PET Aluminum Plated Label Film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 7607201000 | 13.7% | CN | US | Official Doc |
| 3920620050 | 39.2% | CN | US | Official Doc |
| 3919905060 | 40.8% | CN | US | Official Doc |
| 3920992000 | 39.2% | CN | US | Official Doc |
| 3920620090 | 39.2% | CN | US | Official Doc |
AI Analysis
π·οΈ PET Aluminum Plated Label Film (PETιιζ ηΎθ)
π HS Code Reference & Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Really Understand "PET Al Film"?
PET Aluminum Plated Film (Metallized PET) is a composite material widely used in packaging, electronics, and decorative labels. It consists of a base PET (Polyethylene Terephthalate) film coated with a thin layer of aluminum via vacuum metallization. In international trade, its classification hinges on two critical factors:
1. The Purpose/Function: Is it a generic protective film, a specialized metallized film, or specifically formatted as a label?
2. The Surface Treatment: Does it retain its metallic luster (metallized) or is it treated further (e.g., adhesive backing for labels)?
β οΈ Key Distinction Points:
- If the product is generic PET film with aluminum coating (used for barrier properties, insulation, or general metallized applications) β It falls under Chapter 76 (Aluminum) or 3907/3920 (Plastics) depending on specific physical characteristics.
- If the product is specifically prepared for labeling (often with adhesive backing or die-cut) β It falls under Chapter 39 (Plastics), specifically heading 3919 (Self-adhesive plates/sheets/film) or 3920 (Other plastics plates/sheets/film).
- Crucial Note: The presence of "Aluminum" does not automatically place it in Chapter 76 if the plastic base characterizes the essential nature, or if it is classified as a prepared labeling material.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Cross-Reference)
Based on the provided data, here are the potential HS Codes and their corresponding tax implications. The choice depends on the specific physical form and commercial intent of the product.
| HS Code | Product Description | Application Scenario | Tax Burden | Classification Logic |
|---|---|---|---|---|
7607.20.10.00 |
PET Aluminum Film: PET base, metallized, foil/metallic film characteristics. | General metallized PET film for industrial use, insulation, or non-label applications. | 13.7% | Classified as Aluminum foil/wheel. The summary states it "conforms to the physical characteristics of aluminum foil/metallic film." |
3920.62.00.50 |
Metallized PET Film (Other): PET base, metallized, falls under "Other" in metallic PET category. | Standard metallized PET film where specific label preparation is not the primary feature. | 39.2% | Classified as Other plastics sheets/film. High tariff due to "Section 301" duties. |
3919.90.50.60 |
PET Label Film: PET material, flat sheet/film form, specifically for labeling. | Products explicitly marketed as "Label Film," often implying adhesive backing or specific die-cutting for labels. | 40.8% | Classified as Self-adhesive articles. Highest tariff rate due to being a "prepared" plastic good. |
3920.99.20.00 |
PET Label Film: PET base, film form, flexible sheet/strip characteristics. | Alternative classification for label films under "Other plastics plates, sheets, film..." | 39.2% | Classified as Other plastics films. Similar to 3920.62 but different sub-heading based on specific plastic type or treatment. |
3920.62.00.90 |
PET Label Film: PET base, film form, NON-metallic treatment implied or excluded from specific metallized code. | Note: The summary says "Does not involve metal treatment" despite the product name. This suggests a potential misclassification risk if the film IS metallized. | 39.2% | Classified as Other plastics films. WARNING: If the product IS aluminum-plated, this code is incorrect and may lead to penalties. |
π Critical Insight:
-7607.20.10.00(13.7%) is the most cost-effective option IF the film can be legally classified as "Aluminum Foil" or "Metallic Film" under Chapter 76. This requires proving that the aluminum layer contributes significantly to the product's character.
-3919.90.50.60(40.8%) is the most expensive but most accurate if the product is a self-adhesive label.
-3920codes (39.2%) are middle-ground options for non-adhesive metallized films.
- β οΈ Risk Alert:3920.62.00.90explicitly states "does not involve metal treatment." If your product is aluminum-plated, using this code is highly risky and constitutes misclassification.
π° III. 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
β Applicable Market: United States (US)
β Origin: China (CN)
β Effective Date: From November 10, 2025 (including subsequent imports)
π― 1. 7607.20.10.00 ββ Aluminum Foil / Metallic Film (Best Case Scenario)
| Item | Detail |
|---|---|
| Base Tariff | 3.7% (ad valorem) |
| Section 301 Surcharge | 0.0% |
| Section 122 Surcharge | 10.0% |
| Total Tariff | 13.7% |
| Tax Calculation | CIF Value Γ 13.7% |
| De Minimis Eligibility | β No (Deny de minimis) |
| Legal Basis Path | Section 122 β USITC:7607.20.10.00 |
π Explanation:
- This code benefits from 0% Section 301 duty, which is a significant advantage over other plastic codes.
- The 10% Section 122 duty applies to aluminum products.
- Total 13.7% is the lowest among all options, making this the preferred classification if legally defensible.
π― 2. 3920.62.00.50 ββ Metallized PET Film (Other)
| Item | Detail |
|---|---|
| Base Tariff | 4.2% |
| Section 301 Surcharge | 25.0% |
| Section 122 Surcharge | 10.0% |
| Total Tariff | 39.2% |
| Tax Calculation | CIF Value Γ 39.2% |
| De Minimis Eligibility | β No |
| Legal Basis Path | Section 301 (9903.01.24) β Section 122 β USITC:3920.62.00.50 |
π Explanation:
- Section 301 (25%) is the major cost driver.
- Section 122 (10%) is also applied.
- This code is for metallized films that do not qualify as "Aluminum Foil" under Chapter 76.
π― 3. 3919.90.50.60 ββ Self-Adhesive Label Film (Most Expensive)
| Item | Detail |
|---|---|
| Base Tariff | 5.8% |
| Section 301 Surcharge | 25.0% |
| Section 122 Surcharge | 10.0% |
| Total Tariff | 40.8% |
| Tax Calculation | CIF Value Γ 40.8% |
| De Minimis Eligibility | β No |
| Legal Basis Path | Section 301 β Section 122 β USITC:3919.90.50.60 |
π Explanation:
- Highest Tariff (40.8%).
- Applies if the film is self-adhesive (label roll).
- The high base tariff (5.8%) combined with 301 and 122 duties makes this the most costly option.
π― 4. 3920.99.20.00 & 3920.62.00.90 ββ Other Plastic Films
| Item | Detail |
|---|---|
| Base Tariff | 4.2% |
| Section 301 Surcharge | 25.0% |
| Section 122 Surcharge | 10.0% |
| Total Tariff | 39.2% |
| Tax Calculation | CIF Value Γ 39.2% |
| De Minimis Eligibility | β No |
| Legal Basis Path | Section 301 β Section 122 β USITC:3920.xxxxx |
π Explanation:
- Same total rate as3920.62.00.50.
- Crucial Warning:3920.62.00.90states "does not involve metal treatment." If your product IS aluminum-plated, this code is incorrect. Misclassification can lead to audits, back taxes, and penalties.
π οΈ IV. Clearance Practical Advice (Battle-Tested Pitfall Avoidance)
β 1. Documentation Checklist (Non-Negotiable)
| Document | Required | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must clearly state: Base Material (PET), Coating (Aluminum), Thickness, Width, Roll Size. |
| β Commercial Invoice | βοΈ | Description must match HS Code logic. E.g., "Metallized PET Film" vs. "Self-Adhesive Label Roll". |
| β Packing List | βοΈ | Detailed breakdown of rolls, cores, and packaging. |
| β Proof of Metallization Process | βοΈ | If claiming 7607.20.10.00, provide evidence that the aluminum layer is integral (e.g., vacuum metallization reports). |
| β No Adhesive Declaration | βοΈ | If claiming 3920 codes, confirm if adhesive is present. If no adhesive, do NOT use 3919. |
| β Third-Party Test Report | βοΈ | To prove physical characteristics (e.g., aluminum content %). |
β 2. Classification Strategy (Key Mantras)
π₯ βAluminum Core? Chapter 76. Plastic Core? Chapter 39. Adhesive? 3919. No Adhesive? 3920.β
| Scenario | Correct HS Code | Risk if Wrong |
|---|---|---|
| Generic Metallized PET Film (No adhesive, used for packaging/insulation) | 7607.20.10.00 (13.7%) |
Misclassifying as 3920 leads to ~25.5% extra tax. |
| Metallized PET Film (Cannot prove Chapter 76 eligibility) | 3920.62.00.50 (39.2%) |
Safe fallback, but high cost. |
| Self-Adhesive Label Roll (With glue backing) | 3919.90.50.60 (40.8%) |
Using 3920 will cause clearance delays; Customs will reclassify. |
| PET Film with NO Aluminum | 3920.62.00.90 (39.2%) |
Do not use if aluminum is present. |
β 3. Special Circumstances Handling
| Situation | Recommendation |
|---|---|
| OEM Label Film | Provide end-product design. If itβs clearly a label, use 3919. If itβs a raw film for others to make labels, use 3920 or 7607. |
| Mixed Shipments | If a shipment contains both adhesive and non-adhesive films, separate them in the declaration. Do not mix HS Codes in one line. |
| Duty Drawback | If re-exporting, ensure the original classification allows for drawback claims. 7607 may have better drawback potential due to lower duty. |
| Customs Audit Risk | For 7607.20.10.00, be prepared to prove that the aluminum layer is not merely a surface treatment but defines the product as "foil." |
π V. Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 7607.20.10.00 |
13.7% | None specific | Lowest cost. Requires strong justification. |
| πΊπΈ USA | 3919.90.50.60 |
40.8% | None specific | High cost. Only for adhesive labels. |
| π¨π³ China | 3920.62.00.00 |
~5-10% | CCC (if applicable) | Lower tariffs, no 301/122. |
| πͺπΊ EU | 3920.62.00.00 |
~0-3% | REACH | Generally low tariffs. |
| π¬π§ UK | 3920.62.00.00 |
~0-5% | UKCA | Post-Brexit rules apply. |
π Conclusion:
- The USA is the most challenging market due to Section 301 (25%) and Section 122 (10%) duties.
-7607.20.10.00is the strategic sweet spot for metallized films, saving ~25-27% in duties compared to plastic classifications.
- Misclassification is expensive: Using3920for a7607product costs an extra 25.5% in taxes.
π VI. Common Mistakes & Pitfalls (Blood & Tears Lessons)
β Mistake 1: Classifying all "PET Film" under 3920 without checking if it qualifies as 7607.
π Consequence: Paying 39.2% instead of 13.7%. Loss of 25.5% margin!
β Mistake 2: Using 3919 (Adhesive) for non-adhesive metallized film.
π Consequence: Customs rejection, delays, and potential fines for incorrect declaration.
β Mistake 3: Ignoring Section 122 (10%) for aluminum products.
π Consequence: Underpayment of duties. Section 122 applies to all aluminum products imported from China.
β Mistake 4: Using 3920.62.00.90 for aluminum-plated film.
π Consequence: High Audit Risk. This code explicitly excludes metal treatment. Customs will flag this as a lie.
β Correct Approach:
"Is it Aluminum Foil? β 7607 (13.7%). Is it Plastic Film? β 3920 (39.2%). Is it Label? β 3919 (40.8%). Check Adhesive. Check Metal."
π― VII. Conclusion: Precision Classification Saves Money!
π― Remember the Mantra:
πΉ β7607 is King, 3920 is Queen, 3919 is the Jester. Donβt pay 40% when you can pay 13%.β
πΉ βSection 122 Hits Aluminum, Section 301 Hits Plastics. Know your material!β
π Pro Tip:
If you are importing Metallized PET Film, consult with a customs broker to argue for
7607.20.10.00. Provide samples, thickness measurements, and metallization process details to prove it qualifies as "Aluminum Foil."If you are importing Adhesive Labels, accept the
3919.90.50.60(40.8%) rate or explore supply chain adjustments to reduce costs.
π£ Immediate Action:
π Contact your customs broker with Product Specs and Request HS Code Pre-Ruling.
π Save 25% in duties by getting the classification right from the start!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every Percent of Duty Saved is Pure Profit!
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.