PET镀铝复合膜
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 7607201000 | 13.7% | CN | US | Official Doc |
| 3920620050 | 39.2% | CN | US | Official Doc |
| 3919102055 | 40.8% | CN | US | Official Doc |
| 3919905060 | 40.8% | CN | US | Official Doc |
| 7607201000 | 13.7% | CN | US | Official Doc |
AI Analysis
🎬 PET Aluminum-Deposited Composite Film (PET镀铝复合膜)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Grade Clearance Strategy
📌 I. Product Definition & Classification: What Exactly is "PET Aluminum-Deposited Film"?
PET Aluminum-Deposited Composite Film is a high-performance functional packaging material. It consists of a Polyethylene Terephthalate (PET) base film with a microscopic layer of aluminum deposited via vacuum metallization. It combines the mechanical strength and heat resistance of PET with the barrier properties (light, oxygen, moisture) of metal.
In international trade, the classification depends critically on the final form and function: * As a Raw Film/Material: If used as a substrate for further processing, it is often classified under plastics (Chapter 39) or metallized aluminum (Chapter 76). * As an Adhesive Tape: If it has been slit into rolls with an adhesive backing, it is classified under plastic tapes (Chapter 39). * Electrostatic/Specialized: If specifically treated for anti-static properties, it may still fall under films but with specific descriptors.
⚠️ Key Distinction Point:
- Is it a bare film/roll without adhesive? → Likely 7607 (Aluminum foil) or 3920 (Other plastic sheets).
- Is it a pre-cut, self-adhesive tape? → Must be 3919 (Plastic tape).
- Is it anti-static? → Specific descriptors in summary may shift risk, but HS code logic remains tied to form.
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided <DATA>, there are 3 distinct HS Codes depending on the specific product form.
| HS Code | Product Description | Form/Feature | Applicable Scenario |
|---|---|---|---|
7607.20.10.00 |
PET Aluminum-Deposited Film or Anti-Static Film | Film (Metallized) | Raw PET rolls with aluminum coating; serves as barrier packaging material. |
3920.62.00.50 |
PET Aluminum-Deposited Film | Metallized Film (Other) | PET film classified under "Other" plastic plates/sheets/film with metallization. |
3919.10.20.55 |
PET Aluminum-Deposited Tape Base Film | Tape (Plastic Strip) | PET aluminum film that has been converted into adhesive tape. |
3919.90.50.60 |
PET Aluminum-Deposited Tape Base Film | Other Self-Adhesive Tape | Alternative classification for PET aluminum adhesive tapes not falling under 3919.10. |
7607.20.10.00 |
PET Aluminum Anti-Static Film | Film (Plastic Backed Aluminum) | Specifically noted as "with plastic backing" but classified as aluminum foil due to core function. |
🔍 Critical Note:
- Do not mix "Film" and "Tape": If your product has adhesive, it MUST be classified under3919(Tapes). Declaring a tape as a film (7607or3920) is a major compliance error leading to high penalties. - Material vs. Form:7607focuses on the aluminum content/form, while3920/3919focus on the plastic composition/form. Customs often challenge7607for heavily plasticized PET unless the aluminum layer is dominant or the product is strictly "foil-like."
💰 III. 2026 Latest Tariff Rate Breakdown (Including Surtaxes, Policy Surcharges)
✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN)
✅ Effective Time: 2025 November 10 onwards (including subsequent imports)
🎯 1. 7607.20.10.00 —— PET Aluminum-Deposited Film / Anti-Static Film
| Item | Content |
|---|---|
| Base Tariff | 3.7% |
| Additional Tariff (Section 301) | 0.0% |
| 122 Clause Tariff | +10.0% |
| Total Tax Rate | 13.7% |
| Tax Calculation | CIF Value × 13.7% |
| De Minimis Exemption? | ❌ No (Subject to strict scrutiny) |
| Legal Basis Path | Base: 7607 → 122 Clause: 10% → Total: 13.7% |
📌 Explanation:
- This is the lowest tax rate option.
- It applies if the product is deemed primarily an aluminum foil product or a specific metallized film under Chapter 76.
- Risk: Customs may argue it’s a plastic film (3920) rather than aluminum foil, leading to reclassification and higher taxes.
🎯 2. 3920.62.00.50 —— PET Aluminum-Deposited Film (Other Category)
| Item | Content |
|---|---|
| Base Tariff | 4.2% |
| Additional Tariff (Section 301) | +25.0% |
| 122 Clause Tariff | +10.0% |
| Total Tax Rate | 39.2% |
| Tax Calculation | CIF Value × 39.2% |
| De Minimis Exemption? | ❌ No |
| Legal Basis Path | Base: 3920 → 301: 25% → 122: 10% → Total: 39.2% |
📌 Explanation:
- This classification treats the product as an other plastic sheet/film.
- High Cost: The 25% Section 301 surtax significantly increases costs.
- When to use: If the aluminum layer is very thin and the product is clearly used as a plastic substrate rather than a metal barrier.
🎯 3. 3919.10.20.55 & 3919.90.50.60 —— PET Aluminum-Deposited Tape Base Film
| Item | Content |
|---|---|
| Base Tariff | 5.8% |
| Additional Tariff (Section 301) | +25.0% |
| 122 Clause Tariff | +10.0% |
| Total Tax Rate | 40.8% |
| Tax Calculation | CIF Value × 40.8% |
| De Minimis Exemption? | ❌ No |
| Legal Basis Path | Base: 3919 → 301: 25% → 122: 10% → Total: 40.8% |
📌 Explanation:
- Highest Tax Rate: This applies if the product is self-adhesive tape.
- Crucial Distinction: If your "PET Aluminum Film" has any adhesive backing and is sold as tape, you cannot use7607or3920. You must use3919.
- Common Error: Declaring adhesive tape as non-adhesive film to save 25-27%. This triggers severe audits, back taxes, and fines.
🛠️ IV. Customs Clearance Practical Advice (Combat Pitfalls Guide)
✅ 1. Document Checklist (None Missing)
| Document | Required? | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must clearly state: PET Base, Aluminum Coating Thickness, Adhesive Presence/Absence, Anti-Static properties. |
| ✅ Product Photos | ✔️ | Show the roll, the edge (to confirm no adhesive), and any labeling. |
| ✅ Commercial Invoice | ✔️ | Must match the HS Code logic (e.g., "PET Aluminum Film" vs. "PET Aluminum Tape"). |
| ✅ Packing List | ✔️ | Confirm net/gross weight and package count. |
| ✅ Declaration Form | ✔️ | Accurate English/Chinese description. |
✅ 2. Declaration Tips (Critical Mnemonic)
🔥 "No Adhesive = Film/Tape? No! No Adhesive = Film/3920/7607. YES Adhesive = Tape/3919!"
| Scenario | Correct HS Code | Error Scenario | Consequence |
|---|---|---|---|
| Bare PET Alu Film (No Adhesive) | 7607.20.10.00 or 3920.62.00.50 |
Declared as Tape | Under-declaration of tax; penalty. |
| Bare PET Alu Film (No Adhesive) | 7607.20.10.00 or 3920.62.00.50 |
Declared as Tape | 40.8% Tax vs. 13.7%/39.2% → Overpayment! |
| Adhesive PET Alu Tape | 3919.10.20.55 or 3919.90.50.60 |
Declared as Film | Under-declaration; 25% Section 301 missing → Penalty & Back Taxes. |
| Anti-Static PET Alu Film | 7607.20.10.00 |
Declared as Standard Film | Potential misclassification; risk of audit. |
✅ 3. Special Case Handling
| Situation | Handling Advice |
|---|---|
| OEM Custom Film | Provide design specs showing it’s a raw material, not a finished tape. |
| Anti-Static Labeling | Ensure the invoice mentions "Anti-Static" if declaring 7607.20.10.00, as this code specifically covers it in the data. |
| Mixed Shipment | If you ship both films and tapes, declare separately. Do not bundle them under one HS code. |
| 122 Clause | All HS codes listed are subject to the 10% 122 Clause Tariff. Do not forget this in cost calculations. |
🌍 V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Notes |
|---|---|---|---|
| 🇺🇸 USA | 7607.20.10.00 (Film) or 3919 (Tape) |
13.7% (Film) / 40.8% (Tape) | High Section 301 + 122 Clause. Critical to classify correctly. |
| 🇨🇳 China | 3920.62.00.00 / 3919.10.00.00 |
~5-10% | No Section 301. Lower costs for export to China. |
| 🇪🇺 EU | 3920.62.00 / 3919.10.00 |
0-6.5% | No Section 301. Standard MFN rates apply. |
| 🇯🇵 Japan | 3920.62.00 / 3919.10.00 |
0-3.8% | Low tariffs. No punitive surcharges. |
📌 Conclusion:
- USA is the only market with punitive surcharges (301 + 122).
- Cost Sensitivity: A misclassification between Film (13.7%) and Tape (40.8%) results in a 27.1% difference in total tax.
- Strategy: For non-adhesive films, try to justify7607.20.10.00for the lowest rate, but ensure you have strong technical justification that it’s treated as "aluminum foil" or specific metallized film. If it’s clearly plastic-based,3920is safer but more expensive. If it has adhesive, only3919is compliant.
📌 VI. Common Errors & Pitfalls Guide (Blood & Tears Lessons)
❌ Error 1: Declaring Adhesive Tape as Film (7607) to avoid Section 301.
👉 Consequence: Customs audit, 25% back-tax + 10% 122 clause + penalties.
👉 Result: Total tax jumps from 13.7% to 40.8%.
❌ Error 2: Using Vague Description like "Packaging Material".
👉 Consequence: Customs cannot determine HS Code → Delay in clearance, possible storage fees.
👉 Fix: Use precise terms: "PET Aluminum-Deposited Film, 12 microns, No Adhesive".
❌ Error 3: Ignoring the 122 Clause (10%).
👉 Consequence: Under-budgeting. The 10% is mandatory for all HS codes listed.
👉 Fix: Always add 10% to your cost calculation.
❌ Error 4: Confusing Anti-Static with Standard Film.
👉 Consequence: Misdescription. While 7607.20.10.00 covers it, ensure the specs match.
👉 Fix: Highlight "Anti-Static" in the invoice if using this code.
✅ Correct Approach:
"PET Aluminum-Deposited Film, 12μm, Vacuum Metallized, No Adhesive, Anti-Static Option Available, Coiled Roll"
🎯 VII. Conclusion: Professional Classification, Save Money, Avoid Risk
🎯 Remember the Mnemonic:
🔹 "Adhesive = Tape (3919, 40.8%). No Adhesive = Film (7607/3920, 13.7%/39.2%). 122 Clause = Always +10%."
🔹 "HS Code is King. 27% Tax Difference. Wrong Classification = Huge Penalty."
📌 Pro Tip:
If your product is non-adhesive PET aluminum film, consider arguing for 7607.20.10.00 to achieve the 13.7% rate, provided you can justify its classification under aluminum foil/metallized film rules. If it’s clearly a plastic substrate, 3920.62.00.50 at 39.2% is the compliant alternative. Never misdeclare adhesive tape as film.
📣 Immediate Action:
📞 Consult a licensed customs broker.
🚀 Prepare technical specs proving presence/absence of adhesive.
💰 Calculate costs using 13.7%, 39.2%, or 40.8% accordingly.
✨ Professional Clearance Starts with Accurate Classification!
💼 Every Cent Saved is a Profit Earned!
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.