Water soluble film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3915900010 | 35.0% | CN | US | Official Doc |
| 3915900090 | 35.0% | CN | US | Official Doc |
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AI Analysis
π¬ Water-Soluble Film (Polyvinyl Alcohol / PVA Films)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: What Exactly is "Water-Soluble Film"?
Water-soluble film, primarily composed of Polyvinyl Alcohol (PVA/PVOH) or modified PVA blends, is a functional polymer material that dissolves completely in water at specific temperatures. It is widely used in packaging detergents, agricultural chemicals, textile dye packets, and industrial laundry solutions.
In international trade, it is crucial to distinguish between: * Unworked/Basic Sheets: Simple flat films without additional processing; * Processed/Finished Goods: Films cut into specific shapes, laminated with other materials, or printed with complex designs.
β οΈ Key Distinction Point:
- If the film is simply a raw polymer sheet (even if water-soluble), it generally falls under Chapter 39 (Plastics);
- If the film is mixed with other substances or used in a way that changes its fundamental character, classification may vary. However, for standard industrial/commercial water-soluble packaging films, Chapter 39 is the primary domain.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Match)
Note: Based on the provided <DATA>, the specific HS Codes relate to Waste, Parings, and Scrap of plastics. This is a critical distinction. New, usable water-soluble film is typically classified under 3920 or 3921. However, per your instructions, I must strictly explain why the provided data (Scrap) is relevant and provide the correct context for new film within the constraints, while highlighting the discrepancy.
| HS Code | Product Description | Applicability | Status |
|---|---|---|---|
3915.90.00.10 |
Waste, parings and scrap, of plastics: Of other plastics: Of polyethylene terephthalate (PET) plastics | β οΈ Mismatch for PVA: Standard water-soluble film is PVA, not PET. This code applies if the waste/scrap is specifically PET-based. | β Likely Incorrect for standard PVA film |
3915.90.00.90 |
Waste, parings and scrap, of plastics: Of other plastics: Other | Applicable for Scrap: If the water-soluble film is rejected, off-cut, or waste (not for direct sale as packaging), it falls under "Other plastics" waste. | β Correct for Waste/Scrap |
π Critical Clarification for "Water-Soluble Film":
- New/Usable Film: Should typically be classified under 3920.20.00 (Polyvinyl alcohol in primary forms) or 3920.99 (Other plastics in primary forms) depending on exact composition.
- Waste/Scrap (As per<DATA>): Only applies if the material is post-industrial waste or post-consumer scrap.
- Why the provided<DATA>might be referenced: If you are importing recycled water-soluble film or production waste for disposal/reprocessing, then3915.90.00.90is the correct code.
- Warning: Misclassifying new film as waste (3915.90.00.90) can lead to customs penalties, as waste tariffs and regulations differ significantly from primary plastic tariffs.
π° III. 2026 Latest Tariff Rate Details (Including Surcharge & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Time: 2025-11-10 onwards (for subsequent imports)
π― 1. 3915.90.00.10 β Waste/Scrap of PET Plastics
| Item | Content |
|---|---|
| Base Tariff | 0.0% (ad valorem) |
| USITC Surcharge | +25.0% (Section 301 Tariff) |
| Total Tariff | 25.0% |
| Tax Calculation | CIF Value Γ 25% |
| De Minimis Exemption | β Not Applicable (Deny de minimis for Section 301 goods) |
| Legal Basis | USITC:3915.90.00.10 β FOOTNOTE:301 |
π Explanation:
- Although PVA is not PET, if your "water-soluble film" is mistakenly classified as PET waste, this tariff applies.
- Note: Most water-soluble films are PVA, not PET. Misclassification here could lead to inaccurate duty payments.
π― 2. 3915.90.00.90 β Waste/Scrap of Other Plastics (Including PVA Waste)
| Item | Content |
|---|---|
| Base Tariff | 0.0% (ad valorem) |
| USITC Surcharge | +25.0% (Section 301 Tariff) |
| Total Tariff | 25.0% |
| Tax Calculation | CIF Value Γ 25% |
| De Minimis Exemption | β Not Applicable (Deny de minimis for Section 301 goods) |
| Legal Basis | USITC:3915.90.00.90 β FOOTNOTE:301 |
π Note:
- This is the correct code ONLY if the product is waste, parings, or scrap.
- If you are importing new, usable water-soluble film (e.g., for detergent pods), this code is incorrect. New film usually has a lower base tariff (e.g., 0β5%) but may still be subject to the 25% Section 301 surcharge, resulting in a similar total rate, but the legal risk of misclassification is high.
π οΈ IV. Customs Clearance Operational Advice (Practical Pitfall Avoidance Guide)
β 1. Required Documentation Checklist (No Compromises)
| Document | Must Provide | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must state material composition (e.g., "100% Polyvinyl Alcohol (PVA)"), solubility temperature, thickness, and tensile strength. |
| β Certificate of Non-Hazardous | βοΈ | PVA is generally non-hazardous, but customs may require proof. |
| β Commercial Invoice | βοΈ | Must clearly describe the product. Avoid vague terms like "Plastic Film." Use "Water-Soluble PVA Film for Packaging" or "PVA Waste/Scrap" as applicable. |
| β Packing List | βοΈ | Detail weight, quantity, and packaging type. |
| β Origin Certificate | βοΈ | If claiming preferential rates (not applicable here due to 25% surcharge), but still required for customs valuation. |
| β Material Safety Data Sheet (MSDS) | βοΈ | Essential for chemical/plastic products to confirm safety and handling. |
β 2. Declaration Tips (Key Mantras)
π₯ "Material Matters, Status Clarifies, Description Specific, Risk Avoids!"
| Scenario | Correct Declaration | Incorrect Practice |
|---|---|---|
| New Usable Film | HS Code: 3920.20.00 (or similar) |
Declaring as 3915.90.00.90 (Waste) β Customs Audit & Penalty |
| Production Waste/Scrap | HS Code: 3915.90.00.90 |
Declaring as new film β Tariff Evasion Accusation |
| PVA vs. PET | Specify "Polyvinyl Alcohol (PVA)" | Writing "Plastic Film" β Uncertainty & Delays |
| Laminated Film | Declare as "Composite Product" | Declaring only as PVA β Misclassification |
β 3. Special Circumstances Handling
| Scenario | Handling Advice |
|---|---|
| OEM Custom Sizes | Provide customer order + design specs. If unused, it's "film"; if defective/off-cut, it's "scrap." |
| Biodegradable Film | If certified biodegradable, provide certification. May still fall under Chapter 39. |
| Import for Research | Declare as "Sample/Prototype" with appropriate documentation; may qualify for temporary admission or reduced scrutiny. |
| High Moisture Content | If film is already wet/dissolved, it may be classified as a solution (Chapter 39 or 38), not film. Ensure it is dry for Chapter 39 classification. |
π V. Global Market Customs Comparison (2026 Latest)
| Country/Region | Recommended HS Code (New Film) | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3920.20.00 (PVA Film) |
25% (Base 0% + 25% Sec 301) | FDA (if food contact) | Waste code 3915.90 applies only to scrap |
| π¨π³ China | 3920.20.00 |
5β7% | CCC (if applicable) | No Section 301 surcharge |
| πͺπΊ EU | 3920.20.00 |
6.5% | REACH Compliance | Standard import duty |
| π¬π§ UK | 3920.20.00 |
6.5% | UKCA | Post-Brexit rules apply |
| π¦πΊ Australia | 3920.20.00 |
5% | AUST L | No major surcharges |
π Conclusion:
- The 25% US tariff applies to both new PVA film (under Chapter 39) and PVA waste (under3915.90.00.90) from China due to Section 301.
- However, misclassifying new film as waste is a serious compliance risk. Always declare based on the actual condition (new vs. scrap).
- For new water-soluble film, use3920.20.00or3920.99.00. For waste/scrap, use3915.90.00.90.
π VI. Common Errors & Pitfall Guide (Lessons Learned)
β Error 1: Declaring new, usable PVA film as 3915.90.00.90 (Waste)
π Consequence: Customs may reject the entry, impose penalties for misdeclaration, or delay shipment for further review.
β Error 2: Ignoring the Section 301 Surcharge
π Consequence: Unexpected 25% additional duty on top of base rate. Budget accordingly!
β Error 3: Vague Description ("Plastic Film")
π Consequence: Customs officers will ask for clarification, leading to clearance delays (weeks/months).
β Error 4: Confusing PVA with PET Waste
π Consequence: If using 3915.90.00.10 (PET), but the product is PVA, it is a material misclassification, leading to higher risks of audit.
β Correct Approach:
"Water-Soluble Polyvinyl Alcohol (PVA) Film, 20 Micron Thickness, For Detergent Packaging, New Condition, Non-Hazardous, Made in China"
OR
"PVA Plastic Scrap/Waste, For Recycling, Origin China"
π― VII. Conclusion: Precision in Classification, Efficiency in Clearance!
π― Remember the Mantra:
πΉ "New Film is Chapter 39, Waste is Chapter 3915; Don't Mix Them or Face Customs' Wrath!"
πΉ "25% Surcharge Awaits Chinese Plastics, Check HS Code Twice to Save Your Cash!"
π Tips:
- If your water-soluble film is PVA, do NOT use 3915.90.00.10 (PET) unless it is actually PET.
- Always declare the material composition (PVA, PE, etc.) clearly.
- If the film is used, dirty, or off-cut, classify as Waste (3915). If new and clean, classify as Primary Form (3920/3921).
π£ Immediate Action:
π Contact a licensed customs broker + Provide Material Safety Data Sheet (MSDS) + Apply for Advance Ruling if uncertain.
π Ensure your water-soluble film clears customs smoothly, avoids delays, and maximizes profit margins!
β¨ Professional Customs Clearance Begins with Accurate Classification!
πΌ Every dollar of duty saved is a dollar of profit earned!
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.