PET 反光膜
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3926909989 | 22.8% | CN | US | Official Doc |
| 3926909925 | 22.8% | CN | US | Official Doc |
| 3919901000 | 41.5% | CN | US | Official Doc |
| 3919905010 | 40.8% | CN | US | Official Doc |
AI Analysis
🚧 Reflective Film (PP/Plastic Material)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Customs Strategy
📌 I. Product Definition & Classification: Is it "Film" or "Plastic Article"?
Reflective films, often made from PP (Polypropylene) or similar plastics, are critical components in road safety and traffic management. In international trade, they are classified based on their physical form and specific function:
- Reflective Sheeting (Rolls/Coils): If the product is supplied in rolls or coils and features a reflective surface (e.g., microprismatic or glass bead technology), it is often classified under Chapter 39 (Plastics) as "Self-adhesive plates, sheets, film..." or specific "Reflectorized sheeting".
- Signage/Marks (Cut Shapes): If the product is already cut into specific shapes (like warning signs, symbols, or arrows) and is not in roll form, it is typically classified as "Other articles of plastic" under Chapter 39, as it has assumed a specific shape/function beyond just a "film."
⚠️ Key Distinction Point:
- If the product is in rolls/coils and clearly designed as a reflective surface → Consider 3919 (Self-adhesive films/sheets).
- If the product is cut shapes, signs, or general plastic articles with reflective properties → Consider 3926 (Other plastic articles).
- Material: PP (Polypropylene) is firmly a plastic material, ruling out Chapter 32 (Paints) or Chapter 90 (Optical instruments) unless it is part of a complex optical instrument (which simple road films are not).
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Cross-Reference)
Based on the provided data for PP-based Reflective Films, here are the four potential HS Codes and their specific justifications:
| HS Code | Product Description | Justification from Data | Key Characteristic |
|---|---|---|---|
3926.90.99.25 |
Other Plastic Articles (Road Signs) | Material Match: PP is plastic. Use Match: Reflective film fits the material/function needs of road reflective warning signs. | Specific End-Use: Classifies as a "Sign/Mark" rather than just raw film. |
3926.90.99.89 |
Other Plastic Articles (General) | Material Match: PP is plastic. Form/Use Match: It is a plastic article, not excluded from other categories, fitting the "catch-all" definition for other plastic products. | General Catch-All: Used if it doesn't fit specific sub-categories like signs. |
3919.90.10.00 |
Self-Adhesive Plastic Sheets/Films (Non-Printed) | Material Match: PP is plastic. Form Match: Film is flat. Use Match: Reflective characteristic matches glass-bead generated reflective surface features. | Form-Based: Classified by its shape (film/roll) and reflective nature. |
3919.90.50.10 |
Self-Adhesive Plastic Sheets/Films (Reflectorized) | Material Match: PP is plastic. Use Match: Fits the use attribute of "Reflectorized sheeting". | Function-Based: Specifically targets "reflectorized sheeting" within self-adhesive films. |
🔍 Critical Reminder:
- The choice between 3919 (Film/Sheet) and 3926 (Article/Sign) depends on whether the item is imported as a raw material/roll or a finished product/cut sign. - 3919 codes generally carry higher total tariffs due to specific trade remedies (Section 301) targeting adhesive products. - 3926 codes may offer slightly lower or different tariff structures but depend heavily on the "specific use" definition in local customs interpretations.
💰 III. 2026 Latest Tariff Rate Breakdown (Including Add-On Taxes, Policy Surcharges)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Time: 2025/2026 (Subject to current trade policies)
🎯 1. 3926.90.99.25 & 3926.90.99.89 —— Other Plastic Articles
| Item | Content |
|---|---|
| Base Duty Rate | 5.3% (Ad Valorem) |
| Section 301 Duty (Add-On) | +7.5% |
| Section 122 Duty (Add-On) | +10% |
| Total Effective Rate | 22.8% |
| Tax Calculation | CIF Value × 22.8% |
| De Minimis Exemption | ❌ Not Eligible (Typically high-value commercial goods) |
| Legal Basis Path | HTSUS:3926.90.99 → Section 301 List 3 → Section 122 (China Specific) |
📌 Explanation:
- These codes fall under "Other plastic articles." The base rate is relatively low (5.3%). - However, Section 301 adds 7.5%, and Section 122 (often applied to specific Chinese goods) adds another 10%. - Total: 22.8%. This is a moderate-high tariff compared to some consumer goods, but significantly lower than the 3919 options below.
🎯 2. 3919.90.10.00 —— Self-Adhesive Plastic Sheets/Films
| Item | Content |
|---|---|
| Base Duty Rate | 6.5% (Ad Valorem) |
| Section 301 Duty (Add-On) | +25.0% |
| Section 122 Duty (Add-On) | +10% |
| Total Effective Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Exemption | ❌ Not Eligible |
| Legal Basis Path | HTSUS:3919.90.10 → Section 301 List 3 → Section 122 |
📌 Explanation:
- High Tariff Alert!
- The base rate is 6.5%, but the Section 301 tariff is 25%, which is the standard punitive rate for many Chinese plastic/adhesive products. - Total: 41.5%. This is a very high cost burden. If your product can be classified under 3926, it saves nearly 19% in duties.
🎯 3. 3919.90.50.10 —— Reflectorized Sheeting
| Item | Content |
|---|---|
| Base Duty Rate | 5.8% (Ad Valorem) |
| Section 301 Duty (Add-On) | +25.0% |
| Section 122 Duty (Add-On) | +10% |
| Total Effective Rate | 40.8% |
| Tax Calculation | CIF Value × 40.8% |
| De Minimis Exemption | ❌ Not Eligible |
| Legal Basis Path | HTSUS:3919.90.50.10 → Section 301 List 3 → Section 122 |
📌 Explanation:
- Very similar to the above 3919 code. Base rate is slightly lower (5.8% vs 6.5%), but the 25% Section 301 duty remains. - Total: 40.8%. Still a high-cost classification.
🛠️ IV. Customs Clearance Practical Advice (Pitfall Avoidance Guide)
✅ 1. Preparation Checklist (Non-Negotiable)
| Document | Required | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must specify material (PP), thickness, reflective type (glass bead/prismatic), and whether it is self-adhesive. |
| ✅ Photos (Uninstalled & Installed) | ✔️ | Show the roll form (if 3919) or the cut shape/sign (if 3926). |
| ✅ Composition Statement | ✔️ | Explicitly state: "100% Polypropylene (PP) with reflective coating." |
| ✅ Commercial Invoice | ✔️ | Must accurately describe the item (e.g., "PP Reflective Film for Road Signs" vs. "Reflective Material"). |
| ✅ Origin Certificate | ✔️ | If claiming any exemptions (rare for China origin under current tariffs), provide proof. |
✅ 2. Declaration Strategy (Key Tips)
🔥 “Form Defines Code: Rolls go to 3919, Signs go to 3926.”
| Scenario | Correct HS Code | Why? | Cost Impact |
|---|---|---|---|
| Importing Rolls/Coils | 3919.90.10.00 or 3919.90.50.10 |
Physically a "film/Sheet." Fits Chapter 39 heading 39.19. | ~41% (High Risk) |
| Importing Cut Signs/Shapes | 3926.90.99.25 |
Finished "Article." Fits Chapter 39 heading 39.26. | ~23% (Lower) |
| Generic Plastic Plates | 3926.90.99.89 |
Doesn't fit specific sign or film sub-codes. | ~23% (Lower) |
| Misdeclaration | Declaring Signs as Film | ⚠️ High Risk | If Customs re-classifies, you pay back taxes + penalties. |
📌 Pro Tip:
If you are importing raw rolls to cut into signs later in the US, you must use 3919. You cannot declare them as "Signs" (3926) because they are not yet in that form.
If you are importing pre-cut signs from the factory, strictly use 3926 to save significant duty costs.
✅ 3. Special Cases & Mitigation
| Case | Handling Advice |
|---|---|
| Self-Adhesive Backing | If the product has a strong adhesive layer, 3919 is more likely, but ensure the primary characteristic is "plastic article" if cut. |
| Glass Bead vs. Prismatic | Both can fall under 3919 if in film form. The key is the form (roll vs. cut). |
| Transshipment via Vietnam/Malaysia | ⚠️ Warning: Simple transshipment does not exempt Section 301 or 122 duties. Substantial transformation is required. |
| Sample/Small Quantity | Still subject to de minimis rules. If value < $800, may be duty-free under Section 321, but documentation is still required for compliance. |
🌍 V. Global Market Comparison (2026 Update)
| Market | Recommended HS Code | Estimated Duty (China Origin) | Notes |
|---|---|---|---|
| 🇺🇸 USA | 3926.90.99.25 |
22.8% | Best if imported as cut signs. |
| 🇺🇸 USA | 3919.90.10.00 |
41.5% | High penalty for rolls/films. |
| 🇪🇺 EU | 3920.62.00 |
~2.5% - 6.5% | VAT (19-27%) applies. No Section 301. |
| 🇨🇳 China | 3919.90.90 |
~6.5% | Export from US? Check US export controls. |
| 🇲🇽 Mexico | 3926.90.99 |
~5% | USMCA may apply if originating. |
📌 Conclusion:
- The USA is the most challenging market due to Section 301 and Section 122 duties.
- Strategy: Import finished signs (3926) whenever possible to enjoy the lower 22.8% rate. Avoid importing rolls (3919) unless necessary, as the 41% duty is a massive margin killer.
📌 VI. Common Mistakes & Pitfalls (Blood & Tears Lessons)
❌ Mistake 1: Declaring pre-cut signs as "Plastic Film" (3919)
👉 Consequence: Overpaying ~18% in duties unnecessarily.
👉 Fix: Declare as "Reflective Signage Material" or "Plastic Articles."
❌ Mistake 2: Declaring rolls as "Signs" (3926)
👉 Consequence: Customs rejection, reclassification, and penalties.
👉 Fix: If it’s in a roll, it’s a film/sheet (3919). Be honest about the form.
❌ Mistake 3: Ignoring "Section 122"
👉 Consequence: Underpayment by 10%.
👉 Fix: Always check if the product falls under Section 122 (often applies to specific Chinese plastic goods).
✅ Correct Approach:
"Rolls = 3919 (High Tax). Cut Signs = 3926 (Lower Tax). Verify Material (PP) and Form."
🎯 VII. Conclusion: Professional Declaration, Save Costs!
🎯 Remember the Rule:
🔹 "Form Dictates Code: Rolls to 3919, Signs to 3926."
🔹 "PP Reflective Film: 3926 saves 19% duty vs 3919."
🔹 "Check Section 301 & 122: They add up to ~35-40%!"
📌 Tip:
If you are importing large volumes, consider customs bond strategies or pre-classification rulings from CBP (Customs and Border Protection) to lock in the 3926 classification for your specific product design.
📣 Immediate Action:
📞 Consult a licensed customs broker.
📸 Provide photos of the product (roll vs. cut).
📝 Ensure your invoice clearly states the physical form and material composition.
🚀 Minimize your tax burden with precise classification!
✨ Professional Customs Clearance Starts with Accurate Classification!
💼 Every percentage point 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) — 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.