film roll short roll
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3704000000 | 35.0% | CN | US | Official Doc |
| 3702100060 | 38.7% | CN | US | Official Doc |
| 3702310100 | 38.7% | CN | US | Official Doc |
| 3701910060 | 38.7% | CN | US | Official Doc |
| 3920992000 | 39.2% | CN | US | Official Doc |
AI Analysis
🎞️ Film Roll / Short Roll (Photographic Film)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 1. Product Definition & Classification: Do You Really Understand “Film Roll”?
“Film roll” (often referred to as short roll in retail or specific formats) is a light-sensitive recording medium used in photography, cinematography, and industrial imaging. In international trade, it is primarily classified under Chapter 37 (Photographic or Cinematographic Goods).
The core classification depends on the material, format, and intended use (color/black & white, X-ray, or industrial). The data provided highlights several potential HS Codes, ranging from generic photographic film to plastic sheets, each with distinct customs implications.
📦 2. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Applicability | Material/Format | Total Tax Rate (US Imports from CN) |
|---|---|---|---|---|
3704.00.00.00 |
Photographic plates and film in the roll, unexposed (Generic) | General unexposed film rolls | Film/Plate | 35.0% |
3702.10.00.60 |
Unexposed motion picture film on a support of plastics | Motion picture film | Plastic support | 38.7% |
3702.31.01.00 |
Unexposed motion picture film on a support of plastics (Color) | Color motion picture film | Plastic support | 38.7% |
3701.91.00.60 |
Unexposed color photographic plates and film, other than motion picture film | Still photography film (non-motion) | Plastic/Non-paper | 38.7% |
3920.99.20.00 |
Plates, sheets, film, foil and strip, of plastics (Non-photographic) | Misclassified as plastic sheeting | Plastic (Non-photosensitive) | 39.2% |
🔍 Key Distinction:
- True Photographic Film (3704,3702,3701): Must be light-sensitive and used for imaging. If it is just a plain plastic strip without emulsion, it is NOT photographic film.
- Plastic Film (3920): If the item is not photosensitive (e.g., packaging film, protective wrap), it may be misclassified here. However, for photographic rolls, this code is usually incorrect if the product is truly photographic.
💰 3. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Time: November 10, 2025 (and subsequent imports)
🎯 1. 3704.00.00.00 —— General Photographic Film in Rolls
| Item | Content |
|---|---|
| Base Tariff | 0.0% (Ad Valorem) |
| Section 301 Additional Duty | +25.0% |
| Section 122 Duty | +10.0% |
| Total Tariff Rate | 35.0% |
| Tax Calculation | CIF Value × 35.0% |
| De Minimis Eligibility | ❌ No (Deny De Minimis for China-origin goods under these specific codes due to high surcharges) |
| Legal Basis Path | USITC:3704.00.00.00 → SECTION_301:25% → SECTION_122:10% |
📌 Explanation:
- This code is for general unexposed film.
- The 25% Section 301 tariff is the primary burden for Chinese manufacturing.
- The 10% Section 122 tariff is an additional levy on certain goods from China.
- Total 35% is a significant cost factor. Ensure your product is truly "photographic" to avoid misclassification penalties.
🎯 2. 3702.10.00.60 & 3702.31.01.00 —— Motion Picture Film (Plastic Support)
| Item | Content |
|---|---|
| Base Tariff | 3.7% |
| Section 301 Additional Duty | +25.0% |
| Section 122 Duty | +10.0% |
| Total Tariff Rate | 38.7% |
| Tax Calculation | CIF Value × 38.7% |
| De Minimis Eligibility | ❌ No |
| Legal Basis Path | USITC:3702.xxxxx → SECTION_301:25% → SECTION_122:10% |
📌 Note:
- These codes apply specifically to motion picture film (cinema) on plastic supports.
- The 3.7% base rate is higher than3704, but the surcharges remain the same, leading to a higher 38.7% total.
- Misclassifying cinema film as general film (3704) can lead to underpayment of duties and penalties.
🎯 3. 3701.91.00.60 —— Color Photographic Film (Other Than Motion Picture)
| Item | Content |
|---|---|
| Base Tariff | 3.7% |
| Section 301 Additional Duty | +25.0% |
| Section 122 Duty | +10.0% |
| Total Tariff Rate | 38.7% |
| Tax Calculation | CIF Value × 38.7% |
| De Minimis Eligibility | ❌ No |
| Legal Basis Path | USITC:3701.91.00.60 → SECTION_301:25% → SECTION_122:10% |
📌 Explanation:
- This code is for still photography color film (e.g., 35mm, 120 roll film for cameras).
- It explicitly excludes motion picture film.
- If you ship 35mm Kodak/ Fujifilm rolls, this is likely the correct code.
🎯 4. 3920.99.20.00 —— Plastic Plates, Sheets, Film, etc.
| Item | Content |
|---|---|
| Base Tariff | 4.2% |
| Section 301 Additional Duty | +25.0% |
| Section 122 Duty | +10.0% |
| Total Tariff Rate | 39.2% |
| Tax Calculation | CIF Value × 39.2% |
| De Minimis Eligibility | ❌ No |
| Legal Basis Path | USITC:3920.99.20.00 → SECTION_301:25% → SECTION_122:10% |
⚠️ Critical Warning:
- This code is for non-photosensitive plastic film (e.g., shrink wrap, laminating film).
- Do NOT use this for photographic film unless the product is explicitly not light-sensitive.
- If declared as "plastic film" but found to be photographic, customs will reclassify it, leading to back taxes, fines, and delays.
🛠️ 4. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)
✅ 1. Preparation Checklist (Non-Negotiable)
| Document | Required? | Notes |
|---|---|---|
| ✅ Product Specifications | ✔️ | Must state: "Unexposed Photographic Film," format (35mm, 120, 16mm), and light sensitivity. |
| ✅ Composition Statement | ✔️ | Explicitly state: "Emulsion on plastic/paper base, photosensitive." |
| ✅ Photos (Clear & Labeled) | ✔️ | Show the roll, packaging, and any warning labels (e.g., "Keep away from light"). |
| ✅ Commercial Invoice | ✔️ | Describe as "Photographic Film Roll, Unexposed, for Camera Use." Avoid vague terms like "plastic strip." |
| ✅ Packing List | ✔️ | Ensure weight and dimensions match the invoice. |
✅ 2. Declaration Tips (Key Mantras)
🔥 “Be Specific: ‘Photographic,’ Not ‘Plastic.’ Format Matters. Tax Changes.”
| Scenario | Correct Declaration | Wrong Declaration |
|---|---|---|
| 35mm Color Film for Cameras | 3701.91.00.60 – “Unexposed Color Photographic Film, 35mm” |
3920.99.20.00 – “Plastic Roll” |
| Cinema Film Reel | 3702.31.01.00 – “Unexposed Color Motion Picture Film” |
3704.00.00.00 – “General Film” |
| X-ray Film | 3702.31.01.00 or similar medical imaging code |
3704.00.00.00 (May be misclassified) |
| Non-Photosensitive Plastic Wrap | 3920.99.20.00 – “Plastic Film for Packaging” |
3704.00.00.00 – “Photographic Film” |
✅ 3. Special Cases
| Case | Handling Advice |
|---|---|
| OEM/White Label Film | Provide the manufacturer’s datasheet proving it is photosensitive. |
| Digital vs. Analog | Ensure it is unexposed physical film. Digital memory cards are classified under 8523 (different tax rates). |
| Expired Film | Still classified as photographic film. No special tariff reduction for expiration. |
| Mixed Shipments | If shipping film with camera accessories, declare separately. Accessories may have different HS codes (e.g., 9006 for cameras). |
🌍 5. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3701.91.00.60 / 3702.31.01.00 |
38.7% | N/A | High Section 301 & 122 duties apply. |
| 🇨🇳 China | 3701.91.00.60 |
~3-5% | N/A | Low import duty, no Section 301. |
| 🇪🇺 EU | 3702.31.00 |
0% (if under quota) | CE (if applicable) | Often duty-free for photography goods. |
| 🇯🇵 Japan | 3702.31.00 |
0-3% | PSE (if electronic) | Generally low tariffs. |
📌 Conclusion:
- The US market is the most expensive due to Section 301 (25%) and Section 122 (10%) tariffs.
- EU and Japan are more favorable for photographic goods.
- For US imports, accurate classification is critical to avoid penalties, as the tariff difference between photographic (37xx) and non-photographic plastic (39xx) is small, but the risk of misclassification is high.
📌 6. Common Errors & Pitfall Guide (Lessons Learned)
❌ Error 1: Declaring "Photographic Film" as "Plastic Sheet" (3920) to save hassle.
👉 Consequence: If found to be photosensitive, customs will reclassify and charge 39.2% instead of potentially lower base rates, plus penalties for misdeclaration.
❌ Error 2: Using 3704.00.00.00 for all film types.
👉 Consequence: While the base rate is 0%, the specific codes (3701, 3702) may have different administrative treatments. Using the generic code may trigger further customs review.
❌ Error 3: Ignoring "Section 122" in total cost calculation.
👉 Consequence: Many traders only account for the 25% Section 301 tariff, forgetting the additional 10% Section 122, leading to under-budgeting.
❌ Error 4: Failing to specify "Unexposed."
👉 Consequence: Exposed film may be classified differently or restricted due to radiation/chemical content concerns.
✅ Correct Approach:
“Unexposed Color Photographic Film, 35mm Roll, for 35mm Cameras, Made in China, HS Code 3701.91.00.60”
🎯 7. Conclusion: Professional Declaration Saves Money!
🎯 Remember the Mantra:
🔹 “Photographic? Use Chapter 37. Plastic? Use Chapter 39. Don’t Mix!”
🔹 “38.7% is the Reality for US Imports. Plan Your Margin Accordingly.”
📌 Pro Tip:
If you are shipping small quantities, be aware that de minimis exemptions (Section 321) often do not apply to goods subject to Section 301 and Section 122 tariffs from China. Always assume duties will be charged.
📣 Immediate Action:
📞 Verify your product’s photosensitivity with your manufacturer.
🚀 Use the correct HS Code (3701or3702) to ensure smooth clearance.
💼 Accurate classification is the first step to cost control!
✨ Professional Customs Clearance Starts with Precise Classification!
💼 Every percentage point matters in 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) — Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) — More specific grouping within the chapter
- Subheading (6 digits) — Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) — 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 — The standard duty rate applied to WTO members
- General rate — Applied to countries without trade agreements
- Trade remedy duties — 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.