Other plastic film Bubble film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3920992000 | 39.2% | CN | US | Official Doc |
| 3921190010 | 41.5% | CN | US | Official Doc |
| 3926904800 | 13.4% | CN | US | Official Doc |
| 3926909989 | 22.8% | CN | US | Official Doc |
| 3921110000 | 40.3% | CN | US | Official Doc |
| 3920100000 | 39.2% | CN | US | Official Doc |
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AI Analysis
π¦ Bubble Film (Other Plastic Film)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional-Level Clearance Strategy
π Part 1: Product Definition & Classification: Do You Really Understand βBubble Filmβ?
Bubble film, commonly known as air pillows or bubble wrap, is a versatile packaging material made primarily from Polyethylene (PE). In international trade, its classification depends heavily on its physical structure (film vs. other article) and intended use (packaging vs. general plastic goods).
The data provided highlights five distinct HS Codes, ranging from 13.4% to 41.5% in total taxation. This significant variance is driven by:
1. Material Form: Is it strictly a "film" (flexible, thin) or an "other article" (finished good)?
2. Specific Subheading: Does it fall under general films (3920) or specific plastic articles (3926)?
3. Trade Policies: Impact of Section 301 tariffs (25%) and Section 122 tariffs (10%) depending on the specific code.
β οΈ Key Distinction Point:
- If classified as "Other Plastic Films" (3920or3921), it is subject to higher additional tariffs (25% Section 301 + 10% Section 122 in most cases).
- If classified as "Other Plastic Articles" (3926), it may benefit from exemptions from Section 301 tariffs, resulting in significantly lower overall tax (e.g., 13.4% vs. 41.5%).
π Part 2: HS Code Classification Details (2026 Latest Tariff Authoritative Comparison)
| HS Code | Product Description | Classification Logic | Total Tax Rate |
|---|---|---|---|
3920.99.20.00 |
Other plastics, other forms, other plates, sheets, film, foil and strip (PE Bubble Film) | Flexible film made of PE; classified as "other plastic film." | 39.2% |
3921.19.00.10 |
Other plates, sheets, film, foil and strip, of plastics (PE Bubble Film) | PE material + Plastic film structure. | 41.5% |
3926.90.48.00 |
Other plastic articles (Bubble Film) | Plastic made article; classified under "other articles" in Chapter 39. | 13.4% |
3926.90.99.89 |
Other plastic articles (Bubble Film) | Plastic (PE) article; no material conflict; general other plastic goods. | 22.8% |
3921.11.00.00 |
Other plates, sheets, film, foil and strip of polymers of ethylene (Bubble Film) | Film form + Ethylene polymer (PE) base. | 40.3% |
3920.10.00.00 |
Other plates, sheets, film, foil and strip, of polymers of ethylene (Bubble Film) | Film/strip form + Ethylene polymer (PE). | 39.2% |
π Key Observation:
- Codes3920and3921generally trigger Section 301 Tariffs (25%), leading to total rates of 39%-41.5%.
- Code3926.90.48.00is unique because it carries 0% Section 301 tariff, resulting in a much lower total rate of 13.4%.
- Code3926.90.99.89carries a reduced Section 301 rate (7.5%), resulting in 22.8% total tax.
π° Part 3: 2026 Latest Tariff Rate Breakdown (Including Additional Taxes & Policy Surcharges)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: Based on current trade policy frameworks (Section 301 & 122)
π― 1. 3920.99.20.00 & 3921.11.00.00 & 3920.10.00.00 ββ Polyethylene Films (High Tariff)
| Item | Content |
|---|---|
| Base Rate | 4.2% β 5.3% (Ad Valorem) |
| Section 301 Surcharge | +25.0% (USITC Footnote) |
| Section 122 Surcharge | +10.0% (Trade Act of 1962) |
| Total Tax Rate | 39.2% β 40.3% |
| Tax Calculation | CIF Value Γ (Base + 25% + 10%) |
| De Minimis Exemption | β Not Applicable (High value threshold, typically >$800, but subject to strict scrutiny) |
| Legal Basis Path | USITC:3920/3921 β Section301:Footnote β Section122 |
π Explanation:
- These codes classify bubble film as "Plastic Films."
- Section 301 (25%) is aggressively applied to Chinese-origin plastic films.
- Section 122 (10%) is an additional surcharge for certain goods.
- Total Cost Impact: High. For a $10,000 shipment, you pay $3,920β$4,030 in duties alone.
π― 2. 3921.19.00.10 ββ Other Plastic Films (Highest Tariff)
| Item | Content |
|---|---|
| Base Rate | 6.5% |
| Section 301 Surcharge | +25.0% |
| Section 122 Surcharge | +10.0% |
| Total Tax Rate | 41.5% |
| Tax Calculation | CIF Value Γ 41.5% |
| De Minimis Exemption | β Not Applicable |
π Note:
- This is the highest tax bracket in the provided data.
- Avoid this code if possible, as it offers no relief from Section 301 or 122 surcharges.
π― 3. 3926.90.99.89 ββ Other Plastic Articles (Medium Tariff)
| Item | Content |
|---|---|
| Base Rate | 5.3% |
| Section 301 Surcharge | +7.5% (Reduced Rate) |
| Section 122 Surcharge | +10.0% |
| Total Tax Rate | 22.8% |
| Tax Calculation | CIF Value Γ 22.8% |
| De Minimis Exemption | β Not Applicable |
π Note:
- Classified as "Other Articles," so Section 301 is reduced to 7.5% (not 25%).
- Still subject to Section 122 (10%).
π― 4. 3926.90.48.00 ββ Other Plastic Articles (Lowest Tariff - OPTIMAL)
| Item | Content |
|---|---|
| Base Rate | 3.4% |
| Section 301 Surcharge | 0.0% (Exempt) |
| Section 122 Surcharge | +10.0% |
| Total Tax Rate | 13.4% |
| Tax Calculation | CIF Value Γ 13.4% |
| De Minimis Exemption | β Not Applicable |
π Explanation:
- This code classifies bubble film as an "Other Plastic Article" rather than a film.
- Section 301 Tariff is 0% (Exempt).
- Only Section 122 (10%) applies.
- Savings: Compared to3921.19.00.10(41.5%), this saves 28.1% in taxes. For a $10,000 shipment, savings = $2,810.
π οΈ Part 4: Customs Clearance Practical Advice (Battle-Tested Pitfall Avoidance)
β 1. Document Checklist (Essential)
| Document | Mandatory? | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must specify Material: PE (Polyethylene), Form: Film/Sheet, Structure: Bubble. |
| β Photos | βοΈ | Clear images showing the bubble texture and flexibility to justify "Film" or "Article" classification. |
| β Commercial Invoice | βοΈ | Accurate description: "Polyethylene Bubble Film for Packaging." |
| β Packing List | βοΈ | Weight and dimensions. |
| β Customs Ruling (Optional) | βοΈ | Recommended to secure 3926.90.48.00 classification to save 28.1% in taxes. |
β 2. Classification Strategy (Critical Decision)
π₯ "Film vs. Article: Choose Wisely, Save Thousands!"
| Situation | Recommended HS Code | Reason | Tax Rate |
|---|---|---|---|
| Standard Bubble Roll | 3920.99.20.00 or 3921.19.00.10 |
Viewed as "Plastic Film" under general chapters. | 39.2% β 41.5% |
| Bubble Film (Optimized) | 3926.90.48.00 |
Viewed as "Other Plastic Article." Exempt from Section 301. | 13.4% |
| Bubble Film (Partial Relief) | 3926.90.99.89 |
Viewed as "Other Plastic Article" but with different subcategory. | 22.8% |
| Ethylene Polymer Film | 3921.11.00.00 |
Specific to Ethylene polymers. High tax. | 40.3% |
π Pro Tip:
- Argue for3926.90.48.00: If the bubble film is pre-cut, printed, or finished into a specific shape (e.g., pillows), it is easier to classify as an "Article" (Chapter 39, Head 3926) rather than a "Film" (Chapter 39, Heads 3920/3921).
- Head 3926 covers "Other articles of plastics," which often has more favorable trade treatment than "Plastic Films" (Head 3920/3921) under Section 301.
β 3. Special Scenarios
| Scenario | Handling Advice |
|---|---|
| Pre-cut Bubble Pouches | Clearly state "Finished Article" in description. Push for 3926.90.48.00. |
| Bulk Rolls | Risk of being classified as 3920 or 3921. Provide technical specs to argue flexibility and article status. |
| Mixed Packaging | If bubble film is included as free packaging material, declare separately. If sold as a product, declare individually. |
| Origin | China Origin triggers Section 301 & 122. Ensure CO (Certificate of Origin) is accurate. |
π Part 5: Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Estimated Tax (China Origin) | Notes |
|---|---|---|---|
| πΊπΈ USA | 3926.90.48.00 |
13.4% | Best option. Avoid 3921 (41.5%). |
| π¨π³ China | 3920.99.20.00 |
~5-6% | Import duty low. No Section 301. |
| πͺπΊ EU | 3920.99 |
~6.5% | Standard MFN rate. No Section 122/301. |
| π¬π§ UK | 3920.99 |
~6.5% | Post-Brexit rules similar to EU. |
| π¨π¦ Canada | 3920.99 |
~5% | CUSMA benefits may apply if from US/Mexico. |
π Conclusion:
- USA is the only major market with high punitive tariffs (Section 301 & 122).
- Classification as3926(Article) vs.3921(Film) is the single biggest cost factor.
π Part 6: Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Automatically using 3921.19.00.10 for bubble film.
π Consequence: You pay 41.5% tax. If you had used 3926.90.48.00, you would pay only 13.4%. Overpayment: 28.1%.
β Mistake 2: Describing product only as "Plastic Film."
π Consequence: Customs may classify it as 3920 or 3921, triggering high Section 301 tariffs.
π Fix: Use "Plastic Bubble Article" or "Packaging Bubble Wrap" and provide proof of finished form.
β Mistake 3: Ignoring Section 122 Tariffs.
π Consequence: Even if Section 301 is exempt (e.g., 3926.90.48.00), 10% Section 122 still applies. Do not assume 0% tax.
β Correct Approach:
"Polyethylene Bubble Film, Finished Article, for Packaging, Model XYZ, HS Code 3926.90.48.00"
π― Part 7: Conclusion: Professional Declaration, Cost Optimization!
π― Remember the Golden Rule:
πΉ "Film = High Tax (39-41%) | Article = Low Tax (13-22%)"
πΉ "Head 3926 is the Key to Savings!"
πΉ "Section 301 is the Enemy; Section 122 is the Ally (Wait, no! Section 301 is the enemy, Section 122 is still a cost, but 3926 saves you the 25% hit!)"
π Tips:
- If your bubble film is pre-cut or custom-shaped, strongly advocate for 3926.90.48.00.
- If it is plain bulk rolls, the risk of being classified as 3921 is higher. Consider negotiating price to absorb the higher tax or seeking an Advance Ruling.
- Always verify the latest Section 122 status, as it can change.
π£ Immediate Action:
π Consult with your customs broker before shipment.
π Request an HS Code Advance Ruling from U.S. Customs.
π Optimize your supply chain, save up to 28.1% in duties!
β¨ Professional Clearance Starts with Precise Classification!
πΌ Every Percent Saved is Profit Gained!
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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.