax efficiency.
| HS Code | Product Description & Logic | Application Scenario | Why This Code? |
|---|---|---|---|
3921.19.00.90 |
Industrial Film, Form: Film/Sheet/Foil. Material: Other Plastic (PE inferred). No conflict. | Standard industrial wrapping, protective layers, non-adhesive PE sheets. | Generic "Other Plastic Film" under Ch. 3921. Base duty: 6.5%. |
3919.10.20.55 |
Industrial Film, Form: Film. Material: Plastic. No conflict. | Rolled PE films, possibly with slight peeling properties or specific roll forms. | Falls under Self-Adhesive/Peeling subheading logic (even if mild). Base duty: 5.8%. |
3919.90.50.60 |
Industrial Film, Form: Film. Material: Plastic. Catch-all subheading. | Generic rolled PE films that don't fit the specific "adhesive" definition of 3919.10 but are still rolls. | Catch-all for Ch. 3919. Base duty: 5.8%. |
3920.99.10.00 |
Industrial Film, Form: Film/Foil. Material: Plastic. Other category. | Specific PE types not covered by other 3920 subheadings (e.g., laminated or specific thickness). | Other Plates/Sheets/Film of Plastic. Base duty: 6.0%. |
3921.90.50.50 |
Industrial Film, Form: Film. Material: Plastic Class. No obvious conflict. | Broader category of industrial PE films, possibly composite or specialized. | Other Plates/Sheets/Film/foil of Plastic. Base duty: 4.8%. |
π Key Insight:
- Chapter 3921 (3921.xxxx) and Chapter 3920 (3920.xxxx) are for non-self-adhesive plastic films.
- Chapter 3919 (3919.xxxx) is for self-adhesive plates/sheets/film. Even if "PE Film" isn't strictly adhesive, customs may classify "peeling" or "roll-ready" industrial films here if they exhibit adhesive-like behavior or are sold as such.
- Base Duty Range: From 4.8% (3921.90) to 6.5% (3921.19). This difference is crucial when calculating the total landed cost.
π° III. 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: November 10, 2025 onwards
All listed HS Codes are subject to the same surtax structure due to their plastic film origin and Chinese production.
π― 1. Common Surtax Structure (All Codes)
| Component | Rate | Legal Basis |
|---|---|---|
| Basic Tariff | 4.8% β 6.5% | Varies by HS Code (see table above) |
| Section 301 Surtax | +25.0% | USITC Footnote (e.g., 9903.88.01 for plastics) |
| IEEPA Surtax | +10.0% | Section 122 Clause (China-specific, 2025-2026) |
| Total Effective Tax Rate | 39.8% β 41.5% | Sum of all above |
π― Detailed Breakdown by HS Code
1. 3921.90.50.50 β LOWEST TOTAL TAX (39.8%)
| Item | Value |
|---|---|
| Base Duty | 4.8% |
| Section 301 Surtax | 25.0% |
| IEEPA (122 Clause) | 10.0% |
| TOTAL | 39.8% |
| Calculation | CIF Value Γ 39.8% |
| De Minimis Eligibility | β NO (Plastic films from China are excluded from de minimis) |
π Why itβs cheaper: The base duty for this specific "other plastic film" subheading is the lowest (4.8%).
2. 3919.10.20.55 & 3919.90.50.60 β MEDIUM-LOW TAX (40.8%)
| Item | Value |
|---|---|
| Base Duty | 5.8% |
| Section 301 Surtax | 25.0% |
| IEEPA (122 Clause) | 10.0% |
| TOTAL | 40.8% |
| Calculation | CIF Value Γ 40.8% |
| De Minimis Eligibility | β NO |
π Note: These fall under Chapter 3919. The base duty is slightly higher than
3921.90but still competitive. Ensure the product does not truly qualify as "self-adhesive" if using3919.10; otherwise, misclassification risk exists.
3. 3920.99.10.00 β MEDIUM TAX (41.0%)
| Item | Value |
|---|---|
| Base Duty | 6.0% |
| Section 301 Surtax | 25.0% |
| IEEPA (122 Clause) | 10.0% |
| TOTAL | 41.0% |
| Calculation | CIF Value Γ 41.0% |
| De Minimis Eligibility | β NO |
4. 3921.19.00.90 β HIGHEST TOTAL TAX (41.5%)
| Item | Value |
|---|---|
| Base Duty | 6.5% |
| Section 301 Surtax | 25.0% |
| IEEPA (122 Clause) | 10.0% |
| TOTAL | 41.5% |
| Calculation | CIF Value Γ 41.5% |
| De Minimis Eligibility | β NO |
π Why itβs most expensive: The base duty is the highest (6.5%) among the options. Only use this if the physical characteristics (e.g., specific foil/sheet form) strictly match this code.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Avoidance)
β 1. Required Documentation Checklist
| Document | Mandatory? | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must specify: Material (PE), Thickness (mm/mils), Width, Length, Density (HDPE/LDPE/LLDPE). |
| β Commercial Invoice | βοΈ | Must clearly state: "Industrial Grade PE Plastic Film", HS Code, CIF Value. |
| β Packing List | βοΈ | Detail roll dimensions, weight, and number of rolls. |
| β Photo of Product & Label | βοΈ | Show the film roll, label with material composition, and any branding. |
| β Certificate of Origin (CO) | βοΈ | To prove China origin (if claiming any preferential treatment, though unlikely here). |
| β Formal Declaration | βοΈ | Confirm no absorbent backing (unless classifying under 3919/3920 specific subheadings). |
β 2. Declaration Tips (Key Mnemonic)
π₯ βCheck the Backing, Check the Roll, Base Duty Determines the Cost!β
| Scenario | Recommended HS Code | Risk of Misclassification |
|---|---|---|
| Pure PE Roll, No Adhesive | 3921.19.00.90 or 3921.90.50.50 |
Low. Ensure no "sticky" side is present. |
| PE Roll with Peeling Property | 3919.10.20.55 |
Medium. Customs may argue itβs "self-adhesive" even if mild. |
| PE Foil/Layer with Backing | 3920.99.10.00 |
Low. Ensure backing is not absorbent (which would move it to 3921.90 or 3901/3902). |
| Generic Plastic Film (Uncertain) | 3921.90.50.50 |
Best for Cost (39.8%). Use if material is standard PE. |
β 3. Special Cases
| Case | Handling Advice |
|---|---|
| Composite PE Film (e.g., PE + Aluminum) | If PE is the essential character, it may still fall under PE codes. If aluminum is primary, it may fall under 7607 (Aluminum foil). Check essential character! |
| PE Film with Printing | Printing does not change HS Code unless it transforms the product into a different article (e.g., printed bags). |
| Small Sample Shipment | β Do NOT use De Minimis (Section 321). Plastic films from China are explicitly excluded from the $800 de minimis exemption due to Section 301 and IEEPA. Full duty applies. |
π V. Global Market Clearance Comparison (2026)
| Country/Region | Recommended HS Code | Total Tax (Approx.) | Notes |
|---|---|---|---|
| πΊπΈ USA | 3921.90.50.50 |
39.8% | Lowest total tax among options. High scrutiny on material type. |
| π¨π³ China | 3921.90.50.50 |
~4.8% + VAT | Import into China is cheaper, but this guide focuses on Export from China to US. |
| πͺπΊ EU | 3920.50.00 |
~6.5% | No 25%+10% surtax. Much more favorable than US. |
| π¬π§ UK | 3920.50.00 |
~6.5% | Post-Brexit tariffs may vary, but generally lower than US. |
π Conclusion for US Exporters:
- The 25% Section 301 + 10% IEEPA surcharge makes US clearance for Chinese PE Film extremely expensive.
- Choose3921.90.50.50(39.8% total) over3921.19.00.90(41.5%) to save 1.7% on CIF value.
- Ensure accurate material declaration to avoid audits that could lead to higher penalties or reclassification.
π VI. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Using De Minimis (Section 321) for PE Film shipments.
π Consequence: Shipment detained, full duties + penalties applied. Plastic films from China are excluded from de minimis.
β Mistake 2: Misclassifying PE Film as 3920 when it has a mild adhesive backing.
π Consequence: Customs may reclassify to 3919 or penalize for misdeclaration. Ensure your product matches the description.
β Mistake 3: Ignoring the "122 Clause" (IEEPA 10%).
π Consequence: Underestimating landed cost. The 10% is significant on high-volume shipments.
β Mistake 4: Declaring "Plastic Film" generically without specifying "PE".
π Consequence: Customs may request additional documentation, causing delays. Be specific: "Polyethylene (PE) Industrial Film".
β Correct Practice:
"Industrial Grade PE Plastic Film, Roll Form, Non-Adhesive, 50 Microns Thickness, Made of Polyethylene. HS Code: 3921.90.50.50. CIF Value: $10,000."
π― VII. Conclusion: Professional Declaration, Cost Optimization!
π― Remember Mnemonic:
πΉ βCheck Base Duty: 4.8% wins, 6.5% loses. Add 35% surtax, total 39.8-41.5%. No de minimis, plan accordingly!β
πΉ βPE Film from China to US? Expect 40%+ tax. Choose 3921.90.50.50 for best rate!β
π Pro Tip:
If your PE Film is exported to Vietnam, Mexico, or Malaysia, you may benefit from FTAs (Free Trade Agreements) to reduce or eliminate duties. Consider supply chain diversification if US tariffs are too high.
π£ Immediate Action:
π Contact your freight forwarder + Provide Product Specs + Apply for Advance Ruling if shipment volume is high.
π Let your PE Film clear customs smoothly, control costs, and maximize profit!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every percentage point of tax matters. Calculate precisely!
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.