PVC Resin Film Grade
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3921125000 | 41.5% | CN | US | Official Doc |
| 3920490000 | 40.8% | CN | US | Official Doc |
| 3920435000 | 39.2% | CN | US | Official Doc |
| 3919905040 | 40.8% | CN | US | Official Doc |
| 3921121950 | 40.3% | CN | US | Official Doc |
Product Images
AI Analysis
π¦ PVC Resin Film Grade (PVC Films & Sheets)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Strategic Entry Protocols
π I. Product Definition & Classification: What Exactly is "PVC Resin Film Grade"?
PVC Resin Film Grade refers to Polyvinyl Chloride (PVC) specifically formulated for extrusion or calendering into thin films and sheets. Unlike rigid PVC (used for pipes or window profiles), film-grade PVC requires high plasticity, clarity, and flexibility.
In international trade, these are broadly categorized into two main types based on their form and application: 1. Free-standing PVC Films: Sheets used for packaging, blister packs, or lamination. These fall under Chapter 39 (Plastics and Articles Thereof), specifically headings 3920 (non-cellular) or 3921 (other). 2. Self-adhesive PVC Films: Vinyl rolls used for printing, signage, or protection. These fall under 3919 (Self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes).
β οΈ Critical Distinction:
- If the product is a roll/sheet without adhesive (just pure PVC): β Check 3920.xxxx or 3921.xxxx.
- If the product has a glue/adhesive backing (ready to stick): β Check 3919.90.
- The specific chemical composition (Vinyl Chloride Polymer vs. Ethylene-based Vinyl Polymer) determines the exact sub-heading.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Mapping)
Based on the provided data, here are the specific classifications for PVC Film Grade products. Note that all listed codes are subject to significant additional tariffs due to current trade policies.
| HS Code | Product Description | Form/Morphology | Key Characteristics |
|---|---|---|---|
| 3921.12.50.00 | PVC Film, Vinyl Chloride Polymer | Film | Standard rigid or semi-rigid PVC film made from vinyl chloride polymers. |
| 3920.49.00.00 | PVC Film, Ethylene-based Vinyl Polymer | Film | PVC film where the polymer base involves ethylene-based vinyl structures (often for specific flexibility/clarity needs). |
| 3920.43.50.00 | PVC Film, Polyvinyl Chloride Polymer | Film | General-purpose PVC film, likely transparent or colored, non-self-adhesive. |
| 3919.90.50.40 | PVC Film, Plastic Material | Self-adhesive Film | Vinyl rolls with adhesive backing (e.g., for labels, decals, or protective liners). |
| 3921.12.19.50 | PVC Film, Vinyl Chloride Polymer | Film | Specific sub-category of vinyl chloride polymer films, potentially with unique thickness or treatment not covered by 3921.12.50.00. |
π Key Takeaway:
- 3920 and 3921 are for non-adhesive films (packaging, industrial sheets).
- 3919 is exclusively for self-adhesive films.
- Misclassifying an adhesive vinyl as a non-adhesive film (or vice versa) will lead to customs delays and potential penalties.
π° III. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Levies)
β Applicable Country: United States (US)
β Origin: China (CN) (Implied by the "122 Clause" and 25% Section 301 tariffs)
β Effective Date: Current rates apply as per 2026 trade regulations.
π― General Tariff Structure for All Listed HS Codes
All the HS codes provided in the dataset share a common tariff structure due to the ongoing US-China trade tensions.
| Component | Rate | Legal Basis / Explanation |
|---|---|---|
| Base Tariff | 4.2% β 6.5% | Standard MFN (Most Favored Nation) duty rate under HTSUS Chapter 39. Varies slightly by specific subheading. |
| Section 301 Surcharge | +25.0% | Added tariff under Section 301 of the Trade Act of 1974, targeting Chinese imports. This is the dominant cost driver. |
| 122 Clause Surcharge | +10.0% | Refers to specific USITC rulings or statutory provisions (often related to antidumping, countervailing duties, or specific trade agreements/clauses affecting Section 301 calculations). In this context, it appears as a fixed additional levy. |
| Total Effective Tax | 39.2% β 41.5% | Sum of Base + 25% + 10%. |
π― Detailed Breakdown by HS Code
1. 3921.12.50.00 & 3921.12.19.50 (Vinyl Chloride Polymer Films)
- Base Duty: 5.3% β 6.5%
- Surcharges: +25% (Sec 301) + 10% (122 Clause)
- Total Tax: 40.3% β 41.5%
- Note: These are standard PVC films. The high tariff makes them expensive for US importers.
2. 3920.49.00.00 & 3919.90.50.40 (Ethylene-based / Self-adhesive)
- Base Duty: 5.8%
- Surcharges: +25% (Sec 301) + 10% (122 Clause)
- Total Tax: 40.8%
- Note: Self-adhesive films (3919) and certain ethylene-based variants (3920) carry a slightly higher base duty than some other PVC films but follow the same surcharge logic.
3. 3920.43.50.00 (Polyvinyl Chloride Polymer Film)
- Base Duty: 4.2%
- Surcharges: +25% (Sec 301) + 10% (122 Clause)
- Total Tax: 39.2%
- Note: This is the lowest effective tax rate among the options, primarily due to the lower base duty of 4.2%.
π οΈ IV. Customs Clearance Practical Advice (Actionable Pitfall Avoidance)
β 1. Documentation Checklist (Non-Negotiable)
| Document | Required? | Details |
|---|---|---|
| Commercial Invoice | β | Must clearly state "PVC Resin Film Grade" and specify if it is Self-Adhesive or Non-Adhesive. |
| Product Specification Sheet | β | Must detail: - Polymer Type (Vinyl Chloride vs. Ethylene-based) - Thickness (mm/mil) - Width & Length - Plasticizer Content (if any, for REACH/RoHS compliance). |
| Certificate of Origin (CO) | β | Essential for proving origin. If from China, confirm eligibility for any potential exemptions (none available for these HS codes under current 301 rules). |
| Bill of Lading / Air Waybill | β | Ensure HS Codes are correctly listed on the shipping docs to match the customs entry. |
| Customs Bonds | β | Ensure continuous bond is active for commercial entry. |
β 2. Classification Strategy (Key Mnemonics)
π₯ "Adhesive is 3919, Non-Adhesive is 3920/21. Polymer Type Dictates Sub-Heading."
| Scenario | Correct Classification | Error Risk |
|---|---|---|
| Clear PVC rolls for packaging (no glue) | 3920.xxxx or 3921.xxxx | Misclassifying as 3919 leads to reclassification fees. |
| Vinyl rolls for stickers/signage (with glue) | 3919.90 | Misclassifying as 3920 may trigger different inspection protocols. |
| "Vinyl Chloride" specified in spec sheet | Look at 3921.12 or 3920.43 | Using generic "Plastic Film" leads to audit risk. |
| "Ethylene-based Vinyl" specified | Look at 3920.49 | This is a niche category; ensure chemical analysis matches. |
β 3. Cost Optimization & Compliance Tips
| Strategy | Recommendation |
|---|---|
| Tariff Engineering | If possible, verify if the product can be classified under 3920.43.50.00 (39.2% total tax) vs 3921.12.50.00 (41.5%). A 2.3% difference can be significant on large volumes. Ensure the chemical composition justifies the 3920.43 classification. |
| Section 301 Exclusions | Check if any specific PVC film products are currently eligible for Section 301 exclusions. Historically, some PVC films were excluded, but policies change. Assume 25% applies unless a valid exclusion letter is present. |
| 122 Clause Awareness | The "122 Clause" likely refers to a specific statutory provision or ruling that adds 10%. Ensure your broker understands this specific levy to avoid underpayment. |
| Anti-Dumping/Duty (AD/CVD) | While not explicitly listed in the tax detail, PVC products from China are frequently subject to AD/CVD. Check the USITC database for active AD/CVD cases on PVC film. If applicable, additional duties could be 50-100%+, drastically changing the total cost. |
π V. Global Market Comparison (2026 Context)
| Region | Recommended HS Code | Est. Duty Rate | Notes |
|---|---|---|---|
| πΊπΈ USA | See List Above | 39.2% β 41.5% | High tariffs due to Section 301 + 122 Clause. |
| π¨π³ China | 3920 / 3921 | 0% - 5% | Imports into China have lower barriers for raw PVC films. |
| πͺπΊ EU | 3920 / 3921 | 0% - 6.5% | Generally lower duties; no Section 301 equivalent. REACH compliance is key. |
| π²π½ Mexico | 3920 / 3921 | 0% - 5% | Under USMCA, if originating from USMCA region, duty may be 0%. |
π Conclusion for US Importers:
The US market is high-cost for Chinese PVC films. The ~40% effective duty rate makes sourcing from Vietnam, India, or Mexico (if eligible for preferential treatment) highly attractive for cost savings.
π VI. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Calling all PVC films "3920"
π Consequence: If it's self-adhesive, it must be 3919. Misclassification leads to customs holds.
β Mistake 2: Ignoring the "122 Clause"
π Consequence: Underpayment of duties by 10%. CBP will assess interest and penalties on the difference.
β Mistake 3: Assuming "Vinyl" means "Self-Adhesive"
π Consequence: "Vinyl" is a brand/common name for PVC. It can be non-adhesive (packaging) or adhesive (signage). Always check the spec sheet.
β Mistake 4: Failing to Verify AD/CVD Status
π Consequence: If your PVC film is subject to Anti-Dumping duties, the 25% is just the minimum. AD/CVD duties can exceed 100%, making the shipment unprofitable.
β Correct Action:
"PVC Film, Non-Adhesive, Vinyl Chloride Polymer, 0.05mm thick, for Packaging. HS: 3921.12.50.00."
π― VII. Conclusion: Precision in Classification, Profit in Procurement
π― Remember the Key Rules:
πΉ "Adhesive = 3919; Non-Adhesive = 3920/21"
πΉ "Base Duty + 25% (Sec 301) + 10% (122) = Total Cost"
πΉ "Check for AD/CVD β It Could Double Your Duty!"
π Pro Tip:
If you are importing large volumes (>10 containers), consider HS Code Pre-Rulings from CBP to lock in the classification. Also, investigate if Section 301 Exclusions are available for your specific PVC film type, as this could save you 25% on every shipment.
π£ Immediate Action Required:
π Verify AD/CVD Status for your specific PVC film product.
π Review Spec Sheets to confirm Polymer Type (Vinyl Chloride vs. Ethylene-based).
π Calculate Landed Cost including the ~40% duty to ensure margin viability.
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Your Margins Depend on the Details!
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.