聚酯建筑箔
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3921190090 | 41.5% | CN | US | Official Doc |
| 3907995010 | 41.5% | CN | US | Official Doc |
| 3907995050 | 41.5% | CN | US | Official Doc |
| 3921190090 | 41.5% | CN | US | Official Doc |
| 3907995010 | 41.5% | CN | US | Official Doc |
AI Analysis
🏗️ Polyester Building Foil (Architectural & Industrial Films)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Entry Strategy
📌 I. Product Definition & Classification: Do You Really Understand "Polyester Building Foil"?
Polyester Building Foil (also known as Polyester Capacitor Foil or PET Film in broader contexts, but specifically classified here as foil used in construction/electrical components) refers to thin, high-strength polyester sheets. In the context of the provided data, these are specifically "Polyester Capacitor Foils" (聚酯电容器箔) used as intermediate materials or raw components for electrical and building-related electronic systems.
In international trade, classification depends heavily on the form (foil vs. finished product) and material state:
1. Foil Form (Raw/Intermediate):
- Thin, rolled sheets without complex assembly.
- Used as substrates or conductive layers in capacitors, insulation, or architectural films.
- Key Characteristic: "Foil" status, often semi-finished.
2. Material Composition:
- Polyester (PET): A synthetic polymer known for high tensile strength, thermal stability, and electrical insulation properties.
⚠️ Critical Distinction:
- If the product is a raw foil roll or semi-finished sheet for capacitors/electrical use → It is classified under Chapter 39 (Plastics and Articles Thereof).
- If it were a finished capacitor or wiring harness, it would fall under Chapter 85.
- Do not confuse with aluminum foil (Chapter 76); this is specifically polyester.
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Mapping)
Based on the provided data, the product falls into three specific sub-categories under Chapter 39 (Plastics). All are subject to the same total tax rate but differ slightly in descriptive emphasis.
| HS Code | Product Description | Key Characteristics | Application Context |
|---|---|---|---|
3921.19.00.90 |
Polyester Capacitor Foil, Foil Form, Polyester Material | Classified as "Other plastics products"; emphasizes the physical form (foil) | General electrical insulation, architectural film substrates |
3907.99.50.10 |
Polyester Capacitor Foil, Polymer Form, Primary/Semi-finished | Classified as "Other polyesters"; emphasizes chemical form (primary/semi-finished) | Raw material for manufacturing capacitors or films |
3907.99.50.50 |
Polyester Capacitor Foil, Common Intermediate Form | Classified as "Other polyester products"; emphasizes commercial status as intermediate | Standard industrial supply chain intermediate |
🔍 Key Reminder:
- All three HS Codes apply to Polyester (PET) Foil.
- The difference lies in how customs views the state of manufacture:
-3921: Focuses on it being a plastic article (foil).
-3907: Focuses on it being a polymer product (unwound film/foil).
- Total Tax Rate is Identical (41.5%) for all three under current US-China trade rules.
💰 III. 2026 Latest Tariff Rate Breakdown (Including Additional Taxes & Policy Surcharges)
✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN)
✅ Effective Date: From November 10, 2025 (and subsequent imports)
🎯 1. 3921.19.00.90 – Polyester Capacitor Foil (Foil Form)
| Item | Details |
|---|---|
| Base Tariff | 6.5% (ad valorem) |
| Section 301 Surcharge | +25.0% (USITC Footnote for Section 301) |
| Section 122 Surcharge | +10.0% (Specific Chinese-origin policy surcharge) |
| Total Tax Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Eligibility | ❌ NO (Section 301 & 122 taxes apply fully) |
| Legal Path | USITC:3921.19.00.90 → Section 301: 25% → Section 122: 10% |
📌 Explanation:
- The 6.5% is the standard Most Favored Nation (MFN) rate for polyester foils.
- The 25% is the ongoing tariff from the Section 301 investigation (Trade War tariffs).
- The 10% is an additional surcharge under Section 122, targeting specific Chinese-origin plastics/polyester products.
- Combined Total: 41.5% – This is a high-cost barrier that must be factored into pricing.
🎯 2. 3907.99.50.10 – Polyester Capacitor Foil (Primary/Semi-finished Form)
| Item | Details |
|---|---|
| Base Tariff | 6.5% |
| Section 301 Surcharge | +25.0% |
| Section 122 Surcharge | +10.0% |
| Total Tax Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Eligibility | ❌ NO |
| Legal Path | USITC:3907.99.50.10 → Section 301: 25% → Section 122: 10% |
📌 Note:
- Same tax structure as above.
- Customs may scrutinize whether the product is truly "primary form" (unprocessed resin/film) vs. "finished foil." Ensure documentation reflects semi-finished status.
🎯 3. 3907.99.50.50 – Polyester Capacitor Foil (Intermediate Form)
| Item | Details |
|---|---|
| Base Tariff | 6.5% |
| Section 301 Surcharge | +25.0% |
| Section 122 Surcharge | +10.0% |
| Total Tax Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Eligibility | ❌ NO |
| Legal Path | USITC:3907.99.50.50 → Section 301: 25% → Section 122: 10% |
📌 Note:
- This code is used when the product is considered a common intermediate in the polyester supply chain.
- No tax advantage over the other two codes.
🛠️ IV. Customs Clearance Practical Advice (Risk Avoidance Guide)
✅ 1. Required Documentation Checklist (Mandatory)
| Document | Required? | Purpose |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must specify: Material (100% Polyester), Form (Film/Foil), Thickness, Width, Tensile Strength |
| ✅ Commercial Invoice | ✔️ | Clearly state: "Polyester Capacitor Foil, Not for Consumer Use, Intermediate Material" |
| ✅ Packing List | ✔️ | Detail roll dimensions, weight, and packaging type (avoid "mixed" shipments) |
| ✅ Certificate of Origin (CO) | ✔️ | Essential for proving Chinese origin to apply correct Section 301/122 rates |
| ✅ HS Code Pre-Ruling (Optional but Recommended) | ✔️ | Submit to CBP to confirm 3921.19.00.90 vs 3907.99.50.10 before shipment |
✅ 2. Declaration Tips (Key Mnemonic)
🔥 "Foil vs. Film, Form Matters! 41.5% Tax, No Escape!"
| Scenario | Correct Declaration | Incorrect Declaration |
|---|---|---|
| Raw Polyester Foil Rolls | 3907.99.50.10 or 3921.19.00.90 |
Declare as "Finished Capacitor" → 8542.31.00.00 (Higher scrutiny) |
| Semi-finished PET Film | 3907.99.50.50 |
Declare as "Plastic Sheet for Construction" → Risk of reclassification |
| Aluminum Foil (Mistaken Identity) | ❌ Wrong Product | Declare as 7607.11.00.00 → Penalty for Misdeclaration |
| Mixed Package (Foils + Accessories) | Split Declaration | Bundle together → Delayed Release + Audit |
✅ 3. Special Considerations
| Situation | Handling Advice |
|---|---|
| OEM Custom Foils | Provide customer PO and technical drawings to prove "intermediate" status |
| Re-export from Third Country | If re-exported from Vietnam/Mexico, may qualify for lower tariffs if substantial transformation occurred |
| Small Sample Shipments | No De Minimis Exemption for Section 301/122 taxes. Even $100 samples incur 41.5% tax |
| Dual-Use Concerns | Ensure documentation does not imply "military use" if not applicable, to avoid additional export controls |
🌍 V. Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Remarks |
|---|---|---|---|---|
| 🇺🇸 USA | 3921.19.00.90 |
41.5% (6.5% + 25% + 10%) | None specific | High tariff barrier; plan pricing accordingly |
| 🇨🇳 China | 3921.19.00.90 |
6.5% | CCC (if applicable) | Base rate only; no surcharges |
| 🇪🇺 EU | 3920.62.00.00 |
6.5% | CE | Lower tariffs than US; no Section 301 equivalent |
| 🇬🇧 UK | 3920.62.00.00 |
6.5% | UKCA | Post-Brexit alignment with EU |
| 🇯🇵 Japan | 3920.62.00.00 |
6.5% | PSE | Stable trade relations |
📌 Conclusion:
- USA is the most challenging market due to the 41.5% cumulative tariff.
- China, EU, UK, Japan apply base rates (~6.5%), making them more cost-effective for polyester foil exports.
- Strategy: Consider transshipment or third-country assembly if targeting the US market extensively.
📌 VI. Common Errors & Pitfalls (Lessons Learned)
❌ Error 1: Misdeclaring "Polyester Foil" as "Plastic Sheet for Packaging"
👉 Consequence: Incorrect HS Code → Audits & Penalties
❌ Error 2: Assuming De Minimis Exemption Applies
👉 Consequence: Section 301/122 taxes do not apply to de minimis. All shipments incur 41.5% tax.
❌ Error 3: Confusing "Polyester Foil" with "Aluminum Foil"
👉 Consequence: Wrong HS Code → Seizure or Return
❌ Error 4: Omitting "Capacitor Foil" Description
👉 Consequence: Customs may classify as generic plastic film → Uncertainty & Delays
✅ Correct Approach:
"Polyester Capacitor Foil, 12μm, 1000m Roll, For Electrical Insulation, Made in China, HS Code 3921.19.00.90"
🎯 VII. Conclusion: Precision in Classification Saves Money
🎯 Remember This Mantra:
🔹 "Polyester Foil, Not Aluminum, 41.5% Tax in the US!"
🔹 "Base 6.5% + 301 25% + 122 10% = No Escape!"
🔹 "Pre-Rule HS Code, Avoid Delays, Save Time and Cost!"
📌 Pro Tip:
If your polyester foil is originally from Vietnam, Thailand, or Malaysia, you may qualify for lower or zero tariffs under Free Trade Agreements (FTAs).
✅ Recommendation: Apply for Advance Ruling with CBP before shipping to confirm HS Code and tax liability.
📣 Immediate Action:
📞 Contact a licensed customs broker + Provide product specs + Request HS Code Pre-Ruling
🚀 Ensure smooth customs clearance, minimize tariffs, maximize profits!
✨ Professional Clearance Starts with Accurate Classification!
💼 Every percentage point of tax matters in global trade!
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.