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Polyethylene Packaging Roll Film

CN β†’ US
HS Code Tariff Rate Origin Destination Doc
3921905010 39.8% CN US Official Doc
3921190010 41.5% CN US Official Doc
3920100000 39.2% CN US Official Doc
3925900000 40.3% CN US Official Doc
3920632000 40.8% CN US Official Doc

AI Analysis

πŸ“¦ Polyethylene Packaging Roll Film (PE Roll Film)


🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
πŸ“Œ I. Product Definition & Classification: Do You Truly Understand "PE Roll Film"?

Polyethylene (PE) packaging roll film is a ubiquitous material in global logistics, retail, and industrial packaging. It is characterized by its flexibility, chemical resistance, and moisture barrier properties. In international trade, however, it is not a single HS Code. Misclassification is the #1 cause of customs delays and heavy penalties for this product.

International trade classifies PE film primarily based on its physical form (board/sheet vs. roll/film) and its primary application (industrial board vs. construction/building material).

⚠️ Critical Distinction Point:
- If the product is a rigid or semi-rigid board/sheet (even if supplied in rolls for cutting) β†’ Often falls under Chapter 3901/3920 (Plates, Sheets, Film, Foil, and Strip).
- If the product is a thin, flexible film specifically for packaging β†’ Falls under Chapter 3921 (Other Plates, Sheets, Film, Foil, and Strip) or 3920.
- If the product is specifically for construction/building (e.g., vapor barriers) β†’ Falls under Chapter 3925.

Key Note for this Analysis: Based on the provided <DATA>, we are analyzing PE films that are categorized as Board/Sheet or Plastic Building Products, often implying thicker gauges or specific industrial applications rather than simple thin grocery bags.


πŸ“¦ II. HS Code Classification Details (2026 Latest Tariff Authorityε―Ήη…§)

Based on the provided data, here are the relevant HS Codes for Polyethylene Packaging Roll Films, strictly adhering to the input constraints.

HS Code Product Summary Form/Shape Key Attribute
3921.90.50.10 Polyethylene boards/rolls, belonging to plastic board/sheet/strips Board/Roll Classified as "Plastic Board/Sheet"
3921.19.00.10 Polyethylene plastic films/sheets, shape is Board/Roll Board/Roll Specific PE film variant
3920.10.00.00 Vinyl polymer plates, sheets, membranes, foils, and strips Plate/Sheet/Film General polymer sheet classification
3925.90.00.00 Polycarbonate rolls, belonging to plastic building products Roll ⚠️ Note: Data lists "Polycarbonate" here, likely a data anomaly, but classified under "Building Products"
3920.63.20.00 Polycarbonate plates, sheets, membranes, foils, and strips Plate/Sheet ⚠️ Note: Data lists "Polycarbonate" here

πŸ” Important Observation from Data:
The provided <DATA> contains a mix of Polyethylene (PE) items (Codes 3921.90.50.10, 3921.19.00.10, 3920.10.00.00) and Polycarbonate (PC) items (Codes 3925.90.00.00, 3920.63.20.00).
Strictly adhering to your product "Polyethylene Packaging Roll Film", the relevant codes are 3921.90.50.10, 3921.19.00.10, and 3920.10.00.00. The Polycarbonate codes are likely data noise or for mixed shipments, but I will include them in the tax breakdown as they are in the source, with a clear disclaimer.


πŸ’° III. 2026 Latest Tariff Rate Details (Including Additional Taxes & Policy Surcharges)

βœ… Applicable Country: United States (US)
βœ… Origin: China (CN)
βœ… Effective Time: 2025/2026 (Current Trade Environment)

🎯 1. 3921.90.50.10 β€”β€” Polyethylene Boards/Rolls (Plastic Board/Sheet)

Item Content
Base Tariff 4.8%
Section 301 Surcharge +25.0%
Section 122 Surcharge +10.0%
Total Tax Rate 39.8%
Tax Calculation CIF Value Γ— 39.8%
De Minimis Exemption? ❌ No (High-value industrial goods)
Legal Basis Path Base:3921.90 β†’ Sec301:25% β†’ Sec122:10%

πŸ“Œ Explanation:
- This code treats the PE roll as a "Board/Sheet," implying a certain thickness or rigidity.
- The 39.8% total rate is punitive, combining the base rate with two significant US trade sanctions.


🎯 2. 3921.19.00.10 β€”β€” Polyethylene Plastic Films/Sheets (Board/Roll Shape)

Item Content
Base Tariff 6.5%
Section 301 Surcharge +25.0%
Section 122 Surcharge +10.0%
Total Tax Rate 41.5%
Tax Calculation CIF Value Γ— 41.5%
De Minimis Exemption? ❌ No
Legal Basis Path Base:3921.19 β†’ Sec301:25% β†’ Sec122:10%

πŸ“Œ Note:
- Slightly higher base tariff (6.5%) than the previous code, leading to a higher total tax.
- Use this if the product is explicitly described as "Film/Sheet" rather than generic "Board."


🎯 3. 3920.10.00.00 β€”β€” Vinyl Polymer Plates/Sheets/Membranes/Foils/Strips

Item Content
Base Tariff 4.2%
Section 301 Surcharge +25.0%
Section 122 Surcharge +10.0%
Total Tax Rate 39.2%
Tax Calculation CIF Value Γ— 39.2%
De Minimis Exemption? ❌ No
Legal Basis Path Base:3920.10 β†’ Sec301:25% β†’ Sec122:10%

πŸ“Œ Strategy:
- This code often offers the lowest base rate (4.2%) among the PE options, resulting in the lowest total tax (39.2%).
- However, "Vinyl Polymer" is a broad category. Ensure your product fits the technical definition of this subheading to avoid misclassification penalties.


⚠️ 4. 3925.90.00.00 & 3920.63.20.00 β€”β€” Data Anomaly Alert: Polycarbonate Items

Item Content
HS Code 3925.90.00.00 (Polycarbonate Building Rolls)
Total Tax Rate 40.3%
HS Code 3920.63.20.00 (Polycarbonate Sheets)
Total Tax Rate 40.8%

🚨 CRITICAL WARNING:
The input data lists Polycarbonate (PC) for these codes, but your product is Polyethylene (PE).
- Do NOT use 3925.90.00.00 or 3920.63.20.00 for PE film.
- Misdeclaring PE as PC can lead to false declaration penalties, seizure of goods, and blacklisting.
- If your shipment contains both PE and PC, you MUST split the declaration. Do not mix them under one HS code.


πŸ› οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)

βœ… 1. Document Preparation Checklist (Non-Negotiable)

Document Must Provide Explanation
βœ… Product Specification Sheet βœ”οΈ Must specify: Material (100% Polyethylene), Density (HDPE/LDPE/LLDPE), Thickness (mm/mil), Width, Length, Color.
βœ… Commercial Invoice βœ”οΈ Clearly state "Polyethylene Roll Film" NOT just "Plastic Film." Avoid vague terms like "Packaging Material."
βœ… Packing List βœ”οΈ Detail net/gross weight per roll. Rolls must be packed to prevent crushing.
βœ… Material Safety Data Sheet (MSDS) βœ”οΈ Even if non-hazardous, some carriers/customs require it for polymer goods.
βœ… Certificate of Origin (CO) βœ”οΈ Essential for determining preferential rates (though US-China rates are currently high).

βœ… 2. Declaration Tips (Key Mantra)

πŸ”₯ β€œMaterial First, Form Second, Thickness Matters!”

Scenario Correct Declaration Wrong Action
Thick PE Roll (>1mm) Classify as Board/Sheet (3921.90 or 3920.10) Declare as "Bag" or "Film" β†’ Wrong Chapter
Thin PE Film (<1mm) Declare as Film (3921.19) Declare as "Board" β†’ Risk of reclassification
Mixed PE/PC Shipment Split Declaration Merge into one line item β†’ Seizure Risk
Rolls with Core Include core in weight/HS Exclude core β†’ Discrepancy in weight declaration

βœ… 3. Special Case Handling

Situation Handling Advice
OEM Custom Printed PE Film Provide the printing design file or proof. Ensure the ink is also listed.
Antibacterial PE Film Must provide efficacy test reports. If not certified, do not claim "Antibacterial" in the name.
Biodegradable PE Blend Extreme Caution: If it contains PLA/淀粉, it may fall under a different HS code entirely. Pure PE does not biodegrade. Mislabeling leads to FDA/Customs violations.
Small Samples (<600g) Still subject to duties if declared as commercial samples, but may avoid certain formal entry requirements. However, with 39.8% tax, savings are minimal.

🌍 V. Global Market Comparison (2026 Update)

Country/Region Recommended HS Code Estimated Tariff (China Origin) Notes
πŸ‡ΊπŸ‡Έ USA 3921.90.50.10 / 3920.10.00.00 39.2% - 41.5% Includes 301 & 122 surcharges. High barrier.
πŸ‡¨πŸ‡³ China 3921.90 / 3920.10 5% - 6% Low base tariff. No extra surcharges.
πŸ‡ͺπŸ‡Ί EU 3920.10 / 3921.19 0% - 4.5% Generally low tariffs. No 301/122 equivalents.
πŸ‡―πŸ‡΅ Japan 3920.10 / 3921.19 3% - 5% Stable, low tariffs.

πŸ“Œ Conclusion:
- USA is the most expensive market for PE film imports due to aggressive trade policies.
- Diversification Strategy: Consider sourcing or assembling in Vietnam/Mexico to avoid Section 301/122 tariffs if targeting the US market.


πŸ“Œ VI. Common Errors & Pitfall Guide (Blood & Tears Lessons)

❌ Error 1: Declaring "PE Film" under 3921.19 when it is actually a rigid PE Sheet.
πŸ‘‰ Consequence: Customs reclassifies to 3921.90 or 3920.10. While rates are similar, the penalty for misdeclaration can be 2-3x the tax value.

❌ Error 2: Mixing Polycarbonate (PC) and Polyethylene (PE) in one line item.
πŸ‘‰ Consequence: The HS code does not match the material. Customs will flag the shipment, delay inspection, and potentially impose fraud penalties.

❌ Error 3: Ignoring the Section 122 Tariff (10%).
πŸ‘‰ Consequence: Many importers forget this additional surcharge. The total cost becomes underestimated by 10%, wiping out profit margins.

❌ Error 4: Using "Rolls" in the name but declaring as "Sheets."
πŸ‘‰ Consequence: If the physical product is a roll, but the HS code requires sheets, customs may argue the goods are incomplete. Be precise about form.

βœ… Correct Action:

"Polyethylene Roll Film, LDPE, 0.5mm thick, Width 1200mm, for Industrial Packaging, No Additives, HS Code: 3921.19.00.10"


🎯 VII. Conclusion: Precision in Classification Saves Millions!

🎯 Remember the Mantra:

πŸ”Ή β€œPE Film: Check Thickness, Check Material, Check Surcharge!”
πŸ”Ή β€œ39.8% is the Minimum for PE, 41.5% for Specific Film, 40.3% for PC (Don’t Mix!)”
πŸ”Ή β€œSplit PC and PE, Avoid Fraud, Keep Your Clearance Smooth!”


πŸ“Œ Pro Tip:
If your PE film is exclusively for food contact, ensure you have FDA compliance documents ready. While this doesn’t change the HS Code, it changes the customs hold time. Food-grade products are scrutinized more heavily.


πŸ“£ Immediate Action:

πŸ“ž Contact your freight forwarder with the exact thickness, density (HDPE/LDPE), and width of your rolls.
πŸš€ Apply for a Binding Ruling if shipping large volumes to the US, to lock in the HS Code and avoid future disputes.
πŸ’Ό Your Profit Margin Depends on Accurate Classification!


✨ Professional Clearance Starts with Accurate Classification!
πŸ’Ό Every Percent of Tariff 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) 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.