浸渍/层压纸包装基材
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3921904010 | 39.2% | CN | US | Official Doc |
| 4823906700 | 35.0% | CN | US | Official Doc |
| 3921905010 | 39.8% | CN | US | Official Doc |
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AI Analysis
📦 浸渍/层压纸包装基材 (Impregnated/Laminated Paper Packaging Base Material)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Entry Strategies
📌 I. Product Definition & Classification: Do You Really Understand "Paper Packaging"?
Impregnated/Laminated Paper Packaging Base Material is a composite material widely used in high-strength packaging, industrial containers, and decorative applications. In international trade, its classification hinges on whether it is viewed primarily as a paper product or a plastic composite, depending on the manufacturing process and material dominance.
Paper-Based Composite (Cellulose Dominant):
Products where paper is the essential character, coated, impregnated, or laminated with resins or other substances to enhance strength/water resistance.
→ Typically classified under Chapter 48 (Paper/Paperboard).
Plastic-Composite (Resin/Plastic Dominant):
Products where the paper acts merely as reinforcement for a plastic base, or where the plastic layer significantly alters the fundamental nature of the goods, fitting into "Plastics and articles thereof".
→ Typically classified under Chapter 39 (Plastics).
⚠️ Key Distinction Point:
- If the paper is the core substrate, and the impregnation/lamination is for surface treatment/coating to create a specific paper product → Chapter 48.
- If the paper is reinforced within a plastic matrix, or the final product is considered a plastic sheet/board due to the plastic layer's dominance → Chapter 39.
📊 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Material Characteristic |
|---|---|---|---|
4823.90.67.00 |
Articles of paper pulp, paper, cellulose wadding or webs of cellulose fibres, other (Specifically: Coated/Laminated Paper Articles) | High-strength paper bags, coated cartons, paper-based packaging substrates | ✅ Paper-based: Paper is the essential character; impregnation/lamination is a surface treatment. |
3921.90.40.10 |
Other plates, sheets, film, foil and strip, of plastics (Specifically: Paper-Reinforced Plastics) | Plastic laminates with paper core, industrial plastic sheets | ✅ Plastic-based: Paper serves as reinforcement; classified under "Plastics". |
3921.90.50.10 |
Other plates, sheets, film, foil and strip, of plastics (Specifically: High-Pressure Paper-Reinforced Laminates) | HPL (High-Pressure Laminate), industrial structural laminates | ✅ Plastic-based: High-density plastic resin with paper reinforcement; distinct from simple paper coating. |
🔍 Critical Reminder:
- Goods described as "Paper Base Material" that are impregnated/laminated primarily for paper-like functionality should lean towards 4823.90.67.00.
- If the product is explicitly marketed as "Paper-Reinforced Plastic" or has a thick plastic coating making it non-paper-like, it may fall under 3921.90.40.10 or 3921.90.50.10.
- Misclassification can lead to significant tariff discrepancies (e.g., 35% vs. 39.2%+).
💰 III. 2026 Latest Tariff Rate Breakdown (Including Additional Duties & Policy Surcharges)
✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN)
✅ Effective Date: From November 10, 2025 onwards (including subsequent imports)
🎯 1. 4823.90.67.00 —— Paper/Board Articles (Coated/Laminated Paper Packaging)
| Item | Content |
|---|---|
| Base Tariff | 0% (ad valorem) |
| USITC Additional Duty | +25.0% (Under Section 301) |
| IEEPA Additional Duty | +10.0% (针对中国产品，自2025年11月10日起生效) |
| Total Tariff Rate | 35.0% |
| Tax Calculation | CIF Value × 35% |
| De Minimis Exemption Eligible? | ❌ No (deny_de_minimis) |
| Legal Basis Path | USITC:4823.90.67.00 → FOOTNOTE:301.88.01 → IEEPA:9903.01.24 |
📌 Explanation:
- This code treats the item as a paper product.
- The 25% is the standard Section 301 additional tariff for many Chinese goods.
- The 10% is the new IEEPA surcharge effective late 2025.
- Total 35% is high but lower than the plastic alternatives below.
🎯 2. 3921.90.40.10 —— Plastic Plates/Sheets (Paper-Reinforced)
| Item | Content |
|---|---|
| Base Tariff | 4.2% |
| USITC Additional Duty | +25.0% |
| IEEPA Additional Duty | +10.0% |
| Total Tariff Rate | 39.2% |
| Tax Calculation | CIF Value × 39.2% |
| De Minimis Exemption Eligible? | ❌ No (deny_de_minimis) |
| Legal Basis Path | USITC:3921.90.40.10 → FOOTNOTE:301.88.01 → IEEPA:9903.01.24 |
📌 Note:
- Classified as Plastics.
- Higher base duty (4.2%) makes the total higher than the paper code.
- Applies if the paper is seen as mere reinforcement within a plastic matrix.
🎯 3. 3921.90.50.10 —— Plastic Plates/Sheets (High-Pressure Paper-Reinforced)
| Item | Content |
|---|---|
| Base Tariff | 4.8% |
| USITC Additional Duty | +25.0% |
| IEEPA Additional Duty | +10.0% |
| Total Tariff Rate | 39.8% |
| Tax Calculation | CIF Value × 39.8% |
| De Minimis Exemption Eligible? | ❌ No (deny_de_minimis) |
| Legal Basis Path | USITC:3921.90.50.10 → FOOTNOTE:301.88.01 → IEEPA:9903.01.24 |
📌 Note:
- This is the highest tariff option (39.8%).
- Typically for High-Pressure Laminates (HPL) or industrial-grade reinforced plastics.
- Only use if the product is definitively a plastic laminate, not a coated paper sheet.
🛠️ IV. Customs Clearance Practical Advice (Avoid Pitfalls Guide)
✅ 1. Required Documentation Checklist (All Required)
| Document | Mandatory | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must specify: Material composition (e.g., "Paper core with resin coating"), thickness, weight, and processing method (impregnated vs. laminated). |
| ✅ Composition Analysis Report | ✔️ | Third-party lab report showing % of cellulose vs. plastic/resin to support Chapter 48 vs. Chapter 39 classification. |
| ✅ Product Photos | ✔️ | Clear images showing cross-section (to show paper core) and surface finish. |
| ✅ Commercial Invoice | ✔️ | Description must be precise: e.g., "Impregnated Paper Packaging Base, Not Plastic Laminates". Avoid vague terms like "Composite Sheet". |
| ✅ Packing List | ✔️ | Detailed weights and dimensions. |
| ✅ Certificate of Origin (CO) | ✔️ | Mandatory for origin proof; no tariff preference available for CN under these codes. |
✅ 2. Declaration Tips (Key Mantras)
🔥 "Paper Core, Coating is Key. Don't Call it Plastic if it's Paper!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Coated/Laminated Paper (Paper is main substance) | 4823.90.67.00 |
Misclassified as 3921... → Higher tax (39.8%) |
| Reinforced Plastic (Plastic is main substance) | 3921.90.40.10 / 50.10 |
Misclassified as 4823... → Audit risk & penalties |
| Vague "Composite Packaging" | Must specify material hierarchy | Vague description → Customs delay & reclassification |
| HPL (High-Pressure Laminate) | 3921.90.50.10 |
Calling it "Paperboard" → Rejection |
✅ 3. Special Situations Handling
| Situation | Handling Advice |
|---|---|
| Mixed Materials | Provide a Bill of Materials (BOM) showing the paper layer thickness vs. plastic layer. If paper > 50% by weight/volume, argue for Ch. 48. |
| "Impregnated" vs. "Laminated" | Impregnated (resin soaked into paper) favors Ch. 48. Laminated (thin plastic film glued to paper) may still be Ch. 48 if paper is essential character, but can be Ch. 39 if plastic dominates. |
| Customs Audit | If questioned, provide GRI 3(b) analysis: The material that gives the product its essential character (usually paper for packaging substrates) determines classification. |
| Value Declaration | Ensure CIF value is accurate. A 4% difference in base duty (0% vs ~4.8%) on high-value shipments results in significant tax variance. |
🌍 V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Rate | Certification | Remarks |
|---|---|---|---|---|
| 🇺🇸 USA | 4823.90.67.00 |
35.0% | None specific | Most favorable if paper-dominant. Avoid Ch. 39 codes if possible. |
| 🇨🇳 China | 4823.90.67.00 |
~10-13% | RoHS (if applicable) | Lower base tariff; no Section 301. |
| 🇪🇺 EU | 4823.90.67.00 |
~5-6.5% | REACH / FSC | Generally lower tariffs for paper products. |
| 🇬🇧 UK | 4823.90.67.00 |
~5-6.5% | UKCA | Post-Brexit rates similar to EU pre-Brexit for paper. |
📌 Conclusion:
- USA is the critical market with high tariffs.
- Classification as Paper (Ch. 48) saves ~4.8-5.8% in duty compared to Plastic (Ch. 39).
- Given the 10% IEEPA surcharge applies to both, the base duty difference becomes the deciding factor for cost optimization.
📌 VI. Common Mistakes & Pitfalls (Lessons Learned)
❌ Mistake 1: Calling "Impregnated Paper" a "Plastic Laminate"
👉 Consequence: Tariff jumps from 35% to 39.8% → Loss of profit margin!
❌ Mistake 2: Vague Description "Packaging Material"
👉 Consequence: Customs assigns wrong code arbitrarily, often the higher tariff one, or demands manual examination.
❌ Mistake 3: Ignoring the "Essential Character" Test
👉 Consequence: If the paper is only 10% of the volume but claimed as "Paper", customs will reclassify as Plastic and back-taxes.
✅ Correct Declaration Example:
"Impregnated Paper Base Material for Packaging, Cellulose Fiber Core, Resin Coated, Not High-Pressure Plastic Laminate, HS 4823.90.67.00"
🎯 VII. Conclusion: Precision Classification, Cost Optimization!
🎯 Remember the Mantra:
🔹 "Paper Core, Coating is Surface. Don't Let Plastic Label You Up!"
🔹 "35% vs 39.8%: A 4.8% Difference is Huge for Volume Shipments!"
🔹 "Specify 'Impregnated Paper', Not 'Plastic Composite', to Save Taxes."
📌 Pro Tip:
If your product is borderline between paper and plastic, consider applying for an Advance Ruling (Pre-classification) from US Customs and Border Protection (CBP). The cost of a ruling is minor compared to the risk of paying 39.8% instead of 35% or facing penalties.
📣 Immediate Action:
📞 Review your material composition sheet.
📊 Calculate the tax difference based on shipment volume.
🚀 If paper-based, declare under 4823.90.67.00 to maximize savings.
✨ Professional Clearance Starts with Accurate Classification!
💼 Every percentage point saved is pure profit!
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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.