PET Metallized Label Film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3919905060 | 40.8% | CN | US | Official Doc |
| 3920992000 | 39.2% | CN | US | Official Doc |
| 3920620090 | 39.2% | CN | US | Official Doc |
| 3919905040 | 40.8% | CN | US | Official Doc |
| 7607201000 | 13.7% | CN | US | Official Doc |
| 3920620050 | 39.2% | CN | US | Official Doc |
AI Analysis
π·οΈ PET Metallized Label Film (Polyester Metallized Label Film)
π HS Code Classification & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professionalιε
³ Strategy
π I. Product Definition & Core Characteristics: What is "Metallized PET Label Film"?
PET Metallized Label Film is a high-performance packaging material made by depositing a thin layer of metal (usually aluminum) onto a polyester (PET) film substrate under vacuum conditions. It combines the excellent mechanical properties of PET with the metallic luster and barrier properties of aluminum.
In international trade, the core distinction for classification lies in the degree of metallization and the final form: * Self-Adhesive Label Film (Rolls/Sheets): If the film has an adhesive backing and is primarily used for labeling, it may fall under Heading 3919 (Self-adhesive plates, sheets, film...). * Metalized/Coated Flexible Film: If the film is primarily valued for its metallized surface properties (barrier, shine) and is not self-adhesive, or if the metallization is the key characteristic, it falls under Heading 3920 (Other plates, sheets, film, foil and strip, of plastics).
β οΈ Critical Distinction Point:
- If the product is already labeled or has permanent adhesive on one side β 3919.90.50.xx (Self-adhesive)
- If the product is bare metallized film (no adhesive) β 3920.62.xx (Other plastic films)
- If the product is labeled PET film vs. Pure metallized PET film, the tax rates differ significantly due to Section 301 & 122 tariffs.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Key Features | Adhesive? | Metallization? |
|---|---|---|---|---|
3919.90.50.60 |
PET Label Film, Plastic Material, Flat Film Form | Self-adhesive PET film used for labels | β Yes | β No (Standard) |
3920.99.20.00 |
PET Material Film, Flexible Film/Strip/Film, Other | Generic PET film, not elsewhere specified | β No | β No |
3920.62.00.90 |
PET Material Film, Non-Metalized | Pure PET film without metal coating | β No | β No |
3919.90.50.40 |
Self-Adhesive Plastic Film, PET Material, Film Form | Self-adhesive PET film, general category | β Yes | β No |
7607.20.10.00 |
PET Aluminum-Metallized Film | Matches foil/metallized film characteristics | β No | β Yes (Aluminum) |
3920.62.00.50 |
Metalized PET Film, "Other" Category | Metallized PET film, not specified elsewhere | β No | β Yes |
π Key Insight:
- Metallized films often face different tariff treatments. Specifically,7607.20.10.00(Aluminum foil/metallized) has a much lower base tariff than standard PET films.
- However, self-adhesive versions (3919...) are subject to higher "Section 301" and "122" penalties in the US market.
- Pure metallized films (7607or3920.62.00.50) may offer different tax structures depending on the specific metallization process and whether it's considered "foil-like."
π° III. 2026 Latest Tariff Rate Details (Detailed Breakdown)
β Applicable Market: United States (US)
β Origin: China (CN)
β Effective Time: Current (Post-2024 Adjustments)
π― 1. 3919.90.50.60 & 3919.90.50.40 ββ Self-Adhesive PET Label Films
| Item | Content |
|---|---|
| Base Tariff | 5.8% (for 3919.90.50.60) or 5.8% (for 3919.90.50.40) |
| Section 301 Tariff | +25.0% (Additional duty on Chinese goods) |
| Section 122 Tariff | +10.0% (Additional duty on specific plastic articles from China) |
| Total Effective Rate | 40.8% |
| Calculation Basis | CIF Value Γ 40.8% |
| De Minimis Exemption | β Not Eligible (High tax burden prevents $800 exemption) |
| Legal Basis Path | USITC:3919.90.50.xx β Footnote: Section 301 β Footnote: Section 122 |
π Explanation:
- These codes are for self-adhesive label films.
- The 40.8% total rate is extremely high, driven by both Section 301 (25%) and Section 122 (10%) on top of the base duty.
- Risk: High probability of audit due to the combination of duties.
π― 2. 3920.99.20.00 & 3920.62.00.90 ββ Non-Metallized PET Films
| Item | Content |
|---|---|
| Base Tariff | 4.2% |
| Section 301 Tariff | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Effective Rate | 39.2% |
| Calculation Basis | CIF Value Γ 39.2% |
| De Minimis Exemption | β Not Eligible |
| Legal Basis Path | USITC:3920.xx.xx β Footnote: Section 301 β Footnote: Section 122 |
π Note:
- These are non-self-adhesive, non-metallized PET films.
- Slightly cheaper than label films (39.2% vs 40.8%) but still heavily taxed.
- Suitable for industrial use where labeling is done separately.
π― 3. 7607.20.10.00 ββ PET Aluminum-Metallized Film (Aluminum Foil-like)
| Item | Content |
|---|---|
| Base Tariff | 3.7% |
| Section 301 Tariff | 0.0% (Exempt or lower impact for this specific aluminum-related heading in some contexts, but verify current 122 status) |
| Section 122 Tariff | +10.0% |
| Total Effective Rate | 13.7% |
| Calculation Basis | CIF Value Γ 13.7% |
| De Minimis Exemption | β Not Eligible (Generally, high-value industrial goods) |
| Legal Basis Path | USITC:7607.20.10.00 β Footnote: Section 122 |
π Explanation:
- This is the most tax-efficient option for metallized PET films.
- Classified under Chapter 76 (Aluminum) because the metallization is substantial, resembling aluminum foil.
- Base tariff is only 3.7%, and Section 301 does not apply (0%), though Section 122 (10%) still applies.
- Total: 13.7% β Significantly lower than label films (40.8%).
- Condition: Must meet the definition of "aluminum foil" or "metallized film" under 7607.
π― 4. 3920.62.00.50 ββ Metalized PET Film (Other)
| Item | Content |
|---|---|
| Base Tariff | 4.2% |
| Section 301 Tariff | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Effective Rate | 39.2% |
| Calculation Basis | CIF Value Γ 39.2% |
| De Minimis Exemption | β Not Eligible |
| Legal Basis Path | USITC:3920.62.00.50 β Footnote: Section 301 β Footnote: Section 122 |
π Note:
- This is for metallized PET films that do not qualify as aluminum foil (7607).
- It is treated as a standard plastic film (3920), incurring the full 39.2% tax burden.
- Strategy: Try to classify under7607.20.10.00if the metallization is significant, to save ~25% in duties.
π οΈ IV. Customs Clearance Practical Advice (Actionable Pitfall Guide)
β 1. Documentation Checklist (Essential for Clearance)
| Document | Required | Notes |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must detail: Base material (PET), Metallization process (Aluminum coating thickness, % coverage), Adhesive type (if any). |
| β Technical Data Sheet (TDS) | βοΈ | Show barrier properties, tensile strength, and metallization method. |
| β Commercial Invoice | βοΈ | Clearly state: "PET Metallized Film" or "Self-Adhesive PET Label Film". Avoid vague terms like "Plastic Sheet". |
| β Packing List | βοΈ | Specify net/gross weight, dimensions, and quantity. |
| β Certificate of Origin | βοΈ | Required for duty assessment. |
| β Third-Party Test Report | βοΈ | Optional but helpful to prove metallization quality if challenged. |
β 2. Classification Strategy & Key Tips
π₯ "Metallization Determines Chapter, Adhesives Determine Heading!"
| Scenario | Recommended HS Code | Tax Rate | Why? |
|---|---|---|---|
| PET Film + Aluminum Coating (No Adhesive) | 7607.20.10.00 |
13.7% | Classified as aluminum foil-like. Lowest tax. |
| PET Film + Aluminum Coating + Adhesive | 3919.90.50.60 |
40.8% | Adhesive pushes it to 3919. High tax. |
| PET Film + No Metallization + No Adhesive | 3920.62.00.90 |
39.2% | Standard plastic film. |
| PET Film + Metallization + No Adhesive (Not Foil-like) | 3920.62.00.50 |
39.2% | Treated as other plastic film. High tax. |
π Strategic Tip:
- If your product is bare metallized film, aggressively argue for7607.20.10.00to save ~25% in Section 301 tariffs.
- If it is self-adhesive, you cannot avoid the high tax, but ensure accurate description to avoid penalties.
β 3. Special Handling
| Situation | Handling Advice |
|---|---|
| Section 122 Tariff (10%) | Applies to most plastic films from China. No exemption currently. |
| De Minimis ($800) | β Do not use for B2B shipments. High duties mean the goods will be seized or redirected to formal entry. |
| OEM/Custom Films | Provide customer PO and technical specs to prove intended use. |
| Mixed Shipment (Label + Unlabeled) | Split HS codes on one invoice? Risky. Better to ship separately or clearly declare each line item. |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Key Requirements |
|---|---|---|---|
| πΊπΈ USA | 7607.20.10.00 |
13.7% | Strong evidence of metallization. |
| πΊπΈ USA | 3919.90.50.60 |
40.8% | Self-adhesive nature is clear. |
| π¨π³ China | 3920.62.00.90 |
4.2% | Standard import. |
| πͺπΊ EU | 3920.62.00.90 |
6.5% | CE marking not required for film, but RoHS may apply. |
| π―π΅ Japan | 3920.62.00.90 |
8.3% | PSE not required for raw film. |
π Conclusion:
- The US market is the most challenging due to Section 301 & 122 tariffs.
- Classifying under 7607 is the best legal strategy to reduce costs for metallized films.
- Self-adhesive labels are the most expensive category.
π VI. Common Mistakes & Pitfall Guide (Lessons Learned)
β Mistake 1: Declaring "Metalized PET Film" as 3920.62.00.90 when it qualifies as 7607.20.10.00
π Consequence: Paying 39.2% instead of 13.7% β Overpayment of ~25%!
β Mistake 2: Declaring "Self-Adhesive Label Film" as 3920... (Non-adhesive)
π Consequence: Customs may reclassify and apply 40.8% + penalties for misdeclaration.
β Mistake 3: Ignoring Section 122 Tariff
π Consequence: Unexpected 10% charge on top of Section 301. Budget accordingly!
β Mistake 4: Using "Plastic Film" as a generic description
π Consequence: Customs may request more info, leading to delays and potential detention.
β Best Practice:
"Polyester (PET) Film, Vacuum-Aluminized, Non-Adhesive, Width 500mm, Thickness 12mic" β
7607.20.10.00
"Self-Adhesive PET Label Film, Clear with Silver Metallized Finish, Roll" β3919.90.50.60
π― VII. Conclusion: Professional Classification Saves Money!
π― Remember the Golden Rule:
πΉ "Metallized? Check 7607 First." (Saves 25% in Section 301)
πΉ "Adhesive? Expect 40.8%." (No easy way out)
πΉ "Section 122 is Always On." (Add 10% to your budget)
π Pro Tip:
If you are importing large volumes, consider Advance Ruling from US Customs (CBP) to lock in the 7607.20.10.00 classification for metallized films. This provides legal certainty and avoids future disputes.
π£ Immediate Action:
π Consult with a licensed customs broker to review your Technical Data Sheets.
π Optimize your supply chain to maximize the use of 7607 classification where possible.
π‘ Precision in classification = Profit in your pocket!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Your cost savings are calculated in every decimal point!
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.