Long Roll Non Standard Film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3920991000 | 41.0% | CN | US | Official Doc |
| 3920992000 | 39.2% | CN | US | Official Doc |
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AI Analysis
π¦ Long Roll Non-Standard Film (Plastics)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition: What is "Long Roll Non-Standard Film"?
"Long Roll Non-Standard Film" refers to plastic films that do not meet specific standard specifications (such as specific thickness bands or width standards defined in other subheadings) and are supplied in long rolls. In international trade, these products fall under the category of flexible plastic plates, sheets, film, foil, and strip.
Key Distinction: The classification depends heavily on the thickness of the film. The provided data splits this category into two distinct HS Codes based on whether the thickness is over 0.152 mm or other (which implies β€ 0.152 mm for this specific comparative context in the dataset).
β οΈ Critical Threshold:
- Thickness > 0.152 mm: Classified under 3920.99.10.00
- Thickness β€ 0.152 mm (or "Other"): Classified under 3920.99.20.00
π II. HS Code Classification Details (2026 Latest Tariff Authority)
Based on the provided <DATA>, here are the exact classifications and tax implications.
| HS Code | Product Description | Thickness Criteria | Tax Rate (Total) |
|---|---|---|---|
| 3920.99.10.00 | Film, strip, and sheets (flexible), Over 0.152 mm in thickness, not in rolls | > 0.152 mm | 0.0% |
| 3920.99.20.00 | Film, strip, and sheets (flexible), Other | β€ 0.152 mm (implied) | 29.2% |
π Key Note on "Not in Rolls" vs. "Long Roll":
The description for3920.99.10.00explicitly states "not in rolls". However, the user input is "Long Roll". This creates a critical compliance risk.
- If the film is truly in rolls, it generally does not fit the "not in rolls" description of3920.99.10.00.
- If the customs authority interprets "Long Roll" as sheets/strip that are not standard rolls, it might force classification into3920.99.20.00or a different general heading for rolls.
- However, strictly following the provided<DATA>, we must analyze the two options given. The distinction hinges on thickness and form. If it is in rolls, it may be misclassified under3920.99.10.00if declared as "not in rolls". Verification of "Roll" vs. "Not in Rolls" is essential.
π° III. 2026 Latest Tariff Rate Detailed Explanation
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: Based on 2026 data provided
π― 1. 3920.99.10.00 β Plastic Film, Over 0.152 mm, Not in Rolls
| Item | Content |
|---|---|
| Base Tariff | 0.0% |
| Additional Tariff (Section 301/IEEPA) | 0.0% |
| Total Tax Rate | 0.0% |
| Tax Calculation | CIF Value Γ 0.0% = $0 |
| De Minimis Exemption | N/A (Since duty is 0%, de minimis is irrelevant for duty savings, but product must still be compliant) |
| Legal Basis | HTSUS 3920.99.10.00 |
π Explanation:
- This is a duty-free classification for thicker plastic films that are not in roll form.
- CRITICAL WARNING: If your product is "Long Roll", declaring it as "Not in Rolls" to access this 0% rate is fraudulent misclassification and poses a severe customs audit risk.
π― 2. 3920.99.20.00 β Plastic Film, Other
| Item | Content |
|---|---|
| Base Tariff | 4.2% |
| Additional Tariff (Section 301/IEEPA) | 25.0% |
| Total Tax Rate | 29.2% |
| Tax Calculation | CIF Value Γ 29.2% |
| De Minimis Exemption | β Not Exempt |
| Legal Basis | HTSUS 3920.99.20.00 + Section 301 Footnotes |
π Explanation:
- This is the "Other" category, typically capturing thinner films or those in roll form if they don't fit the specific "not in rolls" exemption.
- The 29.2% total duty is high and significantly impacts cost margins.
- This rate applies if the film is β€ 0.152 mm OR if the "Long Roll" form prevents it from qualifying as "not in rolls" under the 0% category.
π οΈ IV. Customs Clearance Practical Advice (Avoiding Pitfalls)
β 1. Documentation Checklist (Must-Have)
| Document | Required | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must clearly state Thickness (in mm) and Form (Roll vs. Sheet/Not in Roll). |
| β Commercial Invoice | βοΈ | Accurately describe product as "Plastic Film, Long Roll" or "Plastic Sheet, Non-Roll". Do not contradict "Long Roll" with "Not in Rolls". |
| β Packing List | βοΈ | Specify dimensions, weight, and number of rolls/sheets. |
| β Photos of Product | βοΈ | Show the product in roll form or as sheets. |
| β Material Composition | βοΈ | Confirm it is "Non-cellular, not reinforced, not laminated" plastics. |
β 2. Declaration Strategy (Key Mnemonics)
π₯ "Thickness is King, Form is Queen!"
| Scenario | Correct HS Code | Duty Rate | Risk Level |
|---|---|---|---|
| Film > 0.152 mm AND Not in Rolls | 3920.99.10.00 |
0.0% | β Safe (if truly not in rolls) |
| Film β€ 0.152 mm OR In Rolls | 3920.99.20.00 |
29.2% | β Accurate for Long Rolls |
| Film > 0.152 mm BUT In Rolls | Re-evaluate! | Likely 29.2% or higher | β High Risk if misdeclared as "Not in Rolls" |
π Correction for "Long Roll":
Since the input is "Long Roll", it is highly likely that3920.99.10.00is incorrect because its description explicitly says "not in rolls".
- Recommendation: Classify under3920.99.20.00(or investigate if there is a separate code for "Rolls" in the full HTSUS, as3920.99.10.00may not apply).
- If you force3920.99.10.00for a Long Roll, Customs may assess 29.2% + Penalties.
β 3. Special Handling Tips
| Situation | Advice |
|---|---|
| Thickness Measurement | Provide certified lab reports for thickness. Even a difference of 0.001 mm can change the rate from 0% to 29.2%. |
| Roll Dimensions | If the roll is very long but cut into "sheets" for shipping, clarify this. If it remains a continuous roll, it is not "not in rolls". |
| Material Type | Ensure it is non-cellular (solid plastic, not foam) and non-reinforced. If reinforced, a different HS code applies. |
| Pre-Ruling | Strongly Recommended: Apply for an Advance Ruling (Pre-Ruling) from CBP due to the "Long Roll" vs. "Not in Rolls" ambiguity. |
π V. Global Market Comparison (2026)
| Country/Region | Recommended HS Code | Duty Rate | Notes |
|---|---|---|---|
| πΊπΈ USA | 3920.99.20.00 |
29.2% | High duty for Long Rolls. Avoid 3920.99.10.00 unless truly not in rolls. |
| π¨π³ China (Import) | Check local HTS | Varies | Domestic classification may differ. |
| πͺπΊ EU | 3920 99 | Varies (typically 4-6.5%) | No US-style 301 tariffs. |
| π¬π§ UK | 3920 99 | Varies (typically 4-6.5%) | Post-Brexit tariffs may vary. |
π Conclusion:
- USA is the critical market with 29.2% duty for most plastic films, especially if in rolls or thin.
- 0% duty is only for thicker, non-roll forms.
π VI. Common Errors & Pitfalls (Lessons Learned)
β Error 1: Declaring "Long Roll" as "Not in Rolls" to get 0% duty.
π Consequence: Customs seizure, fines, and retroactive 29.2% duty + interest.
β Error 2: Ignoring Thickness.
π Consequence: Misclassification between 0.152 mm boundary leads to incorrect duty rate.
β Error 3: Assuming all plastic films are the same.
π Consequence: Failing to distinguish between "cellular" (foam) vs. "non-cellular" or "reinforced" vs. "non-reinforced" leads to wrong HS Code.
β Correct Approach:
"Plastic Film, Long Roll, 0.10 mm Thick, Non-Cellular, Non-Reinforced, 1000 Meters per Roll, Model XYZ"
β Likely 3920.99.20.00 (29.2% Duty).
π― VII. Conclusion: Professional Classification Saves Money!
π― Remember:
πΉ "Long Roll = Not 0% Duty" (Usually)
πΉ "Thickness Matters: 0.152 mm is the Line"
πΉ "Always Declare Form Correctly: Roll or Not?"π Pro Tip:
If your film is > 0.152 mm, consider cutting it into sheets for shipment to potentially qualify for 0% duty under3920.99.10.00(if legally permissible and safe for the product). If it must be shipped as Long Rolls, budget for 29.2% duty.
π£ Action Item:
π Contact your customs broker to verify the "Roll" status and request an Advance Ruling.
π Accurate declaration is the only way to ensure smooth customs clearance and cost control.
β¨ Customs Compliance: Start with the Right HS Code!
πΌ Every percentage point counts in international trade!
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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.