Transparent Soft Film Backing Label Bag
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3923210011 | 38.0% | CN | US | Official Doc |
| 3923210030 | 38.0% | CN | US | Official Doc |
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AI Analysis
π·οΈ Transparent Soft Film Backing Label Bag (Reclosable Poly Bags)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Know What "Label Bag" Really Is?
A "Transparent Soft Film Backing Label Bag" is typically a plastic sack or bag used for packaging small items, documents, or labels. In international trade, its classification depends heavily on the material composition and structural features.
Based on the provided data, these products fall under Chapter 39 (Plastics and Articles Thereof), specifically Heading 3923 (Articles for the conveyance or packing of goods, of plastics).
Key Classification Points: 1. Material: Made of polymers of ethylene (PE). 2. Type: Reclosable, with an integral extruded closure (zipper-style or heat-sealable extruded seam). 3. Size Constraint: The classification differs based on whether any single side exceeds 75 mm in length.
β οΈ Critical Distinction:
- If the bag is reclosable with an integral extruded closure AND no single side exceeds 75 mm in length β HS Code: 3923.21.00.11
- If the bag is reclosable with an integral extruded closure BUT one or more sides exceed 75 mm in length β HS Code: 3923.21.00.30
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Applicable Scenario | Closure Type | Size Limit |
|---|---|---|---|---|
3923.21.00.11 |
Sacks and bags of polymers of ethylene; Reclosable, with integral extruded closure; With no single side exceeding 75 mm in length | Small label bags, jewelry bags, small accessory packs | β Reclosable (Extruded) | β Max 75mm side |
3923.21.00.30 |
Sacks and bags of polymers of ethylene; Reclosable, with integral extruded closure; Other | Larger poly bags, ziplock storage bags, standard mailing poly bags | β Reclosable (Extruded) | β Any side > 75mm |
π Key Reminder:
- Material Matters: These codes apply only to bags made of polymers of ethylene (PE). If made of PP (Polypropylene), PVC, or other plastics, different codes apply.
- Closure Type: The term "integral extruded closure" refers to a zipper or seal formed during the extrusion process (common in "Ziploc-style" bags). It does not include bags with separate metal zippers or adhesive tapes unless specified.
- Size is King: The 75 mm threshold is the only difference between the two codes. Measure the longest side of the bag. If itβs β€75mm, itβs.11. If any side is >75mm, itβs.30.
π° III. 2026 Latest Tariff Rate Breakdown (Including Additional Taxes, Policy Surcharges)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: Current as of 2026
π― 1. 3923.21.00.11 ββ Small Reclosable PE Bags (β€75mm Side)
| Item | Content |
|---|---|
| Base Tariff Rate | 3.0% (Ad Valorem) |
| Section 301 Additional Tariff | 25.0% |
| Total Tax Rate | 28.0% |
| Tax Calculation | CIF Value Γ 28% |
| De Minimis Exemption? | β NO (Not eligible for $800 de minimis exemption if additional tariffs apply to origin country; verify current CBP enforcement on Section 301 goods) |
| Legal Basis Path | HTSUS:3923.21.00.11 β Section 301 Footnote 1 |
π Explanation:
- Base Tariff 3.0%: Standard MFN rate for plastic sacks/bags.
- Section 301 Tariff 25.0%: High additional duty imposed on Chinese-made plastic packaging articles under US Trade Act Section 301.
- Total 28%: This is a high cost for low-value plastic goods. Must be factored into landed cost calculations.
π― 2. 3923.21.00.30 ββ Large Reclosable PE Bags (>75mm Side)
| Item | Content |
|---|---|
| Base Tariff Rate | 3.0% (Ad Valorem) |
| Section 301 Additional Tariff | 25.0% |
| Total Tax Rate | 28.0% |
| Tax Calculation | CIF Value Γ 28% |
| De Minimis Exemption? | β NO |
| Legal Basis Path | HTSUS:3923.21.00.30 β Section 301 Footnote 1 |
π Note:
- Same tariff structure as.11.
- Even if the bag is larger, the tariff rate remains identical (28%).
- The only difference is customs data reporting and market segmentation (small vs. large bags).
π οΈ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Avoidance)
β 1. Document Checklist (Must-Haves)
| Document | Mandatory | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must state: Material (100% PE), Closure Type (Extruded Zipper), Dimensions (L x W x H) |
| β Technical Drawing | βοΈ | Highlight the extruded closure mechanism. Proves itβs not a separate zipper. |
| β Product Photos | βοΈ | Show the bag empty and filled. Clearly display the closure seal. |
| β Commercial Invoice | βοΈ | Describe as: "Reclosable Polyethylene Bags, Size X, for Label Packaging" |
| β Packing List | βοΈ | Ensure quantity and weight match invoice. |
| β Country of Origin Certificate | βοΈ | Required for Section 301 determination. |
β 2. Declaration Tips (Key Mnemonics)
π₯ βMeasure the Side, Check the Seal, State the Material, Avoid the Trap!β
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Bag side β€ 75mm | 3923.21.00.11 + "PE Reclosable Bag, Max Side 75mm" |
Misclassifying as .30 β No tax difference, but inaccurate data |
| Bag side > 75mm | 3923.21.00.30 + "PE Reclosable Bag, Side >75mm" |
Misclassifying as .11 β Customs may question size |
| Non-PE Material | Different HS Code (e.g., PP, PVC) | Claiming PE β Severe penalty for misdeclaration |
| Non-Reclosable Bag | Different HS Code (e.g., 3923.29) | Claiming Reclosable β Tariff audit risk |
β 3. Special Cases Handling
| Scenario | Handling Advice |
|---|---|
| Mixed Sizes in One Shipment | Declare based on the dominant item or separate lines for each HS Code. Do not average. |
| Biaxially Oriented PE (BOPP) Bags | These are NOT "polymers of ethylene" in the simple sense; they may fall under 3920.62 or 3923.29. Verify material composition. |
| Bags with Printing/Branding | Still classified as 3923.21. Printing does not change the HS Code, but must be declared as "Printed Poly Bag". |
| Biodegradable PE Bags | If certified biodegradable, may still be 3923.21. Provide certification if claiming environmental benefits for other markets (not US tariff). |
π V. Global Market Customs Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3923.21.00.11 / .30 |
28% | No specific cert required | High Section 301 tax |
| π¨π³ China | 3923.21.00.11 / .30 |
~5-7% | No special cert | Low import duty |
| πͺπΊ EU | 3923.21 |
6.5% | No special cert | Standard NMF rate |
| π¬π§ UK | 3923.21 |
6.5% | No special cert | Post-Brexit tariff |
| π―π΅ Japan | 3923.21 |
6% | No special cert | Low duty |
π Conclusion:
- USA is the highest-cost market due to the 28% total tariff (3% base + 25% Section 301).
- European and Asian markets offer significantly lower duty rates (~5-7%).
- Strategy: If exporting to the US, consider supplier diversification (e.g., from Vietnam, Thailand) to avoid Section 301 tariffs, if feasible.
π VI. Common Mistakes & Pitfall Guide (Lessons Learned)
β Mistake 1: Declaring "Label Bags" without specifying material or closure type.
π Consequence: Customs may downgrade to a higher-tariff general plastic bag category or demand extra documentation, causing delays.
β Mistake 2: Measuring the area instead of the side length for the 75mm rule.
π Consequence: Misclassification. The rule is strictly about the maximum linear dimension of any single side, not surface area.
β Mistake 3: Assuming all "plastic bags" are the same HS Code.
π Consequence: If made of PVC or PP, 3923.21 is incorrect. PVC bags fall under 3923.29 or similar, with different tariffs.
β Correct Declaration Example:
"Plastic Reclosable Bags, 100% Low-Density Polyethylene (LDPE), Zip Closure, Size 4x6 inches, Clear, 100% Biodegradable (Optional), Model XYZ"
π― VII. Conclusion: Professional Declaration, Save Money, Avoid Delays!
π― Remember the Mantra:
πΉ "PE Material? Extruded Zipper? Check the 75mm Line!"
πΉ "US Tariff 28%, No De Minimis, Think Twice Before You Ship!"
πΉ "Accuracy Saves Dollars, Mistakes Cost Delays!"
π Pro Tip:
- If your bags are small (<75mm), declare as .11.
- If large (>75mm), declare as .30.
- Always specify "Polymers of Ethylene" and "Reclosable with Integral Extruded Closure" in the description.
- For US imports, factor in 28% landed cost. Consider duty drawback or free trade agreements if applicable (e.g., USMCA if re-exported from Canada/Mexico with qualifying origin).
π£ Immediate Action:
π Contact your freight forwarder + Provide dimensional specs + Apply for Pre-Ruling (CBP Ruling Letter) if unsure about size/material.
π Clear Customs Smoothly, Reduce Costs, Maximize Profit!
β¨ Professional Clearance Starts with Precise Classification!
πΌ Every Dollar Saved in Tariffs 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.