PET Aluminum Foil High Transparency Film
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3920620050 | 39.2% | CN | US | Official Doc |
| 7607201000 | 13.7% | CN | US | Official Doc |
| 3923900080 | 38.0% | CN | US | Official Doc |
| 3923109000 | 38.0% | CN | US | Official Doc |
| 3921904010 | 39.2% | CN | US | Official Doc |
| 3921904090 | 39.2% | CN | US | Official Doc |
AI Analysis
🎞️ PET Aluminum Foil High Transparency Film (PET镀铝薄膜)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 Part 1: Product Definition & Classification – What Exactly Is "PET Aluminum Foil High Transparency Film"?
PET Aluminum Foil High Transparency Film is a composite or metallized functional material widely used in packaging, optics, and electronics. In international trade, it is primarily distinguished by its material composition and manufacturing process:
- Metallized PET Film (Metalized Film): PET film coated with a thin layer of aluminum via vacuum metallization. It retains the transparency of PET while offering metallic luster and barrier properties.
- PET-Aluminum Foil Composite: A laminate structure where PET film is bonded with a layer of actual aluminum foil, often used for high-barrier packaging.
⚠️ Key Distinction for Classification:
- If the product is PET film with a thin aluminum coating (metallization process) → It is generally classified under Chapter 39 (Plastics) as metallized plastic film.
- If the product is a composite of PET and thick Aluminum Foil (lamination process) → It may be classified under Chapter 39 as a plastic composite or Chapter 76 as aluminum foil, depending on the dominant material and usage.
- Crucial: The term "High Transparency" suggests it is likely metallized PET (which is semi-transparent) rather than opaque aluminum foil. This points strongly towards HS Codes 3920 or 3921.
📦 Part 2: HS Code Classification Details (2026 Latest Tariff Authority Match)
Based on the provided , here are the specific HS Codes and their tax implications for PET-related films and laminates.
| HS Code | Product Description | Material/State | Total Tax Rate | Tax Breakdown |
|---|---|---|---|---|
| 3920.62.00.50 | PET Metallized Film (PET镀铝薄膜) | PET, Metallized Film State | 39.2% | Base: 4.2% Add'l: 25.0% Sec 301: 10% |
| 7607.20.10.00 | PET Film / Aluminum Foil (PET薄膜，铝箔/金属化) | PET, Aluminum Foil/Metallized State | 13.7% | Base: 3.7% Add'l: 0.0% Sec 301: 10% |
| 3923.90.00.80 | PET-Aluminum Foil Packaging Film (PET铝箔包装膜) | PET + Aluminum Foil Composite, for Packaging | 38.0% | Base: 3.0% Add'l: 25.0% Sec 301: 10% |
| 3923.10.90.00 | PET Packaging Film (PET包装膜) | Plastic, Film State | 38.0% | Base: 3.0% Add'l: 25.0% Sec 301: 10% |
| 3921.90.40.10 | PET Film (PET膜) | Plastic, Film State | 39.2% | Base: 4.2% Add'l: 25.0% Sec 301: 10% |
🔍 Key Insight:
- 3920.62.00.50 is the most precise fit for "PET Metallized Film" (PET镀铝薄膜).
- 7607.20.10.00 offers a significantly lower tax rate (13.7%) but describes "PET film" or "Aluminum Foil" in a way that might be contested if the product is clearly a plastic film with metallization.
- 3923.xxxx codes apply if the film is specifically packaging and involves composite structures (PET + Foil).
💰 Part 3: 2026 Tariff Rate Detailed Breakdown (Including Add-on Taxes)
✅ Applicable Country: USA (US)
✅ Origin: China (CN)
✅ Effective Date: From November 10, 2025 onwards (for subsequent imports)
🎯 1. 3920.62.00.50 – PET Metallized Film (Most Likely Match for "PET镀铝薄膜")
| Item | Detail |
|---|---|
| Base Tariff | 4.2% (ad valorem) |
| Section 301 Tariff | +25.0% (Additional Tariff under US Trade Law Section 301) |
| Section 122 Tariff | +10.0% (Additional Tariff under Section 122 of the Trade Expansion Act) |
| Total Tax Rate | 39.2% |
| Tax Calculation | CIF Value × 39.2% |
| De Minimis Exemption | ❌ Not Applicable (deny_de_minimis) |
| Legal Basis | USITC:3920.62.00.50 → 301:25% → 122:10% |
📌 Explanation:
- The 25% Section 301 tariff is the dominant cost driver for Chinese-origin plastic films.
- The 10% Section 122 tariff is an additional national security-based levy.
- Total 39.2% is very high. Accurate classification is critical to avoid penalties.
🎯 2. 7607.20.10.00 – PET Film / Aluminum Foil (Lowest Tax Option?)
| Item | Detail |
|---|---|
| Base Tariff | 3.7% (ad valorem) |
| Section 301 Tariff | 0.0% (No additional 301 tariff for this specific heading in some contexts) |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 13.7% |
| Tax Calculation | CIF Value × 13.7% |
| De Minimis Exemption | ❌ Not Applicable |
| Legal Basis | USITC:7607.20.10.00 → 122:10% |
⚠️ Caution:
- This code has a much lower total tax (13.7%).
- However, customs authorities may challenge this if the product is predominantly PET plastic film with metallization, as it falls under Chapter 39.
- Use this code only if the product is classified as "Aluminum Foil" (Chapter 76) rather than "Plastic Film" (Chapter 39). This requires strong technical justification that the aluminum layer is the essential character.
🎯 3. 3923.90.00.80 – PET-Aluminum Foil Packaging Film
| Item | Detail |
|---|---|
| Base Tariff | 3.0% (ad valorem) |
| Section 301 Tariff | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 38.0% |
| Tax Calculation | CIF Value × 38.0% |
| De Minimis Exemption | ❌ Not Applicable |
| Legal Basis | USITC:3923.90.00.80 → 301:25% → 122:10% |
📌 Note:
- Applies to composite films specifically used for packaging.
- Tax is slightly lower than pure metallized PET (39.2%) due to a lower base rate (3.0% vs 4.2%).
- Must prove the product is a composite (PET + Foil) and used for packaging.
🎯 4. 3923.10.90.00 – PET Packaging Film
| Item | Detail |
|---|---|
| Base Tariff | 3.0% (ad valorem) |
| Section 301 Tariff | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 38.0% |
| Tax Calculation | CIF Value × 38.0% |
| De Minimis Exemption | ❌ Not Applicable |
| Legal Basis | USITC:3923.10.90.00 → 301:25% → 122:10% |
📌 Note:
- Similar to above, but may apply to simpler PET films used for packaging.
- Less accurate for "aluminum foil" specific products unless the foil is considered part of the plastic composite.
🎯 5. 3921.90.40.10 – PET Film (General Plastic Film)
| Item | Detail |
|---|---|
| Base Tariff | 4.2% (ad valorem) |
| Section 301 Tariff | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 39.2% |
| Tax Calculation | CIF Value × 39.2% |
| De Minimis Exemption | ❌ Not Applicable |
| Legal Basis | USITC:3921.90.40.10 → 301:25% → 122:10% |
📌 Note:
- A general "other plastic film" code.
- Used if the product doesn't fit neatly into 3920 (plastics, not cellulosic) or 3923 (packaging articles).
- Same high tax rate as 3920.62.00.50.
🛠️ Part 4: Customs Clearance Practical Advice (Battle-Tested Guide)
✅ 1. Essential Documentation Checklist (Must-Haves)
| Document | Required? | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Detail material structure (e.g., "PET 12μm + Al coating 0.02μm"), dimensions, transparency level. |
| ✅ Technical Data Sheet (TDS) | ✔️ | Confirm if it is "metallized" (coating) or "laminated" (composite). |
| ✅ Product Photos (Clear) | ✔️ | Show cross-section (if possible), surface luster, and any packaging. |
| ✅ Commercial Invoice | ✔️ | Clearly state "PET Metallized Film" or "PET-Aluminum Composite Film". |
| ✅ Packing List | ✔️ | Detail weight, volume, and number of rolls/units. |
| ✅ Certificate of Origin (CO) | ✔️ | Mandatory for US origin verification. |
| ✅ Third-Party Test Report | ✔️ | Optional but recommended: Adhesion test, barrier property test, optical clarity. |
✅ 2. Classification Strategy & Tips (Critical!)
🔥 "Metallized is Plastic, Composite is Packaging, Origin is China, Tax is High!"
| Scenario | Correct HS Code | Why? | Risk |
|---|---|---|---|
| PET Film with Vacuum-Metallized Al Layer | 3920.62.00.50 |
It is a plastic film with a metallized surface. Dominant material is PET. | Low if described correctly. |
| PET Laminated with Aluminum Foil (for Packaging) | 3923.90.00.80 |
Composite structure used for packaging. | Medium if not clearly "composite". |
| Aluminum Foil with PET Coating | 7607.20.10.00 |
If aluminum is the essential character. | High risk of reclassification to Chapter 39. |
| Generic PET Film (No Al) | 3921.90.40.10 or 3923.10.90.00 |
If "High Transparency" implies no significant Al layer. | Low if no Al is present. |
📌 Key Advice:
- Do NOT use7607.20.10.00unless you are certain the product is classified as "Aluminum Foil" under Chapter 76. Customs may deem it a "plastic film" (Chapter 39) and reassess.
- Do NOT under-declare value. The 25% + 10% add-ons are on CIF value.
- Do NOT use "De Minimis" for shipments from China. These tariffs apply regardless of value.
✅ 3. Special Cases Handling
| Case | Recommendation |
|---|---|
| Customized OEM Film | Provide customer specs and design files to prove intended use. |
| High-Barrier Packaging | If used for food/pharma packaging, emphasize "Packaging Film" (HS 3923) to potentially benefit from lower base rates (3.0% vs 4.2%). |
| Optical/Electronic Use | If not for packaging, use 3920 or 3921. |
| Sample Shipment | Still subject to full tariffs. Do not assume samples are exempt. |
🌍 Part 5: Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Rate (China Origin) | Key Certification | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3920.62.00.50 |
39.2% | None specific, but clear description | High tariffs due to 301 & 122. |
| 🇺🇸 USA | 7607.20.10.00 |
13.7% (if accepted) | None | Risky classification. |
| 🇪🇺 EU | 3920.62.00.00 |
~7-12% (varies) | REACH, RoHS | No Section 301/122. Lower tax. |
| 🇨🇳 China | 3920.62.00.00 |
~5-10% | None | Lower import duties. |
| 🇯🇵 Japan | 3920.62.00.00 |
~5-8% | JIS | Moderate duties. |
📌 Conclusion:
- USA is the most challenging market due to 39.2% total tariffs.
- Consider supply chain diversification (e.g., manufacturing in Vietnam/Malaysia) if tariff costs are prohibitive.
- Pre-clearance ruling from US CBP is highly recommended for new product lines.
📌 Part 6: Common Mistakes & Pitfalls (Lessons Learned)
❌ Mistake 1: Classifying "Metallized PET Film" as "Aluminum Foil" (HS 7607) to save taxes.
👉 Consequence: Customs reclassifies to HS 3920, applies 39.2%, plus penalties. Loss of 25.5% savings + fees!
❌ Mistake 2: Ignoring "Section 122" tariffs.
👉 Consequence: Underpayment by 10%. Customs will demand back payment + interest.
❌ Mistake 3: Using vague descriptions like "Plastic Film" on invoice.
👉 Consequence: Customs may select for inspection, delay shipment, and request technical data. Delivery delay = $100s/day in storage.
❌ Mistake 4: Assuming "De Minimis" applies.
👉 Consequence: Small shipments from China are NOT exempt from Section 301/122 tariffs. Full tax due.
✅ Correct Practice:
"PET Metallized Film, 12 Micron Thickness, Vacuum-Aluminized, High Transparency, for Packaging Use, Model XYZ"
🎯 Part 7: Conclusion – Smart Classification, Cost Control!
🎯 Remember the Mantra:
🔹 "Metallized is Plastic (3920), Composite is Packaging (3923), Aluminum Foil is 7607 but risky, China origin means 39% tax!"
🔹 "Accurate HS Code saves thousands, vague description invites audit!"
📌 Pro Tip:
If your product is exclusively for packaging, argue for HS 3923 (38.0%) to save 1.2% vs HS 3920 (39.2%). The base rate difference (3.0% vs 4.2%) makes it worthwhile if the composite nature is clear.
📣 Immediate Action:
📞 Contact a US Customs Broker + Provide Technical Data Sheet + Request Pre-Ruling (Advance Ruling) from CBP.
🚀 Minimize Tax Burden, Ensure Smooth Clearance, Maximize Profit!
✨ Professional Customs Clearance Starts with Precise Classification!
💼 Every Dollar Counts in High-Tariff Environments!
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) — Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) — More specific grouping within the chapter
- Subheading (6 digits) — Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) — 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 — The standard duty rate applied to WTO members
- General rate — Applied to countries without trade agreements
- Trade remedy duties — 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.