PET 铝箔高透膜
CN → US| HS Code | Tariff Rate | Origin | Destination | 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 |
| 7607201000 | 13.7% | CN | US | Official Doc |
Product Images
AI Analysis
📦 PET-Aluminum Foil High-Transparency Composite Film
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Strategy for Composite Packaging
📌 Part 1: Product Definition & Classification: Do You Really Understand "PET-Al Foil High-Transparency Film"?
This product is a composite packaging material primarily consisting of Polyethylene Terephthalate (PET) and Aluminum Foil (Al). It is widely used in food packaging, pharmaceutical blister packs, and flexible packaging due to its excellent barrier properties (light, oxygen, moisture) and strength.
In international trade, the classification hinges on the primary function, material composition ratio, and structural definition. Is it considered a "plastic film" or a "foil product"? This distinction drastically affects the tariff rate.
⚠️ Key Classification Distinction:
- If the structure is viewed as a composite plastic sheet/film where PET is the base and Al is a layer →归入 Chapter 39 (Plastics).
- If the structure is viewed as an aluminum foil product with PET backing for handling →归入 Chapter 76 (Aluminum).
- Note: In the provided dataset, there is a conflict between Chapter 39 and Chapter 76 interpretations. Below is the detailed breakdown based on the provided data.
📊 Part 2: HS Code Classification Details (Based on Provided Data)
The following four HS Codes are derived from the input data. Please choose the one that best matches your specific product structure and manufacturer's declaration intent.
| HS Code | Product Summary (from Data) | Interpretation & Applicability |
|---|---|---|
| 3923.90.00.80 | Plastic packaging film (PET + Al foil composite). Classified as "Other plastic articles." | Scenario: Used as general packaging bags, sachets, or rolls where the plastic nature is dominant. Note: "PET with Al foil composite plastic packaging film." |
| 3923.10.90.00 | Plastic film (PET material), for packaging purposes. | Scenario: Focuses on the application (packaging). If the Al layer is very thin or treated as a coating, it may fall here. Note: "Plastic (PET) material film, for packaging use." |
| 3921.90.40.10 | Plastic film (PET). Meets the definition of plastic plates, sheets, film, foil, and strips. | Scenario: Focuses on the physical form. If declared strictly as a plastic film item under Chapter 39. Note: "Plastic class (PET) film, compliant with plastic plate/sheet/film definition." |
| 3921.90.40.90 | PET & Al foil composite, film form. Classified under plastic plates/sheets/films. | Scenario: The "other" category for composite plastic films in Chapter 39. Similar to .10 but for non-specific plastic film types. Note: "PET and aluminum foil composite material, in film form, classified as plastic plate/sheet/film." |
| 7607.20.10.00 | Aluminum foil film with PET backing. Meets aluminum foil characteristics. | Scenario: Crucial Difference. If customs views the Aluminum as the essential character. Note: "Contains aluminum foil film, with PET backing, meets aluminum foil characteristics." |
🔍 Critical Observation:
- HS Codes 3923.xx, 3921.xx treat the product as Plastic (Chapter 39).
- HS Code 7607.20.10.00 treats the product as Aluminum (Chapter 76).
- Why two different tax rates? Chapter 39 items attract higher "Additional Tariffs" (25%), while Chapter 76 items do not attract the 25% additional tariff (only 10%).
💰 Part 3: 2026 Latest Tariff Rate Detailed Explanation (Including Surcharges)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: From 2025/2026 onwards (Based on Data Context)
🎯 1. High-Tariff Group: Plastic-Based Classification (HS Codes 3923.90.00.80, 3923.10.90.00, 3921.90.40.10, 3921.90.40.90)
These codes are classified under Chapter 39 (Plastics). They are subject to ALL surcharges.
| Item | Content |
|---|---|
| Base Tariff | 3.0% - 4.2% (Ad Valorem) (3% for 3923 codes, 4.2% for 3921 codes) |
| USITC Surcharge (301 Tariff) | +25.0% (Applies to most Chinese-made plastic/aluminum composite films) |
| IEEPA Surcharge (Section 122/China Specific) | +10.0% (Targeted surcharge on Chinese origin products) |
| Total Effective Tax Rate | 38.0% - 39.2% |
| Calculation | CIF Value × (Base + 25% + 10%) |
| De Minimis Exemption | ❌ NOT APPLICABLE (Deny de minimis for this HS code group) |
| Legal Basis Path | USITC:3923/3921 → FOOTNOTE:25% Surcharge → IEEPA:10% Surcharge |
📌 Explanation:
- The 25% USITC surcharge is the major cost driver.
- The 10% IEEPA surcharge is additional.
- Total ~38-39% makes this a high-cost import category.
- Example: For3921.90.40.10, Base is 4.2% + 25% + 10% = 39.2%.
🎯 2. Low-Tariff Group: Aluminum-Based Classification (HS Code 7607.20.10.00)
This code is classified under Chapter 76 (Aluminum). It attracts a lower surcharge profile.
| Item | Content |
|---|---|
| Base Tariff | 3.7% (Ad Valorem) |
| USITC Surcharge (301 Tariff) | 0.0% (Aluminum foil products may be exempt from the 25% plastic/electronics surcharge in this specific dataset context) |
| IEEPA Surcharge (Section 122/China Specific) | +10.0% |
| Total Effective Tax Rate | 13.7% |
| Calculation | CIF Value × 13.7% |
| De Minimis Exemption | ❌ NOT APPLICABLE (Usually, de minimis is denied for surcharged items, but check specific CBP rulings) |
| Legal Basis Path | USITC:7607.20.10.00 → IEEPA:10% Surcharge |
📌 Explanation:
- NO 25% Surcharge is applied here in the provided data.
- Only the 10% IEEPA surcharge applies.
- Total ~13.7% is significantly cheaper than the ~39% plastic classification.
- Strategic Implication: If your product can be legally declared as "Aluminum Foil with PET Backing" (HS 7607.20.10.00), you save ~25% in duties.
🛠️ Part 4: Customs Clearance Practical Advice (Battle-Tested Tips)
✅ 1. Documentation Checklist (Essential)
| Document | Required | Explanation |
|---|---|---|
| Product Spec Sheet | ✅ | Must clearly state: PET Thickness, Al Foil Thickness, Total Thickness, Layers. |
| Composition Ratio | ✅ | CRITICAL: Declare the % by weight or thickness of PET vs. Al. This determines if it's "Plastic" or "Aluminum" dominant. |
| Product Photos | ✅ | Show cross-section (layered structure) and end-use (packaging). |
| Commercial Invoice | ✅ | Describe as: "Composite Flexible Packaging Film: PET/Al Foil/LDPE" OR "Aluminum Foil with PET Backing". |
| Packing List | ✅ | Include weight, volume, and number of rolls/sheets. |
| Certificate of Origin | ✅ | Mandatory for proving China origin (triggers surcharges). |
✅ 2. Declaration Strategy (Key Mnemonic)
🔥 "Al Dominant = 13.7%, Plastic Dominant = 39%! Choose Wisely!"
| Scenario | Recommended HS Code | Tax Rate | Risk Level |
|---|---|---|---|
| Al Foil is the main barrier; PET is just a backing for strength | 7607.20.10.00 | 13.7% | ⚠️ Medium. Must prove Al is "essential character." |
| PET is the main structural material; Al is a thin coating | 3923.90.00.80 or 3921.90.40.90 | 38.0-39.2% | ✅ Low. Standard plastic film declaration. |
| General Packaging Roll | 3923.10.90.00 | 38.0% | ✅ Low. Easy to justify as "plastic packaging." |
✅ 3. Special Handling & Pitfalls
| Situation | Advice |
|---|---|
| Customs Audits on "Aluminum Foil" | If you declare 7607.20.10.00, be prepared to show that the Al foil is the primary value-add or functional layer. If PET is thicker/more expensive, customs may revert to Chapter 39. |
| "High-Transparency" Claim | Do NOT claim "High Transparency" if there is a solid Al layer. Al foil is opaque. If it's "High Transparency," it might be PET/Metalized PET (not solid Al), which changes the HS code entirely (likely 3921.xx). Clarify: Is it solid Al or Metalized? The data says "Al Foil," implying opacity. |
| De Minimis (Section 321) | ❌ DO NOT USE Section 321 de minimis for these HS codes. The data implies "deny_de_minimis" for all listed codes due to surcharges. Shipments under $800 will likely be seized or held. |
| Packaging Form | Ensure rolls are wound correctly. If cut into sheets, ensure the description matches "Plastic Plates/Sheets" (3921) vs "Foil" (7607). |
🌍 Part 5: Global Market Comparison (Inferred)
| Market | Recommended Approach | Est. Tax Impact |
|---|---|---|
| 🇺🇸 USA | Strategic Classification: Try to justify 7607.20.10.00 for 13.7% vs 39%. |
High Sensitivity. 25% surcharge makes Chapter 39 very expensive. |
| 🇨🇳 China (Export) | Declare as "Plastic Composite Film" (3921/3923) for domestic consistency. | 0% Export Tax. |
| 🇪🇺 EU | Likely 3921.xx. VAT varies (19-27%). No "Section 122" type surcharges. | Moderate. |
📌 Conclusion for US Importers:
The 13.7% vs 39.2% difference is massive.
- If your product is Al Foil with PET backing, argue for 7607.20.10.00.
- If it is a Plastic Film with Al layer (e.g., laminated bag), it is likely 3923.90.00.80.
- Consult a Customs Broker to submit a Pre-Ruling if the product structure is borderline.
📌 Part 6: Common Errors & Pitfalls (Blood & Tears Lessons)
❌ Error 1: Declaring "Aluminum Foil" but the product is Metalized PET (thin metal coating on plastic, not solid foil).
👉 Consequence: HS Code should be 3921.xx (Plastic). If declared as 7607, it's false declaration. If declared as 3923, tax is 39%. Check: Is it solid Al or Vapor Deposited?
❌ Error 2: Ignoring the 25% USITC Surcharge for Chapter 39 codes.
👉 Consequence: Budgeting for 3% tax, but paying 39%. Profit Margin Erosion!
❌ Error 3: Using "De Minimis" for shipments < $800.
👉 Consequence: CBP will seize the goods. These codes are explicitly excluded from de minimis exemptions in the provided data context.
❌ Error 4: Vague Description: "Plastic Film."
👉 Consequence: Customs will inspect, delay, and possibly reclassify to the highest tariff code.
✅ Correct Description Example:
"Composite Flexible Packaging Film: 12 micron PET / 7 micron Aluminum Foil / 15 micron LDPE. Total Thickness: 34 microns. Wound on Core. For Food Packaging."
🎯 Part 7: Conclusion: Precise Classification Saves Money!
🎯 Key Takeaway:
🔹 "Al Foil Backing? Aim for 7607 (13.7%). Plastic Dominant? Expect 3921/3923 (39%)."
🔹 "The 25% Surcharge is the Killer. Don't let it slip."
🔹 "No De Minimis. Ship Big or Ship Smart."
📌 Pro Tip:
If you are unsure about the "Essential Character" of the film, consider applying for an Customs Ruling with CBP before large-scale shipment. The difference between 13.7% and 39.2% is not just a number; it's the difference between profit and loss.
📣 Immediate Action:
📞 Contact your Freight Forwarder: Confirm if they can support
7607.20.10.00declaration.
📄 Review Spec Sheet: Ensure PET/Al ratio is clear.
🚀 Optimize Supply Chain: If 39% is unavoidable, explore sourcing from non-China origins for US market if possible (to avoid IEEPA 10% + 301 25%).
✨ Professional Customs Clearance Starts with Accurate HS Codes!
💼 Every Percent in Tax is a Percent in Profit Lost!
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.