Photo Album with Protective Film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 4823906700 | 35.0% | CN | US | Official Doc |
| 3921905050 | 39.8% | CN | US | Official Doc |
| 3919102055 | 40.8% | CN | US | Official Doc |
| 3921904090 | 39.2% | CN | US | Official Doc |
AI Analysis
πΈ Photo Album with Protective Film (Surface Protective Film for Photos)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: What Exactly Is This Product?
"Photo Album with Protective Film" in this context refers specifically to the surface protective film applied to photos or photo materials. It is not the album itself (which would be paper/plastic goods), but the functional film layer.
In international trade, this product is classified based on its material composition and form: 1. Paper-Based Protective Film: Coated paper or paperboard products used for functional protection. 2. Plastic-Based Protective Film: Plastic films, which are furtherη»ε by form (flat self-adhesive, other sheets/plates) and use.
β οΈ Critical Distinction:
- If the product is a finished photo album book (containing pages and binding) β It belongs to Chapter 49 (Books/Newspapers/Photographic Albums).
- If the product is only the protective film/sheet intended for surface coating β It belongs to Chapter 48 (Paper) or Chapter 39 (Plastics).
The following analysis strictly covers the "Protective Film" aspect as per the provided data.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Material/Form | Application | Total Tax Rate (US Import from CN) |
|---|---|---|---|---|
4823.90.67.00 |
Photo Surface Protective Film, Paper-Based | Coated paper or paperboard product, functional film | Functional paper-based protection | 35.0% |
3921.90.50.50 |
Photo Surface Protective Film, Plastic Film | Plastic film, other category of plastic products | General plastic protective film | 39.8% |
3919.10.20.55 |
Photo Surface Protective Film, Plastic | Flat plastic film, self-adhesive/protective use | Self-adhesive plastic protection | 40.8% |
3921.90.40.90 |
Photo Surface Protective Film, Plastic/Film | Film/sheet/strip, other category | General plastic film/sheet | 39.2% |
π Key Reminder:
- Paper vs. Plastic: The most critical split is between4823(Paper) and39xx(Plastic). Paper-based films have a lower base tariff (0%) compared to plastics (4.2%-5.8%), but the final total rate varies due to the specific sub-categories andιε η¨. - Self-Adhesive vs. Non-Adhesive:3919is specifically for self-adhesive plastic films. If the film is not self-adhesive (e.g., static cling or tape-applied separately), it may fall under3921(Other plates, sheets, film, foil and strip, of plastics).
π° III. 2026 Latest Tariff Rate Breakdown (Including Additional Duties & Policy Surcharges)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: November 10, 2025 onwards (for subsequent imports)
π― 1. 4823.90.67.00 ββ Photo Surface Protective Film (Paper-Based)
| Item | Detail |
|---|---|
| Base Tariff | 0.0% (Ad Valorem) |
| Section 301 Tariff | +25.0% (Additional Tariff under US Trade Law Section 301) |
| Section 122 Tariff | +10.0% (Specific additional duty) |
| Total Tax Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35.0% |
| De Minimis Exemption | β Not Eligible (Deny De Minimis) |
| Legal Basis Path | Base: 0% β Section 301: +25% β Section 122: +10% |
π Explanation:
- Base Tariff 0%: Paper products often have low or zero base tariffs. - Section 301 (25%): Standard additional tariff on Chinese goods in this category. - Section 122 (10%): A specific additional duty applicable to this subheading. - Total 35%: Significantly lower than plastic-based alternatives, making paper-based protective films more cost-effective for US import.
π― 2. 3921.90.50.50 ββ Photo Surface Protective Film (Plastic - Other Category)
| Item | Detail |
|---|---|
| Base Tariff | 4.8% |
| Section 301 Tariff | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 39.8% |
| Tax Calculation | CIF Value Γ 39.8% |
| De Minimis Exemption | β Not Eligible |
| Legal Basis Path | Base: 4.8% β Section 301: +25% β Section 122: +10% |
π Note:
- This code applies to plastic films that do not fit into the self-adhesive3919category or other specific plastic film categories. - The base tariff is higher (4.8% vs 0% for paper), leading to a higher total rate.
π― 3. 3919.10.20.55 ββ Photo Surface Protective Film (Plastic - Self-Adhesive)
| Item | Detail |
|---|---|
| Base Tariff | 5.8% |
| Section 301 Tariff | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 40.8% |
| Tax Calculation | CIF Value Γ 40.8% |
| De Minimis Exemption | β Not Eligible |
| Legal Basis Path | Base: 5.8% β Section 301: +25% β Section 122: +10% |
π Note:
- This is the highest tax rate among the four options. - Applies specifically to flat plastic films, self-adhesive, used for protection. - Even if "self-adhesive," the higher base tariff (5.8%) makes it less competitive than non-self-adhesive plastic films (3921.90.50.50at 39.8%).
π― 4. 3921.90.40.90 ββ Photo Surface Protective Film (Plastic - Film/Sheet/Strip)
| Item | Detail |
|---|---|
| Base Tariff | 4.2% |
| Section 301 Tariff | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 39.2% |
| Tax Calculation | CIF Value Γ 39.2% |
| De Minimis Exemption | β Not Eligible |
| Legal Basis Path | Base: 4.2% β Section 301: +25% β Section 122: +10% |
π Note:
- This code is for plastic films/sheets not classified elsewhere (e.g., not self-adhesive under 3919, not specific plastic articles under 3926). - It has the lowest base tariff among plastic categories (4.2%), resulting in a total rate of 39.2%, which is lower than the self-adhesive plastic option (3919).
π οΈ IV. Customs Clearance Practical Advice (Pitfall Avoidance Guide)
β 1. Preparation Checklist (All Required)
| Document | Required | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must specify material (Paper vs. Plastic), form (Self-adhesive vs. Non-adhesive), and thickness. |
| β Product Photos | βοΈ | Clear images of the film, showing texture, packaging, and any adhesive side. |
| β Commercial Invoice | βοΈ | Must clearly state "Photo Surface Protective Film" and not "Photo Album" (to avoid Chapter 49 classification errors). |
| β Packing List | βοΈ | Detail weight, dimensions, and quantity. |
| β Origin Certificate (if applicable) | βοΈ | For origin verification. |
| β Test Reports (if applicable) | βοΈ | If claiming special environmental certifications. |
β 2. Declaration Techniques (Key Mnemonic)
π₯ "Material First, Form Second, Name Accurate, Tax Lower!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Paper-based protective film | 4823.90.67.00 |
Misdeclare as plastic β 35% vs 39.2%+ |
| Plastic, Self-Adhesive | 3919.10.20.55 |
Misdeclare as non-adhesive β 40.8% vs 39.2% |
| Plastic, Non-Adhesive (Other) | 3921.90.40.90 or 3921.90.50.50 |
Misdeclare as self-adhesive β Higher tax |
| Finished Photo Album | Chapter 49 (e.g., 4903.00) | Misdeclare as "Film" β Severe penalty |
β 3. Special Cases
| Scenario | Handling Advice |
|---|---|
| Mixed Materials | If the film has a plastic backing with a paper coating, consult customs for classification. Usually, the essential character determines the chapter. |
| Customs Labeling | Clearly label as "Protective Film for Photos" to avoid confusion with "Photo Paper" (which may have different HS codes). |
| Section 301 Exclusions | Check if the specific HS code was eligible for Section 301 exclusions in 2025-2026. As of 2026, most are reinstated. |
| De Minimis (800 USD) | β Do not rely on de minimis. All these codes are explicitly not eligible for de minimis clearance. Full formal entry is required. |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 4823.90.67.00 (Paper) |
35.0% | No special cert | Lowest total tax among options. |
| πΊπΈ USA | 3921.90.40.90 (Plastic) |
39.2% | No special cert | Higher than paper. |
| πΊπΈ USA | 3919.10.20.55 (Plastic SA) |
40.8% | No special cert | Highest tax rate. |
| πͺπΊ EU | See local classification | Varies | CE, REACH | No Section 301/122. |
| π¨π³ China | See local classification | 0%-5% | None | Export to China not applicable here. |
π Conclusion:
- USA is the primary market with high additional tariffs. - Paper-based films (4823.90.67.00) are the most tax-efficient option for US import, with a total rate of 35%. - If plastic is unavoidable, non-self-adhesive films (3921.90.40.90) are cheaper than self-adhesive ones (3919.10.20.55).
π VI. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Declaring as "Photo Album" (Chapter 49)
π Consequence: Wrong HS Code, potential penalty, or delay.
Correct: Declare as "Protective Film" (Chapter 48/39).
β Mistake 2: Assuming "De Minimis" applies (Under $800)
π Consequence: Shipment held, fined, or forced to file formal entry.
Correct: All listed codes are not eligible for de minimis.
β Mistake 3: Confusing Self-Adhesive vs. Non-Adhesive
π Consequence: Overpayment of tax (40.8% vs 39.2%).
Correct: Verify if the film has an adhesive layer. If yes, use 3919. If no, use 3921.
β Correct Declaration Example:
"Surface Protective Film for Photos, Made of Coated Paper, Functional Protective Layer, Not Self-Adhesive, Model: PF-100"
π― VII. Conclusion: Smart Classification, Cost Saving!
π― Remember the Mnemonic:
πΉ "Paper is King (35%), Plastic is High (39-40%), Self-Adhesive is Highest (40.8%)."
πΉ "No De Minimis for Films, Formal Entry Required."
π Pro Tip:
If you are importing plastic films, consider if a paper-based alternative (4823.90.67.00) is technically feasible. The 5.8% tax savings (35% vs 40.8%) is significant for high-volume shipments.
π£ Immediate Action:
π Consult your customs broker to confirm the material composition (Paper vs. Plastic) and adhesive type (Self-adhesive vs. Non-adhesive).
π Accurate classification saves money and time!
β¨ Professional Clearance Starts with Precise Classification!
πΌ Every cent counts in cross-border trade!
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.