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Unreinforced Polyamide Plastic Film

CN β†’ US
HS Code Tariff Rate Origin Destination Doc
3920992000 39.2% CN US Official Doc
3920991000 41.0% CN US Official Doc
3908100000 41.3% CN US Official Doc
3908907000 41.5% CN US Official Doc
3920920000 39.2% CN US Official Doc

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AI Analysis

🎞️ Unreinforced Polyamide Plastic Film (PA Film)


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

Unreinforced Polyamide Plastic Film (commonly known as Nylon Film or PA Film) is a high-performance packaging material characterized by excellent barrier properties (oxygen, aroma), high tensile strength, and abrasion resistance. In international trade, it is primarily classified under Chapter 39 (Plastics and Articles Thereof).

The classification hinges on two key factors: 1. Material Composition: Is it pure Polyamide (PA) or a generic "Other Plastic"? 2. Processing State: Is it in primary forms or specifically as "films/flat sheets"?

⚠️ Critical Distinction:
- If the material is explicitly Polyamide (Nylon) β†’ It falls under Heading 3908 (Primary Forms) or 3920 (Other Plates/Sheets/Film) depending on specific subheading nuances in the provided data.
- If the material is a generic plastic (not specified as PA) but non-reinforced β†’ It falls under Heading 3920 (Other plates, sheets, film, foil and strip, of plastics).
- "Unreinforced" means no fibrous reinforcement (like glass fibers), which keeps it within standard plastic film classifications rather than composite reinforced materials.


πŸ“¦ II. HS Code Classification Details (2026 Latest Tariff Authoritative Comparison)

Based on the provided <DATA>, here are the specific HS Codes and their logic for Unreinforced Polyamide Plastic Film:

HS Code Product Description (Summary) Material/Type Logic for Classification Total Tax Rate
3920.99.20.00 Unreinforced plastic film, material is plastic, form is film, meets non-reinforced characteristics. Generic Plastic (Unreinforced) Classified as "Other" plastic films under 3920.99. 39.2%
3920.99.10.00 Unreinforced plastic film, material is plastic, form is film, belongs to plastic plate/sheet/film/foil category. Generic Plastic (Unreinforced) Specific sub-subheading for plastic films under 3920.99. 41.0%
3908.10.00.00 Polyamide film, material is Polyamide, form is film, belongs to primary forms. Polyamide (PA) Classified under 3908 (Polyamides) in primary forms/films. 41.3%
3908.90.70.00 Polyamide film, material is Polyamide, form is film, belongs to other categories. Polyamide (PA) Classified under 3908 (Polyamides) as "Other". 41.5%
3920.92.00.00 Polyamide film, material is Polyamide, form is film, meets coding requirements. Polyamide (PA) Specific code for Polyamide films under 3920.92. 39.2%

πŸ” Key Insight:
- Polyamide-specific codes (3908.xx and 3920.92) are preferred if the product is confirmed to be Polyamide (Nylon).
- Generic codes (3920.99) apply if the plastic type is not specified or is a different polymer.
- Tax Variation: Even within Polyamide, the tax rate varies from 39.2% to 41.5% depending on the specific subheading (Primary Form vs. Film vs. Other).


πŸ’° III. 2026 Latest Tariff Rate Details (Including Surcharges & Policy Add-ons)

βœ… Applicable Country: United States (US)
βœ… Origin: China (CN)
βœ… Effective Time: Based on current trade data (Note: Rates include specific surcharges)

🎯 1. 3920.99.20.00 β€”β€” Unreinforced Plastic Film (Generic)

Item Content
Base Tariff 4.2% (Ad valorem)
Section 301 Surcharge +25.0%
122 Clause Surcharge +10.0%
Total Tariff Rate 39.2%
Tax Calculation CIF Value Γ— 39.2%
De Minimis Exemption ❌ Not Applicable
Legal Basis Standard USITC Tariff + Section 301 + 122 Clause

πŸ“Œ Explanation:
- The 4.2% is the standard Most Favored Nation (MFN) rate for other plastic films.
- The 25% is the Section 301 tariff on Chinese plastics.
- The 10% is the additional "122 Clause" tariff (often related to specific strategic goods or policy adjustments).
- Total: 39.2%.


🎯 2. 3920.99.10.00 β€”β€” Unreinforced Plastic Film (Specific Subcategory)

Item Content
Base Tariff 6.0%
Section 301 Surcharge +25.0%
122 Clause Surcharge +10.0%
Total Tariff Rate 41.0%
Tax Calculation CIF Value Γ— 41.0%
De Minimis Exemption ❌ Not Applicable

πŸ“Œ Explanation:
- Slightly higher base rate (6.0%) compared to 3920.99.20.00.
- Total: 41.0%.


🎯 3. 3908.10.00.00 β€”β€” Polyamide Film (Primary Forms)

Item Content
Base Tariff 6.3%
Section 301 Surcharge +25.0%
122 Clause Surcharge +10.0%
Total Tariff Rate 41.3%
Tax Calculation CIF Value Γ— 41.3%
De Minimis Exemption ❌ Not Applicable

πŸ“Œ Explanation:
- Polyamides (Nylon) in primary forms often carry a higher base tariff.
- Total: 41.3%.


🎯 4. 3908.90.70.00 β€”β€” Polyamide Film (Other)

Item Content
Base Tariff 6.5%
Section 301 Surcharge +25.0%
122 Clause Surcharge +10.0%
Total Tariff Rate 41.5%
Tax Calculation CIF Value Γ— 41.5%
De Minimis Exemption ❌ Not Applicable

πŸ“Œ Explanation:
- "Other" polyamides typically have the highest base rate among the listed options.
- Total: 41.5%.


🎯 5. 3920.92.00.00 β€”β€” Polyamide Film (Specific Film Code)

Item Content
Base Tariff 4.2%
Section 301 Surcharge +25.0%
122 Clause Surcharge +10.0%
Total Tariff Rate 39.2%
Tax Calculation CIF Value Γ— 39.2%
De Minimis Exemption ❌ Not Applicable

πŸ“Œ Explanation:
- Interestingly, this Polyamide-specific film code has the same total rate (39.2%) as the generic 3920.99.20.00 due to the same 4.2% base rate.
- Total: 39.2%.


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

βœ… 1. Preparation Checklist (Mandatory)

Document Required Notes
βœ… Product Specification Sheet βœ”οΈ Must clearly state "Polyamide" or "Nylon" and "Unreinforced".
βœ… Material Safety Data Sheet (MSDS) βœ”οΈ Confirms chemical composition (PA 6, PA 66, etc.).
βœ… Product Photos βœ”οΈ Show texture, thickness, and packaging.
βœ… Commercial Invoice βœ”οΈ Accurate description: "Unreinforced Polyamide Plastic Film".
βœ… Packing List βœ”οΈ Weight and dimensions for volume calculations.

βœ… 2. Declaration Tips (Key Mantras)

πŸ”₯ β€œMaterial First, Reinforcement Check, Code Precision, Tax Savings!”

Scenario Correct Declaration Wrong Practice
Pure Polyamide Film 3920.92.00.00 or 3908.xx Use generic 3920.99 β†’ Risk of audit if material is misstated.
Generic Plastic Film 3920.99.20.00 Mislabel as "Polyamide" β†’ Higher base rate (6.3-6.5% vs 4.2%).
Reinforced Film Not Listed in Data Declaring as "Unreinforced" when it contains glass fiber β†’ Severe Penalty/Smuggling Charge.
Coated Laminated Film Check if "Plastic" is primary material If paper/foil is primary, may fall under different chapters.

βœ… 3. Special Circumstances Handling

Situation Handling Advice
OEM Custom Film Provide customer order + material specs to justify specific HS code.
Multi-layer Lamination If layers are polyamide + other plastic, classify based on the essential character (usually the main structural layer).
Sample vs. Bulk Samples may still be subject to duty if not declared as "Free of Charge" with proof.
Transshipment Ensure origin certificate is from China to apply the correct Section 301 rates.

🌍 V. Global Market Clearance Comparison (2026 Latest)

Country/Region Recommended HS Code Tariff (China Origin) Certification Notes
πŸ‡ΊπŸ‡Έ USA 3920.92.00.00 / 3920.99.20.00 39.2% - 41.5% FDA (if food contact) High tariffs due to Section 301 + 122 Clause.
πŸ‡¨πŸ‡³ China 3920.92.00.00 ~5-6% (Import) No special surcharges Lower base rates.
πŸ‡ͺπŸ‡Ί EU 3920.92.00.00 0-2.7% (CE/RoHS) REACH Compliance No Section 301 tariffs.
πŸ‡―πŸ‡΅ Japan 3920.92.00.00 3-5% PSE (if electrical) Moderate tariffs.
πŸ‡»πŸ‡³ Vietnam Varies 0-5% (with RCEP) Local Standards Potential for preferential tariffs if assembled locally.

πŸ“Œ Conclusion:
- USA is the most expensive market due to aggressive surcharges (Section 301 + 122 Clause).
- EU/Japan/Vietnam offer significantly lower total tariff burdens.
- Strategic Recommendation: Consider supply chain diversification (e.g., Vietnam/Mexico) for US-bound goods to mitigate 25-35% surcharges.


πŸ“Œ VI. Common Mistakes & Pitfall Guide (Lessons Learned)

❌ Mistake 1: Misidentifying "Reinforced" as "Unreinforced"
πŸ‘‰ Consequence: Customs Seizure & Heavy Fines. Reinforced films (e.g., glass fiber) have different HS codes and lower/no Section 301 surcharges in some cases, but false declaration is fraud.

❌ Mistake 2: Using Generic Code for Polyamide
πŸ‘‰ Consequence: May attract higher base tariff (6.5% vs 4.2%) if the specific Polyamide code (3920.92.00.00) is more appropriate, or vice versa. Always specify "Polyamide".

❌ Mistake 3: Ignoring the "122 Clause"
πŸ‘‰ Consequence: Underestimating total cost by 10%. This is a significant hidden cost for US imports.

❌ Mistake 4: Incorrect CIF Valuation
πŸ‘‰ Consequence: Under-declaring value leads to penalties. Ensure freight and insurance are included.

βœ… Correct Practice:

"Unreinforced Polyamide 6 Film, Thickness 0.05mm, Width 1m, Food Grade, Made in China"


🎯 VII. Conclusion: Professional Declaration, Save Time & Money!

🎯 Remember the Mantra:

πŸ”Ή "Polyamide Specifics, 3920.92 is Key for Film."
πŸ”Ή "Unreinforced Means No Fibers, Check Before You Ship."
πŸ”Ή "US Tariff is High (40%), Plan Your Supply Chain."


πŸ“Œ Pro Tip:
If your film is food-contact compliant, ensure FDA documentation is ready.
For US Imports, calculate the 39.2%-41.5% total cost into your pricing model immediately.
Consider Advance Rulings from US Customs (CBP) if the product structure is complex (e.g., multi-layer).


πŸ“£ Immediate Action:

πŸ“ž Contact a licensed Customs Broker
πŸ“„ Prepare MSDS & Product Specs
πŸš€ Optimize your supply chain to handle the ~40% US tariff burden.


✨ Professional Customs Clearance Starts with Accurate Classification!
πŸ’Ό Every Percent of Tariff Mattersβ€”Precision Saves Profit!

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.