Chapter 39 covers plastics and articles thereof, including plastics in primary forms, synthetic resins, cellulose and its chemical derivatives, natural polymers, etc. This chapter is divided into two subchapters according to the form and processing stage of plastics: Subchapter I covers primary forms, and Subchapter II covers semi-manufactures and articles. Regenerated cellulose is a chemically modified natural polymer and therefore falls under this chapter. Heading 3920 covers plates, sheets, film, foil and strip of other non-cellular plastics, not reinforced, laminated, supported or similarly combined with other materials. This heading includes plates, sheets, film and foil of plastics such as polyethylene, polypropylene, polystyrene, polyvinyl chloride, polyethylene terephthalate, as well as similar products made of regenerated cellulose. The first 2 digits 39 represent Chapter 39, plastics and articles thereof; digits 3-4, 20, represent heading 3920, namely plates, sheets, film, foil and strip of other non-cellular plastics; digits 5-6, 71, represent subheading 3920.71, specifically plates, sheets, film and foil of regenerated cellulose. Regenerated cellulose is a cellulose material obtained by regeneration through the cellulose xanthate process or the cuprammonium process, with common commercial products such as cellophane. This subheading includes only products made of regenerated cellulose and does not include products made of cellulose derivatives such as cellulose acetate. The goods are plates, sheets, film and foil made of regenerated cellulose, belonging to semi-manufactures of non-cellular plastics, and the material is regenerated cellulose, which conforms to the description of heading 3920. The adjacent codes 3920.10 to 3920.69 correspond respectively to other plastic materials, while 3920.71 specifically targets regenerated cellulose, so this code is preferred over other plastic subheadings or cellulose derivative subheadings.
Chapter
Chapter 39 covers plastics and articles thereof, including plastics in primary forms, synthetic resins, cellulose and its chemical derivatives, natural polymers, etc. This chapter is divided into two subchapters according to the form and processing stage of plastics: Subchapter I covers primary forms, and Subchapter II covers semi-manufactures and articles. Regenerated cellulose is a chemically modified natural polymer and therefore falls under this chapter.
Heading
Heading 3920 covers plates, sheets, film, foil and strip of other non-cellular plastics, not reinforced, laminated, supported or similarly combined with other materials. This heading includes plates, sheets, film and foil of plastics such as polyethylene, polypropylene, polystyrene, polyvinyl chloride, polyethylene terephthalate, as well as similar products made of regenerated cellulose.
Digit Breakdown
The first 2 digits 39 represent Chapter 39, plastics and articles thereof; digits 3-4, 20, represent heading 3920, namely plates, sheets, film, foil and strip of other non-cellular plastics; digits 5-6, 71, represent subheading 3920.71, specifically plates, sheets, film and foil of regenerated cellulose. Regenerated cellulose is a cellulose material obtained by regeneration through the cellulose xanthate process or the cuprammonium process, with common commercial products such as cellophane. This subheading includes only products made of regenerated cellulose and does not include products made of cellulose derivatives such as cellulose acetate.
Classification Basis
The goods are plates, sheets, film and foil made of regenerated cellulose, belonging to semi-manufactures of non-cellular plastics, and the material is regenerated cellulose, which conforms to the description of heading 3920. The adjacent codes 3920.10 to 3920.69 correspond respectively to other plastic materials, while 3920.71 specifically targets regenerated cellulose, so this code is preferred over other plastic subheadings or cellulose derivative subheadings.
📝 Declaration Elements
Product name: The specific name of the declared goods, which should include material and form, such as "film made of regenerated cellulose". Material: Clearly state regenerated cellulose, and the process may be noted, such as "regenerated cellulose by viscose process". Specifications and dimensions: Declare thickness, width, length, etc., such as thickness 0.02 mm, width 1000 mm. Appearance: Describe color, transparency, gloss, etc., such as "transparent colorless film". Use: State the main use, such as "for food packaging, pharmaceutical packaging". Whether reinforced: Declare whether it is reinforced, laminated or supported with other materials, such as "not reinforced". Density: If available, provide the density value, such as 1.45 g/cm³. Brand or model: If there is a brand or model, it must be declared, such as "Brand XX, model YY". Example of customs declaration: Product name: film made of regenerated cellulose; Material: regenerated cellulose (viscose process); Specifications and dimensions: thickness 0.02 mm, width 1200 mm, length 5000 m; Appearance: transparent colorless; Use: for food packaging; Whether reinforced: not reinforced; Density: 1.45 g/cm³; Brand: none. Misreporting regenerated cellulose as cellulose acetate, resulting in classification under 3920.73 or 3912. Failure to distinguish whether it is reinforced; if reinforced, it may be classified under 3921. Incomplete declaration of specifications and dimensions, affecting customs valuation and classification.
Product name
The specific name of the declared goods, which should include material and form, such as "film made of regenerated cellulose".
⚠️ Writing only "film" without indicating the material, or incorrectly writing "cellophane" without stating regenerated cellulose.
Material
Clearly state regenerated cellulose, and the process may be noted, such as "regenerated cellulose by viscose process".
⚠️ Misreporting as cellulose acetate, nitrocellulose or other plastics.
Specifications and dimensions
Declare thickness, width, length, etc., such as thickness 0.02 mm, width 1000 mm.
⚠️ Providing only width without thickness, or using non-standard units of measurement.
Appearance
Describe color, transparency, gloss, etc., such as "transparent colorless film".
⚠️ Omitting the appearance description, or it is inconsistent with the actual goods.
Use
State the main use, such as "for food packaging, pharmaceutical packaging".
⚠️ The use description is too broad, such as "industrial use".
Whether reinforced
Declare whether it is reinforced, laminated or supported with other materials, such as "not reinforced".
⚠️ Misreporting as reinforced, resulting in classification under another heading.
Density
If available, provide the density value, such as 1.45 g/cm³.
⚠️ Ignoring density, or providing an incorrect value.
Brand or model
If there is a brand or model, it must be declared, such as "Brand XX, model YY".
⚠️ If there is no brand, fill in "none", but mistakenly filling in other information.
Example： Example of customs declaration: Product name: film made of regenerated cellulose; Material: regenerated cellulose (viscose process); Specifications and dimensions: thickness 0.02 mm, width 1200 mm, length 5000 m; Appearance: transparent colorless; Use: for food packaging; Whether reinforced: not reinforced; Density: 1.45 g/cm³; Brand: none.
Common Mistakes：
Misreporting regenerated cellulose as cellulose acetate, resulting in classification under 3920.73 or 3912.
Failure to distinguish whether it is reinforced; if reinforced, it may be classified under 3921.
Incomplete declaration of specifications and dimensions, affecting customs valuation and classification.
🎯 Classification Logic
The core basis for classification is whether the material of the goods is regenerated cellulose and whether the form is plates, sheets, film or foil of non-cellular plastics. Regenerated cellulose is a material obtained by chemically regenerating natural cellulose; its molecular structure is cellulose, but it has undergone a dissolution and regeneration process. According to the Import and Export Tariff, 3920.71 specifically refers to plates, sheets, film and foil of regenerated cellulose and must meet conditions such as not being reinforced or laminated. If it is a cellulose derivative such as cellulose acetate, it is classified under subheadings such as 3920.73. 3920.73 Plates, sheets, film and foil of cellulose acetate: The material is cellulose acetate, which is a cellulose derivative, not regenerated cellulose. Regenerated cellulose retains the cellulose chemical structure, while cellulose acetate is an esterification product. 3921.13 Plates, sheets, film and foil of cellular plastics made of regenerated cellulose: 3921 covers plates, sheets, film and foil of cellular plastics or reinforced, laminated, etc. plastics. If the regenerated cellulose product is cellular or reinforced, it is classified under 3921. 3912.11 Regenerated cellulose in primary forms: 3912 covers cellulose and its chemical derivatives in primary forms, such as non-plasticized regenerated cellulose. 3920.71 covers semi-manufactured plates, sheets, film and foil, which have been formed. 4823.20 Cellophane (made of regenerated cellulose): If cellophane is in rolls and used for packaging, it may be classified under 4823; but 3920.71 covers plates, sheets, film and foil, usually not printed or cut into specific shapes. Is the material regenerated cellulose? Is it non-cellular plastic? Is it not reinforced or laminated with other materials? Is it in the form of plates, sheets, film or foil? Has it not been cut into articles listed under other headings?
Basis
The core basis for classification is whether the material of the goods is regenerated cellulose and whether the form is plates, sheets, film or foil of non-cellular plastics. Regenerated cellulose is a material obtained by chemically regenerating natural cellulose; its molecular structure is cellulose, but it has undergone a dissolution and regeneration process. According to the Import and Export Tariff, 3920.71 specifically refers to plates, sheets, film and foil of regenerated cellulose and must meet conditions such as not being reinforced or laminated. If it is a cellulose derivative such as cellulose acetate, it is classified under subheadings such as 3920.73.
Confused Codes：
3920.73 - Plates, sheets, film and foil of cellulose acetate
The material is cellulose acetate, which is a cellulose derivative, not regenerated cellulose. Regenerated cellulose retains the cellulose chemical structure, while cellulose acetate is an esterification product.
3921.13 - Plates, sheets, film and foil of cellular plastics made of regenerated cellulose
3921 covers plates, sheets, film and foil of cellular plastics or reinforced, laminated, etc. plastics. If the regenerated cellulose product is cellular or reinforced, it is classified under 3921.
3912.11 - Regenerated cellulose in primary forms
3912 covers cellulose and its chemical derivatives in primary forms, such as non-plasticized regenerated cellulose. 3920.71 covers semi-manufactured plates, sheets, film and foil, which have been formed.
4823.20 - Cellophane (made of regenerated cellulose)
If cellophane is in rolls and used for packaging, it may be classified under 4823; but 3920.71 covers plates, sheets, film and foil, usually not printed or cut into specific shapes.
Self-Check：
✓ Is the material regenerated cellulose?
✓ Is it non-cellular plastic?
✓ Is it not reinforced or laminated with other materials?
✓ Is it in the form of plates, sheets, film or foil?
✓ Has it not been cut into articles listed under other headings?
❓ FAQ
Are film made of regenerated cellulose and cellophane the same thing? Is the HS code the same? Cellophane is usually a common name for regenerated cellulose film, but the HS code must be determined according to the specific form and processing. If it is unreinforced film in rolls, it is classified under 3920.71; if it has been printed or cut into specific sizes for packaging, it may be classified under 4823. It is recommended to declare according to the actual state. How to distinguish regenerated cellulose from cellulose acetate? Regenerated cellulose is obtained by dissolving and regenerating natural cellulose through the viscose process or cuprammonium process, and its chemical structure remains cellulose; cellulose acetate is an esterification product obtained by reacting cellulose with acetic anhydride. They can be distinguished by infrared spectroscopy or chemical testing, and material proof must be provided at the time of declaration. If regenerated cellulose film is coated, can it still be classified under 3920.71? If the coating is only a surface treatment (such as a moisture-proof coating) and does not change the essential characteristics, it may still be classified under 3920.71; but if the coating constitutes reinforcement or lamination, it may be classified under 3921. This must be judged according to the coating material and process. Among the declaration elements for regenerated cellulose film, is density mandatory? Density is not mandatory in all cases, but it is recommended to provide it because density is an important parameter for distinguishing materials. If it cannot be provided, "not determined" may be stated, but this may affect customs classification. When importing regenerated cellulose film, how can the tariff rate be checked? You can log on to the website of the General Administration of Customs of China or use the Customs Tariff to check by entering HS code 3920.71 and viewing the MFN rate, general rate, etc. Rates may change, so the latest tariff should prevail. If regenerated cellulose film is used for food packaging, what additional documents are required? Materials used for food contact require test reports complying with national food safety standards, such as GB 4806.8. Customs may require relevant declarations or certificates. What is the difference between the HS codes for regenerated cellulose film and polyethylene film? Polyethylene film is classified under 3920.10 (polymers of ethylene), while regenerated cellulose film is classified under 3920.71. The materials are different, and classification must be distinguished by material. If regenerated cellulose film is in rolls but the width is less than 5 mm, is it still classified under 3920.71? According to the tariff, 3920 includes strip, but only that exceeding 5 mm in width is regarded as plates, sheets, film and foil. If the width is less than 5 mm, it is usually regarded as yarn or strip and classified under 3916 or 5404, etc. The specific dimensions must be confirmed.
Q: Are film made of regenerated cellulose and cellophane the same thing? Is the HS code the same?
A: Cellophane is usually a common name for regenerated cellulose film, but the HS code must be determined according to the specific form and processing. If it is unreinforced film in rolls, it is classified under 3920.71; if it has been printed or cut into specific sizes for packaging, it may be classified under 4823. It is recommended to declare according to the actual state.
Q: How to distinguish regenerated cellulose from cellulose acetate?
A: Regenerated cellulose is obtained by dissolving and regenerating natural cellulose through the viscose process or cuprammonium process, and its chemical structure remains cellulose; cellulose acetate is an esterification product obtained by reacting cellulose with acetic anhydride. They can be distinguished by infrared spectroscopy or chemical testing, and material proof must be provided at the time of declaration.
Q: If regenerated cellulose film is coated, can it still be classified under 3920.71?
A: If the coating is only a surface treatment (such as a moisture-proof coating) and does not change the essential characteristics, it may still be classified under 3920.71; but if the coating constitutes reinforcement or lamination, it may be classified under 3921. This must be judged according to the coating material and process.
Q: Among the declaration elements for regenerated cellulose film, is density mandatory?
A: Density is not mandatory in all cases, but it is recommended to provide it because density is an important parameter for distinguishing materials. If it cannot be provided, "not determined" may be stated, but this may affect customs classification.
Q: When importing regenerated cellulose film, how can the tariff rate be checked?
A: You can log on to the website of the General Administration of Customs of China or use the Customs Tariff to check by entering HS code 3920.71 and viewing the MFN rate, general rate, etc. Rates may change, so the latest tariff should prevail.
Q: If regenerated cellulose film is used for food packaging, what additional documents are required?
A: Materials used for food contact require test reports complying with national food safety standards, such as GB 4806.8. Customs may require relevant declarations or certificates.
Q: What is the difference between the HS codes for regenerated cellulose film and polyethylene film?
A: Polyethylene film is classified under 3920.10 (polymers of ethylene), while regenerated cellulose film is classified under 3920.71. The materials are different, and classification must be distinguished by material.
Q: If regenerated cellulose film is in rolls but the width is less than 5 mm, is it still classified under 3920.71?
A: According to the tariff, 3920 includes strip, but only that exceeding 5 mm in width is regarded as plates, sheets, film and foil. If the width is less than 5 mm, it is usually regarded as yarn or strip and classified under 3916 or 5404, etc. The specific dimensions must be confirmed.
⚠️ Disclaimer: HS code classification, declaration elements, tariff rates and regulatory conditions on this page are for reference only and do not constitute legal advice on customs classification. Tariff rates and regulations are subject to change; the latest announcements from the General Administration of Customs and on-site determinations shall prevail. Please consult professional customs brokers or customs authorities before import/export.