Roll Packaging Material for Food
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3923290000 | 38.0% | CN | US | Official Doc |
| 4819300040 | 35.0% | CN | US | Official Doc |
| 4819400040 | 35.0% | CN | US | Official Doc |
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AI Analysis
π¦ Roll Packaging Material for Food
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Entry Strategy
π I. Product Definition & Classification: Do You Really Understand "Roll Packaging Material"?
"Roll Packaging Material for Food" is a broad term in international trade, typically referring to flexible packaging used for wrapping, sealing, or containing food products. The classification depends heavily on the material composition and form.
Based on common industry standards, these materials are usually classified into two main categories: 1. Plastic-based Flexible Packaging: Plastic films, bags, or rolls used for food preservation. 2. Paper/Cellulose-based Flexible Packaging: Paper rolls, kraft paper, or cellulose films used for wrapping or lining.
β οΈ Critical Distinction Point:
- If the material is plastic (e.g., PE, PP, PET films) without specific structural features like valves or spouts, it generally falls under HS 3923.
- If the material is paper or paperboard (even if coated), in the form of rolls or folded bags, it generally falls under HS 4819.
- Misclassification Risk: Declaring paper as plastic (or vice versa) triggers customs inspections, delays, and potential penalties due to differing tariff rates.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Material Type |
|---|---|---|---|
3923.29.00.00 |
Sacks and bags (including cones), for the conveyance or packaging of goods | Flexible plastic films, shrink wrap, food storage rolls | β Plastic |
4819.30.00.40 |
Boxes, bags, and wrappers, of paper, paperboard, cellulose wadding or webs of cellulose fiber | Paper rolls, coated paper packaging, food-grade paper wraps | β Paper/Cellulose |
4819.40.00.40 |
Other sacks and bags, including cones, of paper or paperboard | Rolled paper packaging, other paper bags not specified elsewhere | β Paper/Cellulose |
π Key Reminder:
- Plastic Packaging: Must be declared as plastic-based. Even if transparent, if itβs not glass or ceramic, itβs likely plastic.
- Paper Packaging: Includes paper that may have plastic coatings or laminates, but the base material is paper.
- "Roll" Form: Both plastic films and paper rolls can fall under these codes if they are flexible packaging items.
π° III. 2026 Latest Tariff Rate Details (Including Surcharges, Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: From November 10, 2025 (including subsequent imports)
π― 1. 3923.29.00.00 ββ Plastic Packaging Material (Sacks, Bags, Cones)
| Item | Content |
|---|---|
| Base Tariff Rate | 3.0% (ad valorem) |
| USITC Additional Tariff | +25% (under Section 301, USITC Footnote) |
| IEEPA Additional Tariff | +10% (Targeting Chinese/HK products, effective Nov 10, 2025) |
| Total Tariff Rate | 38.0% |
| Tax Calculation | CIF Value Γ 38.0% |
| De Minimis Exemption Eligible? | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3923.29.00.00 |
π Explanation:
- 3.0% Base: Standard MFN rate for plastic packaging articles.
- 25% Section 301 Tariff: Applies to specific plastic products from China.
- 10% IEEPA Tariff: New additional levy on Chinese goods.
- Total 38%: This is a high-cost category. Importers must factor this into their pricing strategy.
π― 2. 4819.30.00.40 ββ Paper Packaging Material (Rolls/Wrappers)
| Item | Content |
|---|---|
| Base Tariff Rate | 0.0% (ad valorem) |
| USITC Additional Tariff | +25% (Under Section 301, USITC Footnote) |
| IEEPA Additional Tariff | +10% (Targeting Chinese/HK products, effective Nov 10, 2025) |
| Total Tariff Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35.0% |
| De Minimis Exemption Eligible? | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:4819.30.00.40 |
π Explanation:
- 0% Base: Paper packaging often enjoys lower base tariffs.
- 35% Total: Still a significant burden due to the 25% + 10% surcharges.
- Why 35% vs 38%? The 3% difference comes from the 3% base tariff on plastic vs. 0% on paper.
π― 3. 4819.40.00.40 ββ Other Paper Sacks/Bags (Rolls)
| Item | Content |
|---|---|
| Base Tariff Rate | 0.0% (ad valorem) |
| USITC Additional Tariff | +25% (Under Section 301, USITC Footnote) |
| IEEPA Additional Tariff | +10% (Targeting Chinese/HK products, effective Nov 10, 2025) |
| Total Tariff Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35.0% |
| De Minimis Exemption Eligible? | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:4819.40.00.40 |
π Explanation:
- Similar to4819.30.00.40, this is a catch-all for other paper packaging.
- Key Point: Even if the paper is food-grade or coated, the base material determines the HS code, not the usage (food).
π οΈ IV. Customs Clearance Practical Advice (Expert Pitfall Avoidance Guide)
β 1. Preparation Checklist (All documents required)
| Document | Mandatory | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must specify material (e.g., "Polyethylene Film" vs. "Kraft Paper"), thickness, width, length. |
| β Material Safety Data Sheet (MSDS) | βοΈ | For plastic packaging, confirm no prohibited substances. |
| β Food Contact Compliance Certificate | βοΈ | FDA or equivalent certification proving the material is safe for direct/indirect food contact. |
| β Commercial Invoice | βοΈ | Must clearly state: "Roll Packaging Material for Food, Made of [Plastic/Paper]". |
| β Packing List | βοΈ | Show roll dimensions, core size, and packaging type. |
| β Certificate of Origin (CO) | βοΈ | Essential for verifying Chinese origin and applying surcharges. |
β 2. Declaration Tips (Key Mantras)
π₯ "Material First, Form Second. Plastic or Paper? Know Your Base!"
| Scenario | Correct Declaration | Wrong Action |
|---|---|---|
| Plastic Roll Film | HS 3923.29.00.00 |
Misdeclare as paper β 35% (But if caught, penalty for false declaration) |
| Paper Roll Wrap | HS 4819.30.00.40 or 4819.40.00.40 |
Misdeclare as plastic β 38% (Overpaying, but less risky than under-declaring material) |
| Laminated Packaging (Paper + Plastic) | Primary Material Rule | Usually classified by the outermost or principal material. If paper is dominant, use 4819. If plastic is dominant, use 3923. |
| Rolls vs. Cut Bags | Rolls | If cut into bags, still flexible packaging, but check if it fits "bags" vs "rolls" definitions. HS codes above cover both. |
β 3. Special Case Handling
| Case | Handling Advice |
|---|---|
| Laminated Materials | Provide layer-by-layer composition. Customs will determine the principal material. |
| Food-Grade Coating | The coating does not change the base material classification. A plastic film coated with wax is still plastic (3923). |
| Customs Inspection Trigger | If unsure, provide photos of the material cross-section or a sample. |
| IEEPA Exemption | β No Exemption for plastic or paper packaging from China under current policies. |
π V. Global Major Market Customs Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification Requirements | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3923.29.00.00 / 4819.30.00.40 |
35% - 38% | FDA + RoHS (if applicable) | High surcharges. De Minimis not available. |
| π¨π³ China | 3923.29.00.00 / 4819.30.00.40 |
0% - 5% | GB Standards | Low tariffs. No extra surcharges. |
| πͺπΊ EU | 3923.29.00.00 / 4819.30.00.40 |
0% - 4% | CE + LFGB (Food Contact) | No Section 301/IEEPA equivalents. |
| π¬π§ UK | 3923.29.00.00 / 4819.30.00.40 |
0% - 4% | UKCA + Food Standards Agency | Post-Brexit rules apply. |
π Conclusion:
- USA is the most expensive market due to 35-38% total tariffs.
- EU/UK offer significant cost advantages if you can source or manufacture outside China.
- Food Compliance is the non-negotiable barrier in all markets.
π VI. Common Errors & Pitfall Guide (Lessons Learned)
β Error 1: Declaring "Plastic" as "Paper" to avoid 38% tariff
π Consequence: Customs inspection reveals plastic. Seizure, fines, and blacklisting.
β Error 2: Not specifying "Food Contact" in description
π Consequence: FDA may hold shipment for testing if intended for food, even if HS code is correct.
β Error 3: Ignoring Lamination Composition
π Consequence: Incorrect HS code assignment. If the primary material is misidentified, the entire shipment is at risk.
β Error 4: Assuming "Rolls" automatically qualify for De Minimis
π Consequence: β De Minimis is denied for Chinese-origin goods under IEEPA and Section 301.
β Correct Approach:
"Food Grade Plastic Roll Packaging Material, Polyethylene, 0.05mm Thickness, Width 50cm, Length 1000m, FDA Compliant"
OR
"Food Grade Paper Roll Packaging, Kraft Paper, Coated, 100mic, Width 60cm"
π― VII. Conclusion: Precision Classification, Cost Efficiency, Risk Mitigation
π― Remember the Mantra:
πΉ "Plastic is 38%, Paper is 35%. Base material dictates fate!"
πΉ "Food grade certs are mandatory, no exceptions!"
πΉ "No De Minimis for China. Plan your supply chain accordingly."
π Pro Tip:
If your packaging is laminated, prioritize the primary structural layer. If itβs unclear, request a Pre-Ruling from US Customs (CBP) before shipping. This can save thousands in potential duties and delays.
π£ Immediate Action:
π Contact your customs broker with the material composition sheet.
π Verify FDA compliance documents for each batch.
πΌ Calculate landed cost including the 35-38% tariff to ensure profitability.
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every percentage point in tariff mattersβoptimize your HS Code strategy!
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.