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PET镀铝绝缘膜

CN → US
HS Code Tariff Rate Origin Destination Doc
7607201000 13.7% CN US Official Doc
3926909989 22.8% CN US Official Doc
7607205000 17.5% CN US Official Doc
3926909400 35.0% CN US Official Doc
3926909989 22.8% CN US Official Doc

AI Analysis

🎨 PET Aluminum-Coated Insulation Film

(Polyethylene Terephthalate Vapor-Deposited Aluminum Insulation Film)

🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional-Level Strategy
📌 I. Product Definition & Classification: Do You Really Understand "PET Aluminized Film"?

PET aluminum-coated insulation film is a composite functional material widely used in electronics, solar energy, and packaging. It consists of a PET (polyester) base film with a thin layer of aluminum deposited on its surface (usually via vacuum metallization).

In international trade, the classification depends heavily on whether the aluminum layer is considered the "essential character" or if the PET substrate dominates. This leads to divergent HS Code interpretations and significant tax implications.

⚠️ Key Distinction Point:
- If the product is primarily viewed as "Aluminum Foil with Plastic Backing" → It falls under Chapter 76 (Aluminum).
- If the product is primarily viewed as a "Plastic Film/Product" → It falls under Chapter 39 (Plastics).
- Note: The presence of "Anti-static" or "Insulation" functions does NOT automatically change the HS code, but the material composition does.


📦 II. HS Code Classification Details (Based on Provided Data)

The following table breaks down the five specific HS Codes provided in the dataset, explaining the rationale and associated tax burdens for PET Aluminized Film.

HS Code Product Description & Rationale Total Tax Rate* Tax Breakdown (US Context)
7607.20.10.00 Aluminum Foil with Plastic Backing.
Rationale: Classified as aluminum foil with a PET backing. The aluminum layer is considered the primary functional element.
13.7% Base: 3.7%
Additional: 0.0%
Section 122: 10%
3926.90.99.89 Other Plastic Articles.
Rationale: Classified as a finished plastic product/film. The PET substrate is dominant; aluminum is just a coating. Applies to both Insulation and Anti-static variants in some contexts.
22.8% Base: 5.3%
Additional: 7.5%
Section 122: 10%
7607.20.50.00 Aluminum Foil with Plastic Backing (Other).
Rationale: Similar to 7607.20.10 but may differ in thickness, width, or specific application definitions within Chapter 76. PET acts as the backing material.
17.5% Base: 0.0%
Additional: 7.5%
Section 122: 10%
3926.90.94.00 Plastic Sheets/Films (Other).
Rationale: Classified strictly as a plastic sheet/film. This category often attracts the highest penalties in current trade environments.
35.0% Base: 0.0%
Additional: 25.0%
Section 122: 10%
3926.90.99.89 Other Plastic Articles (Insulation Variant).
Rationale: Specifically referenced for "PET Aluminized Insulation Film." Treated identically to the anti-static version under this code.
22.8% Base: 5.3%
Additional: 7.5%
Section 122: 10%

* Tax Rates calculated based on the provided JSON data, which reflects a specific trade scenario (likely US imports from China, given the "Section 122" and "122 Clause" references, along with typical 301/IEEPA surcharges).


💰 III. Detailed Tax Rate Analysis (2026 Context)

🎯 1. The "Aluminum Route": 7607.20.10.00 & 7607.20.50.00

  • Best For: Products where the aluminum layer provides the primary shielding or reflective function.
  • Tax Profile:
    • 7607.20.10.00 (13.7%): The most balanced option. Low base tariff (3.7%) with no additional 301-style surcharge, only the 10% Section 122.
    • 7607.20.50.00 (17.5%): No base tariff, but higher additional surcharge (7.5%) + 10% Section 122.
  • Strategic Advantage: Lower overall tax burden compared to most plastic classifications.

🎯 2. The "Plastic Route": 3926.90.99.89

  • Best For: Products where the PET film is the primary structural element, and the aluminum is merely a surface treatment.
  • Tax Profile:
    • Rate: 22.8%
    • Breakdown: Base (5.3%) + Additional (7.5%) + Section 122 (10%).
  • Risk: Higher than the aluminum route. If misclassified from 7607 to 3926, you pay an extra ~9% in duties.

🎯 3. The "High-Penalty Route": 3926.90.94.00

  • Best For: Generic plastic films that do not meet specific exemption criteria.
  • Tax Profile:
    • Rate: 35.0% (The Highest in the dataset)
    • Breakdown: Base (0.0%) + Additional 25.0% + Section 122 (10%).
  • Warning: This code includes a massive 25% additional tariff. Avoid this code unless absolutely necessary, as it can destroy profit margins.

🛠️ IV. Customs Clearance Practical Advice (Pitfall Avoidance Guide)

✅ 1. Preparation Checklist (Non-negotiable)

Document Requirement Reason
Product Specification Sheet Must detail: PET thickness, Al thickness (nm), conductivity/resistivity values. To prove whether it's "Aluminum Foil" or "Plastic Film."
Structure Diagram Cross-section showing layers (PET base + Al layer). Customs needs to see if Al is vapor-deposited (thin) or rolled foil (thick).
Commercial Invoice Clear description: "PET Aluminized Film for Insulation" or "Anti-static." Vague descriptions like "Aluminum Foil" without mentioning PET backing can lead to audits.
Usage Statement Intended end-use (e.g., "used in solar panels," "used in ESD packaging"). Helps justify the functional classification.

✅ 2. Classification Strategy (Crucial Decision)

🔥 Rule of Thumb: "Aluminum defines the function, Plastic defines the shape."

Scenario Recommended HS Code Why?
High Reflectivity/Shielding 7607.20.10.00 The aluminum layer is the key functional component. Lowest tax (13.7%).
Structural Insulation/ESD Control 3926.90.99.89 If the PET substrate's properties (thickness, flexibility) are more critical than the Al layer. Moderate tax (22.8%).
Generic/Undifferentiated 3926.90.94.00 AVOID if possible. High tax (35%). Only use if the product clearly doesn't fit other plastic categories.

✅ 3. Common Errors & Consequences

Error 1: Declaring "Aluminum Foil" when it's actually "PET Film with Al Coating." 👉 Consequence: Customs may reclassify to 3926 or impose fines for misdeclaration. If they think it's pure aluminum, they might expect different origin rules.

Error 2: Using 3926.90.94.00 for a standard insulated film. 👉 Consequence: Paying 35% tax instead of 13.7% or 22.8%. That’s a 10-20% extra cost on every shipment.

Error 3: Ignoring the "Section 122" clause. 👉 Consequence: Forgetting that 10% is added to all codes in this dataset. Many traders miss this hidden cost.


🌍 V. Global Market Comparison (Contextual Note)

Market Typical Classification for PET Al Film Note
🇺🇸 USA (This Dataset) 7607 or 3926 Heavy use of Section 122/301/IEEPA surcharges. Choice of HS code drastically affects final cost.
🇪🇺 EU 7606 or 3920 Generally lower tariffs for aluminum/plastic composites if origin is non-preferential. No "Section 122."
🇨🇳 China (Export) 3920 or 7607 Export duties may apply. Check local HS codes.

📌 Conclusion:
For US Imports, 7607.20.10.00 (13.7%) is the optimal choice if the product can be justified as "Aluminum Foil with Plastic Backing."
If the product is more plastic-dominant, 3926.90.99.89 (22.8%) is acceptable.
Avoid 3926.90.94.00 (35.0%) unless forced by specific product characteristics.


📌 VI. Actionable Next Steps

  1. Evaluate Physical Properties: Measure aluminum thickness. If < 0.02mm, it’s often considered "coated film" (Chapter 39), but if > 0.02mm, it leans toward "foil" (Chapter 76). Check specific tariff notes.
  2. Apply for Advance Ruling: If the product is a new design, file an Advance Ruling with US Customs to lock in the 7607 classification and secure the 13.7% rate.
  3. Update Documentation: Ensure invoices explicitly state "PET Backing" to support the 7607 classification if chosen.

🎯 Final Thought

💡 "Classification is Cost Control!"
Choosing between 7607 and 3926 isn't just academic—it's a 9% to 21.3% difference in tax liability.
Don't let ambiguous descriptions cost you millions in customs duties.


Professional Clearance Starts with Precise Classification!
💼 Every percent of tax saved is pure profit!

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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.