Wide format Industrial Radiography Film
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3921905050 | 39.8% | CN | US | Official Doc |
| 3921904090 | 39.2% | CN | US | Official Doc |
| 3702440160 | 38.7% | CN | US | Official Doc |
| 3702440130 | 38.7% | CN | US | Official Doc |
| 3920992000 | 39.2% | CN | US | Official Doc |
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AI Analysis
ποΈ Wide Format Industrial Radiography Film
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional-Level Customs Strategy
π I. Product Definition & Classification: Do You Really Understand "Industrial Radiography Film"?
Industrial Radiography Film, used in Non-Destructive Testing (NDT) for inspecting welds, castings, and structures, is a specialized material. In international trade, it is critical to distinguish between Photographic/Artistic Film (Chapter 37) and General Purpose Plastic Films (Chapter 39). The classification hinges on two key factors: 1. Physical Dimensions: Specifically, whether the width exceeds 105mm (the threshold for "Wide Format" in Chapter 37). 2. Material & Usage: Is it a "Sensitive Emulsion" designed for image capture, or a generic "Plastic Substrate/Film"?
β οΈ Key Distinction Point:
- If the film is photographic/sensitive and width β€ 105mm β Classified under 3702 (Photographic Film).
- If the film is photographic/sensitive and width > 105mm β Classified under 3702 (Wide Format Photographic Film).
- If the film is non-sensitive plastic film (e.g., PET backing only, not for direct imaging) β Classified under 3920/3921 (Plastic Films/Sheets).
π¦ II. HS Code Classification Details (2026 Latest Tariff Authoritative Comparison)
| HS Code | Product Description | Applicable Scenario | Width Constraint |
|---|---|---|---|
3702.44.01.30 |
Photographic film, sensitive, unexposed, in rolls of a width > 105 mm but not > 610 mm, for photographic use in the image arts | Standard industrial radiography rolls (e.g., for pipe welds) | 105mm β 610mm |
3702.44.01.60 |
Photographic film, sensitive, unexposed, in rolls of a width > 105 mm, for photographic use in the image arts | Large-format industrial radiography | > 105mm (Specific sub-code for wider/standard industrial rolls) |
3921.90.50.50 |
Other plates, sheets, film, foil and strip, of plastics | Non-sensitive plastic film, backing materials, generic plastic sheets | N/A (Generic plastic) |
3921.90.40.90 |
Other plates, sheets, film, foil and strip, of plastics | Generic plastic film/sheets (non-photographic) | N/A (Generic plastic) |
3920.99.20.00 |
Other plates, sheets, film, foil and strip, of plastics, not reinforced, laminated, supported or similarly combined with other materials | General purpose plastic films | N/A (Generic plastic) |
π Key Reminder:
- True Radiography Film (sensitized emulsion for X-ray/Gamma ray imaging) falls under Chapter 37. The key differentiator for "Wide Format" is the width > 105mm.
- Do NOT misclassify sensitized radiography film as generic plastic (Chapter 39) unless it is explicitly non-sensitive or used merely as a carrier/backing. Misclassification leads to severe penalties.
- Sub-codes3702.44.01.30and3702.44.01.60are specific to sensitive film in the image arts/industrial inspection sector.
π° III. 2026 Latest Tariff Rate Details (Including Surcharge, Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: From November 10, 2025 (inclusive)
π― 1. 3702.44.01.60 β Wide Format Sensitive Photographic Film (>105mm)
| Item | Content |
|---|---|
| Base Tariff Rate | 3.7% (ad valorem) |
| USITC Surcharge | +25.0% (From USITC Footnote 9903.88.01 / Section 301) |
| IEEPA Surcharge | +10.0% (For China/HK origin, from Nov 10, 2025) |
| Total Tariff Rate | 38.7% |
| Tax Calculation | CIF Value Γ 38.7% |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3702.44.01.60 β FOOTNOTE:9903.88.01 |
π Explanation:
- The 25% USITC surcharge is applied under Section 301 of the Trade Act for specific Chinese imports.
- The 10% IEEPA surcharge is a separate levy under the International Emergency Economic Powers Act targeting Chinese goods.
- Total 38.7% is a high tariff burden. Precise classification is crucial to avoid over-taxing if the product is non-sensitive.
π― 2. 3702.44.01.30 β Sensitive Photographic Film (Width 105mm-610mm)
| Item | Content |
|---|---|
| Base Tariff Rate | 3.7% (ad valorem) |
| USITC Surcharge | +25.0% |
| IEEPA Surcharge | +10.0% |
| Total Tariff Rate | 38.7% |
| Tax Calculation | CIF Γ 38.7% |
| De Minimis Eligibility | β Not Eligible |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3702.44.01.30 β FOOTNOTE:9903.88.01 |
π Note:
- Same tariff structure as above. The width range (105mm-610mm) distinguishes the sub-code but not the effective tax rate.
- Applies to standard industrial radiography rolls used in pipeline inspection, welding checks, etc.
π― 3. 3921.90.50.50 β Other Plastic Films (Non-Sensitive)
| Item | Content |
|---|---|
| Base Tariff Rate | 4.8% (ad valorem) |
| USITC Surcharge | +25.0% |
| IEEPA Surcharge | +10.0% |
| Total Tariff Rate | 39.8% |
| Tax Calculation | CIF Γ 39.8% |
| De Minimis Eligibility | β Not Eligible |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3921.90.50.50 β FOOTNOTE:9903.88.01 |
π Note:
- If the product is not sensitive film (e.g., generic plastic sheeting used in packaging or non-imaging industrial applications), it falls here.
- Surprisingly, the rate is HIGHER (39.8%) than sensitive film (38.7%). Do not assume generic plastics are cheaper!
π― 4. 3921.90.40.90 β Other Plastic Films (Non-Sensitive)
| Item | Content |
|---|---|
| Base Tariff Rate | 4.2% (ad valorem) |
| USITC Surcharge | +25.0% |
| IEEPA Surcharge | +10.0% |
| Total Tariff Rate | 39.2% |
| Tax Calculation | CIF Γ 39.2% |
| De Minimis Eligibility | β Not Eligible |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3921.90.40.90 β FOOTNOTE:9903.88.01 |
π― 5. 3920.99.20.00 β Other Plastic Films
| Item | Content |
|---|---|
| Base Tariff Rate | 4.2% (ad valorem) |
| USITC Surcharge | +25.0% |
| IEEPA Surcharge | +10.0% |
| Total Tariff Rate | 39.2% |
| Tax Calculation | CIF Γ 39.2% |
| De Minimis Eligibility | β Not Eligible |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3920.99.20.00 β FOOTNOTE:9903.88.01 |
π Summary of Tax Rates:
- Sensitive Radiography Film (Ch37): 38.7%
- Generic Plastic Film (Ch39): 39.2% β 39.8%
- Crucial Insight: Sensitive film often has a slightly lower total tariff rate than generic plastic films in this specific tariff configuration. Misclassifying sensitive film as generic plastic will increase your tax burden.
π οΈ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)
β 1. Required Documentation Checklist (Non-negotiable)
| Document | Mandatory? | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must detail: Sensitivity type (X-ray/Gamma), emulsion type, width, length, weight. |
| β Certificate of Non-Sensitivity (if applicable) | βοΈ | If claiming Ch39, provide lab report proving NO silver halide or photographic emulsion. |
| β Commercial Invoice | βοΈ | Clearly state: "Industrial Radiography Film, Sensitive, Width: 150mm, For Non-Destructive Testing". Avoid vague terms like "Plastic Film". |
| β Packing List | βοΈ | Detail roll dimensions and core size. |
| β Origin Certificate (CO) | βοΈ | Required for US Customs entry. |
β 2. Declaration Strategy (Key Mnemonics)
π₯ βSensitive Emulsion, Width Matters. If >105mm, Code 3702. If Generic, Code 39.β
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Sensitized Radiography Film | HS 3702.44.01.60 (or .30) | Declaring as "Plastic Film" β Higher tax (39.8%) |
| Non-Sensitive Plastic Backing | HS 3921.90.50.50 | Declaring as "Photographic Film" β Compliance risk |
| Width β€ 105mm (Sensitized) | HS 3702.xx (Narrow format) | Using Wide Format code β Inaccurate but same tax? Check specific sub-codes. |
| Mixed Containers (Sensitized + Non-Sensitized) | Separate Line Items | Mixing codes β High risk of audit/seizure |
β 3. Special Handling Cases
| Case | Handling Advice |
|---|---|
| Sample Shipments | Even samples are subject to 38.7%~39.8% tariffs. No De Minimis exemption ($800 rule does NOT apply). |
| Re-exported Goods | If re-exported from the US, ensure original classification was correct to claim duty drawback if eligible. |
| Labeling | Must label as "Sensitive Photographic Material" if Ch37. If Ch39, label as "Plastic Film". Mislabeling triggers customs holds. |
π V. Global Market Customs Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Remarks |
|---|---|---|---|---|
| πΊπΈ USA | 3702.44.01.60 |
38.7% | None specific | High surcharges apply. |
| π¨π³ China | 3702.44.01.60 |
~5-7% | CCC (if applicable) | Lower base rate, no 301 tariff. |
| πͺπΊ EU | 3702.44 |
6.5% | REACH | No Section 301 equivalent, but VAT applies. |
| π¦πΊ Australia | 3702.44 |
5% | GSR | Moderate tariffs. |
π Conclusion:
- USA is the most expensive market for industrial radiography film due to combined Section 301 (25%) and IEEPA (10%) surcharges.
- Accurate classification is financially critical: Misclassifying sensitive film as generic plastic increases tax by ~1%.
- No De Minimis: Small shipments do NOT bypass tariffs. Plan logistics cost accordingly.
π VI. Common Mistakes & Pitfall Guide (Blood-Teaching Lessons)
β Mistake 1: Calling "Radiography Film" simply "Plastic Sheet"
π Consequence: Customs may classify it as Ch39 (39.2-39.8%) OR flag it for lacking proper safety/emulsion labels. Risk of penalty.
β Mistake 2: Ignoring the 105mm Width Threshold
π Consequence: Using narrow format codes for wide rolls leads to misdeclaration. While tax might be similar, accuracy is required for trade compliance.
β Mistake 3: Assuming De Minimis Applies
π Consequence: Sending a sample roll under $800 and expecting free entry. Result: Shipment held, tax demanded, delayed by weeks.
β Mistake 4: Failing to Distinguish Sensitive vs. Non-Sensitive
π Consequence: If you ship sensitive film but declare it as non-sensitive plastic, you violate import regulations regarding hazardous materials (silver halide). Seizure risk.
β Correct Practice:
"Industrial Radiography Film, Sensitive, Unexposed, Width: 150mm, Roll Length: 100m, For Non-Destructive Testing of Steel Welds, Model XYZ, Ch3702.44.01.60"
π― VII. Conclusion: Professional Declaration, Save Money, Save Time!
π― Remember the Mantras:
πΉ "Sensitive Film is Ch37, Width >105mm is Key. If Non-Sensitive, Check Ch39. Taxes are High, Be Accurate!"
πΉ "38.7% for Sensitive, 39.8% for Generic. Don't Pay Extra Due to Wrong Code!"
πΉ "No De Minimis for Film. Pay Tax on Samples Too!"
π Tips:
- If your film is originally from Vietnam, Malaysia, or Thailand, you MIGHT be eligible for IEEPA Exemption or lower Section 301 rates.
- Recommendation: Apply for an Advance Ruling from US Customs (CBP) if shipping large volumes. This locks in the classification and prevents unexpected audits.
π£ Immediate Action:
π Contact a Licensed Customs Broker + Provide Product Photos + Request CBP Advance Ruling
π Ensure Your Radiography Film Clears Customs Smoothly, Minimizing Costs and Delays!
β¨ Professional Customs Clearance Starts with Precise Classification!
πΌ Every Percent of Tariff Saves Your Profit Margin!
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.