Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, and chemical derivatives of cellulose. This chapter classifies plastics based on their source, processing method, and use, and is an important chapter for chemical products in international trade. Heading 3920 covers non-cellular plates, sheets, film, foil and strip of plastics, not reinforced, laminated, supported or similarly combined with other materials. This heading is further divided into subheadings based on the type of plastic (such as polyethylene, polypropylene, polystyrene, polyvinyl chloride, cellulose acetate, etc.). First 2 digits 39: Chapter 39 (Plastics and articles thereof). Digits 3-4, 20: Heading 3920, representing non-cellular plates, sheets, film, foil and strip of plastics. Digits 5-6, 73: Subheading 392073, specifically plates, sheets, film and foil of cellulose acetate. Therefore, 392073 represents non-cellular plates, sheets, film and foil of cellulose acetate. The goods are plates, sheets, film and foil made of cellulose acetate, not combined with other materials and not reinforced, falling under subheadings of heading 3920 classified by material. Since the material is cellulose acetate, they are classified under 392073, rather than other plastic subheadings (such as 392010 for polyethylene).
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, and chemical derivatives of cellulose. This chapter classifies plastics based on their source, processing method, and use, and is an important chapter for chemical products in international trade.
Heading
Heading 3920 covers non-cellular plates, sheets, film, foil and strip of plastics, not reinforced, laminated, supported or similarly combined with other materials. This heading is further divided into subheadings based on the type of plastic (such as polyethylene, polypropylene, polystyrene, polyvinyl chloride, cellulose acetate, etc.).
Digit Breakdown
First 2 digits 39: Chapter 39 (Plastics and articles thereof). Digits 3-4, 20: Heading 3920, representing non-cellular plates, sheets, film, foil and strip of plastics. Digits 5-6, 73: Subheading 392073, specifically plates, sheets, film and foil of cellulose acetate. Therefore, 392073 represents non-cellular plates, sheets, film and foil of cellulose acetate.
Classification Basis
The goods are plates, sheets, film and foil made of cellulose acetate, not combined with other materials and not reinforced, falling under subheadings of heading 3920 classified by material. Since the material is cellulose acetate, they are classified under 392073, rather than other plastic subheadings (such as 392010 for polyethylene).
📝 Declaration Elements
Product name: The specific name of the declared goods, which should include key information such as material and shape, e.g., 'film of cellulose acetate'. Material: Clearly state cellulose acetate, and if necessary, indicate whether it is plasticized or contains other components. Shape: Declare as plate, sheet, film, foil or strip, and indicate whether it is in rolls, dimensions, etc. Whether cellular: Declare whether it is cellular plastic, as cellular plastics are classified under 3921, and non-cellular under 3920. Whether combined with other materials: State whether it is reinforced, laminated, supported or similarly combined with other materials; if not, classify under 3920. Specifications and dimensions: Declare thickness, width, length, etc., to confirm whether it meets the definition of plate, sheet, film or foil. Use: Briefly describe the main use, such as for packaging, insulation, optics, etc., to assist classification. Brand or model: If there is a brand or model, it must be declared for customs identification. Product name: Film of cellulose acetate; Material: Cellulose acetate (plasticizer content 5%); Shape: Film in rolls, thickness 0.05mm, width 500mm; Whether cellular: Non-cellular; Whether combined with other materials: Not combined with other materials; Specifications and dimensions: Thickness 0.05mm, width 500mm, length 1000m/roll; Use: For food packaging; Brand: XX brand; Model: CA-100. Misreporting cellulose acetate as cellulose fiber (the latter belongs to textile materials, classified under Chapter 54). Ignoring the cellular attribute, incorrectly classifying cellular cellulose acetate under 3920, when it should actually be classified under 3921. Failing to declare whether combined with other materials; if combined, it may be classified under 3921 or other headings.
Product name
The specific name of the declared goods, which should include key information such as material and shape, e.g., 'film of cellulose acetate'.
⚠️ Writing only 'plastic film' without specifying the material, leading to classification disputes.
Material
Clearly state cellulose acetate, and if necessary, indicate whether it is plasticized or contains other components.
⚠️ Misreporting as 'cellulose fiber' or 'cellulosic plastic', failing to accurately use 'cellulose acetate'.
Shape
Declare as plate, sheet, film, foil or strip, and indicate whether it is in rolls, dimensions, etc.
⚠️ Misreporting film as 'sheet', or failing to indicate whether it is in rolls.
Whether cellular
Declare whether it is cellular plastic, as cellular plastics are classified under 3921, and non-cellular under 3920.
⚠️ Ignoring the cellular attribute, incorrectly classifying under 3920.
Whether combined with other materials
State whether it is reinforced, laminated, supported or similarly combined with other materials; if not, classify under 3920.
⚠️ Failing to declare the combination status, potentially leading to incorrect classification under 3921 or other headings.
Specifications and dimensions
Declare thickness, width, length, etc., to confirm whether it meets the definition of plate, sheet, film or foil.
⚠️ Incomplete specification description, making it impossible to determine whether it is strip or film.
Use
Briefly describe the main use, such as for packaging, insulation, optics, etc., to assist classification.
⚠️ Use description too general, such as 'industrial use'.
Brand or model
If there is a brand or model, it must be declared for customs identification.
⚠️ Omitting brand and model, affecting inspection.
Example： Product name: Film of cellulose acetate; Material: Cellulose acetate (plasticizer content 5%); Shape: Film in rolls, thickness 0.05mm, width 500mm; Whether cellular: Non-cellular; Whether combined with other materials: Not combined with other materials; Specifications and dimensions: Thickness 0.05mm, width 500mm, length 1000m/roll; Use: For food packaging; Brand: XX brand; Model: CA-100.
Common Mistakes：
Misreporting cellulose acetate as cellulose fiber (the latter belongs to textile materials, classified under Chapter 54).
Ignoring the cellular attribute, incorrectly classifying cellular cellulose acetate under 3920, when it should actually be classified under 3921.
Failing to declare whether combined with other materials; if combined, it may be classified under 3921 or other headings.
🎯 Classification Logic
Core basis for classification: 1) Material is cellulose acetate; 2) Shape is plate, sheet, film, foil or strip; 3) Non-cellular; 4) Not reinforced, laminated, supported or similarly combined with other materials. Only when all the above conditions are met is it classified under 392073. If cellular or combined, it is classified under 3921. 392071 Plates, sheets, film and foil of regenerated cellulose: Material is regenerated cellulose (such as cellophane), not cellulose acetate. Cellulose acetate is cellulose acetate ester, and the two have different chemical structures. 392079 Plates, sheets, film and foil of other cellulose derivatives: Material is other cellulose derivatives (such as cellulose nitrate, carboxymethyl cellulose), not cellulose acetate. 392010 Plates, sheets, film and foil of polyethylene: Material is polyethylene, an ethylene polymer, completely different from cellulose acetate. 392112 Cellular plates, sheets, film and foil of vinyl chloride polymers: Material is vinyl chloride polymer and is cellular, whereas 392073 is non-cellular cellulose acetate. 391211 Non-plasticized cellulose acetate in primary forms: Shape is primary form (such as powder, granules), not plates, sheets, film or foil. Is the material cellulose acetate? Is it non-cellular? Is it not combined with other materials? Is the shape plate, sheet, film, foil or strip? Is it not in primary form?
Basis
Core basis for classification: 1) Material is cellulose acetate; 2) Shape is plate, sheet, film, foil or strip; 3) Non-cellular; 4) Not reinforced, laminated, supported or similarly combined with other materials. Only when all the above conditions are met is it classified under 392073. If cellular or combined, it is classified under 3921.
Confused Codes：
392071 - Plates, sheets, film and foil of regenerated cellulose
Material is regenerated cellulose (such as cellophane), not cellulose acetate. Cellulose acetate is cellulose acetate ester, and the two have different chemical structures.
392079 - Plates, sheets, film and foil of other cellulose derivatives
Material is other cellulose derivatives (such as cellulose nitrate, carboxymethyl cellulose), not cellulose acetate.
392010 - Plates, sheets, film and foil of polyethylene
Material is polyethylene, an ethylene polymer, completely different from cellulose acetate.
392112 - Cellular plates, sheets, film and foil of vinyl chloride polymers
Material is vinyl chloride polymer and is cellular, whereas 392073 is non-cellular cellulose acetate.
391211 - Non-plasticized cellulose acetate in primary forms
Shape is primary form (such as powder, granules), not plates, sheets, film or foil.
Self-Check：
✓ Is the material cellulose acetate?
✓ Is it non-cellular?
✓ Is it not combined with other materials?
✓ Is the shape plate, sheet, film, foil or strip?
✓ Is it not in primary form?
❓ FAQ
How to inquire about the import tariff rate for 392073? You can log on to the official website of the General Administration of Customs of China or use the 'Customs Import and Export Tariff' to inquire. Enter HS code 392073, and the system will display the MFN rate, general rate, VAT rate, etc. Note that tariff rates may be adjusted with policy changes, and it is recommended to refer to the latest published version. What are the differences in classification and declaration between cellulose acetate film and regenerated cellulose film (cellophane)? Cellulose acetate film is classified under 392073, and regenerated cellulose film under 392071. When declaring, the material must be clearly stated. Cellulose acetate is cellulose acetate ester, and regenerated cellulose is regenerated by the viscose process. They look similar but have different chemical compositions and can be identified by infrared spectroscopy. If cellulose acetate plates, sheets, film and foil are cellular, which code should they be classified under? Cellular cellulose acetate plates, sheets, film and foil should be classified under heading 3921, specifically subheading 392119 (cellular plates, sheets, film and foil of other plastics). When declaring, the 'cellular' attribute must be indicated to avoid incorrect classification under 392073. How should cellulose acetate film combined with other plastic films be classified? If combined with other materials (such as lamination, reinforcement), it is no longer classified under 3920 but under 3921 (plates, sheets, film and foil of other plastics). For example, cellulose acetate film laminated with aluminum foil should be classified under 3921. When declaring, the combination status must be indicated. Among the declaration elements for cellulose acetate plates, sheets, film and foil, which are most prone to errors? Common errors include: material misreported as 'cellulose fiber', failure to declare whether cellular, failure to indicate whether combined with other materials, and incomplete specifications and dimensions. It is recommended to fill in each item strictly according to the tariff requirements to ensure accurate classification. From the perspective of customs classification, does the thickness of cellulose acetate film affect classification? Heading 3920 does not set a thickness limit, but thickness affects the definition as 'film' or 'sheet'. Generally, thickness less than 0.25mm is called film, and greater may be regarded as sheet. However, classification is mainly based on material and shape, and thickness is only an auxiliary reference. What is the export tax rebate rate for cellulose acetate plates, sheets, film and foil? The export tax rebate rate needs to be inquired in the latest export tax rebate policy. You can refer to the export tax rebate rate library published by the State Taxation Administration. Generally, cellulose acetate products may have different rebate rates, and it is recommended to refer to official data. If cellulose acetate film is used in the optical field, are there special provisions for classification? Classification is mainly based on material and shape, and use usually does not affect heading attribution, unless the goods have characteristics of other chapters (such as optical elements). If it is only used as film, it is still classified under 392073. However, if it is specially processed into an optical element, it may be classified under Chapter 90.
Q: How to inquire about the import tariff rate for 392073?
A: You can log on to the official website of the General Administration of Customs of China or use the 'Customs Import and Export Tariff' to inquire. Enter HS code 392073, and the system will display the MFN rate, general rate, VAT rate, etc. Note that tariff rates may be adjusted with policy changes, and it is recommended to refer to the latest published version.
Q: What are the differences in classification and declaration between cellulose acetate film and regenerated cellulose film (cellophane)?
A: Cellulose acetate film is classified under 392073, and regenerated cellulose film under 392071. When declaring, the material must be clearly stated. Cellulose acetate is cellulose acetate ester, and regenerated cellulose is regenerated by the viscose process. They look similar but have different chemical compositions and can be identified by infrared spectroscopy.
Q: If cellulose acetate plates, sheets, film and foil are cellular, which code should they be classified under?
A: Cellular cellulose acetate plates, sheets, film and foil should be classified under heading 3921, specifically subheading 392119 (cellular plates, sheets, film and foil of other plastics). When declaring, the 'cellular' attribute must be indicated to avoid incorrect classification under 392073.
Q: How should cellulose acetate film combined with other plastic films be classified?
A: If combined with other materials (such as lamination, reinforcement), it is no longer classified under 3920 but under 3921 (plates, sheets, film and foil of other plastics). For example, cellulose acetate film laminated with aluminum foil should be classified under 3921. When declaring, the combination status must be indicated.
Q: Among the declaration elements for cellulose acetate plates, sheets, film and foil, which are most prone to errors?
A: Common errors include: material misreported as 'cellulose fiber', failure to declare whether cellular, failure to indicate whether combined with other materials, and incomplete specifications and dimensions. It is recommended to fill in each item strictly according to the tariff requirements to ensure accurate classification.
Q: From the perspective of customs classification, does the thickness of cellulose acetate film affect classification?
A: Heading 3920 does not set a thickness limit, but thickness affects the definition as 'film' or 'sheet'. Generally, thickness less than 0.25mm is called film, and greater may be regarded as sheet. However, classification is mainly based on material and shape, and thickness is only an auxiliary reference.
Q: What is the export tax rebate rate for cellulose acetate plates, sheets, film and foil?
A: The export tax rebate rate needs to be inquired in the latest export tax rebate policy. You can refer to the export tax rebate rate library published by the State Taxation Administration. Generally, cellulose acetate products may have different rebate rates, and it is recommended to refer to official data.
Q: If cellulose acetate film is used in the optical field, are there special provisions for classification?
A: Classification is mainly based on material and shape, and use usually does not affect heading attribution, unless the goods have characteristics of other chapters (such as optical elements). If it is only used as film, it is still classified under 392073. However, if it is specially processed into an optical element, it may be classified under Chapter 90.
⚠️ 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.