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
ποΈ Unreinforced Polyamide Plastic Film (PA Film)
π HS Code Reference & Customs Clearance Guide | 2026 Updated Tariff Analysis | Professional Clearance Strategy
π 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"?
β οΈ 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.
π¦ 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% |
π Key Insight:
- Polyamide-specific codes (3908.xxand3920.92) 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).
π° III. 2026 Latest Tariff Rate Details (Including Surcharges & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Time: Based on current trade data (Note: Rates include specific surcharges)
π― 1. 3920.99.20.00 ββ 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 | β Not Applicable |
| Legal Basis | Standard USITC Tariff + Section 301 + 122 Clause |
π 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%.
π― 2. 3920.99.10.00 ββ 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 | β Not Applicable |
π Explanation:
- Slightly higher base rate (6.0%) compared to3920.99.20.00.
- Total: 41.0%.
π― 3. 3908.10.00.00 ββ 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 | β Not Applicable |
π Explanation:
- Polyamides (Nylon) in primary forms often carry a higher base tariff.
- Total: 41.3%.
π― 4. 3908.90.70.00 ββ 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 | β Not Applicable |
π Explanation:
- "Other" polyamides typically have the highest base rate among the listed options.
- Total: 41.5%.
π― 5. 3920.92.00.00 ββ 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 | β Not Applicable |
π Explanation:
- Interestingly, this Polyamide-specific film code has the same total rate (39.2%) as the generic3920.99.20.00due to the same 4.2% base rate.
- Total: 39.2%.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Preparation Checklist (Mandatory)
| Document | Required | Notes |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must clearly state "Polyamide" or "Nylon" and "Unreinforced". |
| β Material Safety Data Sheet (MSDS) | βοΈ | Confirms chemical composition (PA 6, PA 66, etc.). |
| β Product Photos | βοΈ | Show texture, thickness, and packaging. |
| β Commercial Invoice | βοΈ | Accurate description: "Unreinforced Polyamide Plastic Film". |
| β Packing List | βοΈ | Weight and dimensions for volume calculations. |
β 2. Declaration Tips (Key Mantras)
π₯ βMaterial First, Reinforcement Check, Code Precision, Tax Savings!β
| 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. |
β 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. |
π V. Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ 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. |
| π¨π³ China | 3920.92.00.00 |
~5-6% (Import) | No special surcharges | Lower base rates. |
| πͺπΊ EU | 3920.92.00.00 |
0-2.7% (CE/RoHS) | REACH Compliance | No Section 301 tariffs. |
| π―π΅ Japan | 3920.92.00.00 |
3-5% | PSE (if electrical) | Moderate tariffs. |
| π»π³ Vietnam | Varies | 0-5% (with RCEP) | Local Standards | Potential for preferential tariffs if assembled locally. |
π 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.
π VI. Common Mistakes & Pitfall Guide (Lessons Learned)
β Mistake 1: Misidentifying "Reinforced" as "Unreinforced"
π 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.
β Mistake 2: Using Generic Code for Polyamide
π 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".
β Mistake 3: Ignoring the "122 Clause"
π Consequence: Underestimating total cost by 10%. This is a significant hidden cost for US imports.
β Mistake 4: Incorrect CIF Valuation
π Consequence: Under-declaring value leads to penalties. Ensure freight and insurance are included.
β Correct Practice:
"Unreinforced Polyamide 6 Film, Thickness 0.05mm, Width 1m, Food Grade, Made in China"
π― VII. Conclusion: Professional Declaration, Save Time & Money!
π― Remember the Mantra:
πΉ "Polyamide Specifics, 3920.92 is Key for Film."
πΉ "Unreinforced Means No Fibers, Check Before You Ship."
πΉ "US Tariff is High (40%), Plan Your Supply Chain."
π 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).
π£ Immediate Action:
π Contact a licensed Customs Broker
π Prepare MSDS & Product Specs
π Optimize your supply chain to handle the ~40% US tariff burden.
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every Percent of Tariff MattersβPrecision 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.