Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, cellulose and its chemical derivatives, natural polymers, etc. This chapter is classified by polymer type and product form (such as plates, sheets, film, foil, strips, etc.), and is the core chapter for classifying plastic commodities in international trade. Heading 3920 covers other plates, sheets, film, foil and strip, of non-cellular plastics, not reinforced, laminated, supported or similarly combined with other materials. This heading covers semi-finished products of various plastic materials, such as film and sheet made of polyethylene, polypropylene, polystyrene, etc., widely used in packaging, construction, electronics and other fields. First 2 digits 39: indicates Chapter 39 (Plastics and articles thereof). Digits 3-4, 20: indicates heading 3920 (Other plates, sheets, film, foil and strip, of non-cellular plastics). Digits 5-6, 91: indicates subheading 3920.91, specifically plates, sheets, film, foil of poly(vinyl butyral) (PVB). This subheading further distinguishes PVB from other plastic materials, facilitating customs statistics and trade control. The goods are plates, sheets, film, foil made of poly(vinyl butyral) (PVB), which are semi-finished products of non-cellular plastics, not reinforced or laminated with other materials, meeting the description of heading 3920. Meanwhile, PVB is a specific polymer, so it is classified under subheading 3920.91, rather than other plastic subheadings (such as 3920.10 of polymers of ethylene).
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, cellulose and its chemical derivatives, natural polymers, etc. This chapter is classified by polymer type and product form (such as plates, sheets, film, foil, strips, etc.), and is the core chapter for classifying plastic commodities in international trade.
Heading
Heading 3920 covers other plates, sheets, film, foil and strip, of non-cellular plastics, not reinforced, laminated, supported or similarly combined with other materials. This heading covers semi-finished products of various plastic materials, such as film and sheet made of polyethylene, polypropylene, polystyrene, etc., widely used in packaging, construction, electronics and other fields.
Digit Breakdown
First 2 digits 39: indicates Chapter 39 (Plastics and articles thereof). Digits 3-4, 20: indicates heading 3920 (Other plates, sheets, film, foil and strip, of non-cellular plastics). Digits 5-6, 91: indicates subheading 3920.91, specifically plates, sheets, film, foil of poly(vinyl butyral) (PVB). This subheading further distinguishes PVB from other plastic materials, facilitating customs statistics and trade control.
Classification Basis
The goods are plates, sheets, film, foil made of poly(vinyl butyral) (PVB), which are semi-finished products of non-cellular plastics, not reinforced or laminated with other materials, meeting the description of heading 3920. Meanwhile, PVB is a specific polymer, so it is classified under subheading 3920.91, rather than other plastic subheadings (such as 3920.10 of polymers of ethylene).
📝 Declaration Elements
Product Name: The specific name of the declared commodity, such as "poly(vinyl butyral) film" or "PVB film". Material: Indicate poly(vinyl butyral) (PVB) and its content, such as "PVB content ≥95%". Appearance: Describe color, transparency, shape (roll, sheet, etc.). Specifications and Dimensions: Thickness, width, length, etc., such as "thickness 0.38mm, width 1000mm". Use: Main use, such as "used for laminated automotive safety glass". Brand or Model: If there is a brand or model, it needs to be declared, such as "Eastman Saflex". Whether Combined with Other Materials: Declare whether it is laminated, reinforced, etc. with other materials, such as "not combined with other materials". Product Name: poly(vinyl butyral) film; Material: PVB content 99%; Appearance: transparent roll; Specifications and Dimensions: thickness 0.38mm, width 1000mm, length 500m; Use: laminated automotive safety glass; Brand: Eastman; Model: Saflex RB11; Whether Combined with Other Materials: No. Confusing PVB film with PVB resin, the latter is classified under 3905. Not specifying whether combined with other materials; if laminated, it may be classified under 3921. Inaccurate declaration of thickness, affecting subheading determination. Use description too broad, may trigger customs questioning.
Product Name
The specific name of the declared commodity, such as "poly(vinyl butyral) film" or "PVB film".
⚠️ Mistakenly written as "plastic film" or "PVB resin", without specifying the form.
Material
Indicate poly(vinyl butyral) (PVB) and its content, such as "PVB content ≥95%".
⚠️ Only writing "plastic" or "PVB", without stating the content.
Confusing PVB film with PVB resin, the latter is classified under 3905.
Not specifying whether combined with other materials; if laminated, it may be classified under 3921.
Inaccurate declaration of thickness, affecting subheading determination.
Use description too broad, may trigger customs questioning.
🎯 Classification Logic
Classification basis: The goods are non-cellular plastic plates, sheets, film, foil made of poly(vinyl butyral) (PVB), not reinforced or laminated with other materials, meeting the notes to Chapter 39 and the text of heading 3920 of the Tariff. According to the subheading structure, products made of PVB are classified under 3920.91. Key review points include material, form, and whether combined with other materials. 392010 Plates, sheets, film, foil of polymers of ethylene: Material is polyethylene, not PVB. PVB has unique adhesion and optical properties, used for safety glass. 392190 Plates, sheets, film, foil of other plastics: Covers plastics not elsewhere specified, such as polycarbonate, nylon, etc. PVB is specifically named, so it is not classified here. 3921 Other plates, sheets, film, foil of plastics: Refers to cellular plastic or plastic plates, sheets reinforced, laminated, supported with other materials. If PVB film is combined with other materials, it is classified under 3921. 3905 Poly(vinyl butyral) in primary forms: 3905 is primary forms (liquid, paste, block, etc.), 3920 is semi-finished plates, sheets, film, foil. Is the material PVB? Is it non-cellular plastic? Is it not combined with other materials? Is it in the form of plates, sheets, film, foil? Are the specifications and dimensions complete?
Basis
Classification basis: The goods are non-cellular plastic plates, sheets, film, foil made of poly(vinyl butyral) (PVB), not reinforced or laminated with other materials, meeting the notes to Chapter 39 and the text of heading 3920 of the Tariff. According to the subheading structure, products made of PVB are classified under 3920.91. Key review points include material, form, and whether combined with other materials.
Confused Codes：
392010 - Plates, sheets, film, foil of polymers of ethylene
Material is polyethylene, not PVB. PVB has unique adhesion and optical properties, used for safety glass.
392190 - Plates, sheets, film, foil of other plastics
Covers plastics not elsewhere specified, such as polycarbonate, nylon, etc. PVB is specifically named, so it is not classified here.
3921 - Other plates, sheets, film, foil of plastics
Refers to cellular plastic or plastic plates, sheets reinforced, laminated, supported with other materials. If PVB film is combined with other materials, it is classified under 3921.
3905 - Poly(vinyl butyral) in primary forms
3905 is primary forms (liquid, paste, block, etc.), 3920 is semi-finished plates, sheets, film, foil.
Self-Check：
✓ Is the material PVB?
✓ Is it non-cellular plastic?
✓ Is it not combined with other materials?
✓ Is it in the form of plates, sheets, film, foil?
✓ Are the specifications and dimensions complete?
❓ FAQ
How to inquire about the import tax rate for 392091? You can check the "Import and Export Tariff of the People's Republic of China" on the official website of the General Administration of Customs of China or the "Single Window", enter HS code 392091, and view the MFN rate, general rate, VAT and consumption tax. Tax rates may be adjusted; it is recommended to refer to the latest tariff. What should be noted when classifying PVB film used for automotive glass? It is necessary to confirm whether it is laminated with other materials. If PVB film is imported alone, it is classified under 392091; if it has been combined with glass or other materials, it may be classified under Chapter 70 or 3921. When declaring, material, use and combination status must be provided. What is the main difference between 392091 and 392010? 392091 is made of poly(vinyl butyral) (PVB), 392010 is made of polyethylene (PE). The materials are different. PVB has high adhesion and transparency, mainly used for safety glass, while PE is commonly used for packaging. Material must be strictly distinguished during classification. How to fill in "Specifications and Dimensions" when declaring? Fill in thickness, width, length (or roll length), and specify units, such as "thickness 0.38mm, width 1000mm, length 500m". If in sheet form, you can fill in "thickness 0.5mm, length 1000mm, width 600mm". Dimensions affect subheading determination, so they must be accurate. If PVB film has release paper, does it affect classification? If the release paper is only used as a protective layer and does not change the essential characteristics of the PVB film, it is still classified under 392091. However, if the release paper and PVB film are combined to form another product, it should be classified according to the actual product. The release paper situation should be explained when declaring. How to declare PVB film sold via cross-border e-commerce? Cross-border e-commerce must declare according to the actual commodity, providing product name, material, specifications, use, etc. If it is a small parcel direct mail, simplified declaration may apply, but the HS code still needs to be accurate. It is recommended to consult a customs broker or use the customs advance classification service. Does 392091 involve anti-dumping or trade control? It is necessary to check announcements from the General Administration of Customs. Some plastic products may involve anti-dumping duties. PVB film currently has no general control, but the latest policies should be monitored. You can check through the "China Trade Remedy Information Network". What are the consequences of classification errors? Classification errors may lead to tax supplements, fines, credit downgrades, etc. If intentionally falsely declared, it may constitute smuggling. Enterprises are advised to strengthen compliance and apply for advance classification when necessary to ensure accurate HS codes.
Q: How to inquire about the import tax rate for 392091?
A: You can check the "Import and Export Tariff of the People's Republic of China" on the official website of the General Administration of Customs of China or the "Single Window", enter HS code 392091, and view the MFN rate, general rate, VAT and consumption tax. Tax rates may be adjusted; it is recommended to refer to the latest tariff.
Q: What should be noted when classifying PVB film used for automotive glass?
A: It is necessary to confirm whether it is laminated with other materials. If PVB film is imported alone, it is classified under 392091; if it has been combined with glass or other materials, it may be classified under Chapter 70 or 3921. When declaring, material, use and combination status must be provided.
Q: What is the main difference between 392091 and 392010?
A: 392091 is made of poly(vinyl butyral) (PVB), 392010 is made of polyethylene (PE). The materials are different. PVB has high adhesion and transparency, mainly used for safety glass, while PE is commonly used for packaging. Material must be strictly distinguished during classification.
Q: How to fill in "Specifications and Dimensions" when declaring?
A: Fill in thickness, width, length (or roll length), and specify units, such as "thickness 0.38mm, width 1000mm, length 500m". If in sheet form, you can fill in "thickness 0.5mm, length 1000mm, width 600mm". Dimensions affect subheading determination, so they must be accurate.
Q: If PVB film has release paper, does it affect classification?
A: If the release paper is only used as a protective layer and does not change the essential characteristics of the PVB film, it is still classified under 392091. However, if the release paper and PVB film are combined to form another product, it should be classified according to the actual product. The release paper situation should be explained when declaring.
Q: How to declare PVB film sold via cross-border e-commerce?
A: Cross-border e-commerce must declare according to the actual commodity, providing product name, material, specifications, use, etc. If it is a small parcel direct mail, simplified declaration may apply, but the HS code still needs to be accurate. It is recommended to consult a customs broker or use the customs advance classification service.
Q: Does 392091 involve anti-dumping or trade control?
A: It is necessary to check announcements from the General Administration of Customs. Some plastic products may involve anti-dumping duties. PVB film currently has no general control, but the latest policies should be monitored. You can check through the "China Trade Remedy Information Network".
Q: What are the consequences of classification errors?
A: Classification errors may lead to tax supplements, fines, credit downgrades, etc. If intentionally falsely declared, it may constitute smuggling. Enterprises are advised to strengthen compliance and apply for advance classification when necessary to ensure accurate HS codes.
⚠️ 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.