Chapter 39 covers plastics and articles thereof, and is a core chapter in the HS classification organized by material properties. This chapter includes polymers in primary forms, synthetic resins, plastic semi-finished products (such as plates, sheets, film, foil, strip, etc.), and articles of plastics. Amino resins, as an important category of thermosetting plastics, have their semi-finished products such as plates, sheets, film, and foil classified in this chapter. This chapter overlaps with Chapter 40 on rubber and articles thereof and Chapter 48 on paper and paperboard, and classification must be determined strictly based on material composition and processing state. Heading 3920 covers plates, sheets, film, foil and strip of other non-cellular plastics, not reinforced, laminated, or combined with other materials. This heading includes semi-finished products made of all thermoplastic or thermosetting plastics, but excludes cellular plastics (heading 3921) and products that have been reinforced or laminated (heading 3921). Plates, sheets, film and foil of amino resins are generally classified under 3920 due to their thermosetting characteristics, but attention must be paid to whether they have undergone surface treatment or been combined with other materials. The first 2 digits '39' represent Chapter 39 on 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 '93' represent subheading 3920.93, specifically plates, sheets, film and foil of amino resins. Amino resins include urea-formaldehyde resins, melamine-formaldehyde resins, etc., and their products must meet the conditions of not being reinforced, not laminated, and non-cellular. If amino resin plates or sheets have been reinforced or combined with other materials, they may be classified under 3921. This product is plate, sheet, film or foil made of amino resin, belongs to non-cellular plastic semi-finished products, and has not been reinforced, laminated, or combined with other materials, and is therefore classified under 3920.93. If it were cellular plastic, it would be classified under 3921.1; if it were a reinforced or laminated product, it would be classified under 3921.9; if it were amino resin in primary forms, it would be classified under 3909. Correctly distinguishing the processing state and material combination is key.
Chapter
Chapter 39 covers plastics and articles thereof, and is a core chapter in the HS classification organized by material properties. This chapter includes polymers in primary forms, synthetic resins, plastic semi-finished products (such as plates, sheets, film, foil, strip, etc.), and articles of plastics. Amino resins, as an important category of thermosetting plastics, have their semi-finished products such as plates, sheets, film, and foil classified in this chapter. This chapter overlaps with Chapter 40 on rubber and articles thereof and Chapter 48 on paper and paperboard, and classification must be determined strictly based on material composition and processing state.
Heading
Heading 3920 covers plates, sheets, film, foil and strip of other non-cellular plastics, not reinforced, laminated, or combined with other materials. This heading includes semi-finished products made of all thermoplastic or thermosetting plastics, but excludes cellular plastics (heading 3921) and products that have been reinforced or laminated (heading 3921). Plates, sheets, film and foil of amino resins are generally classified under 3920 due to their thermosetting characteristics, but attention must be paid to whether they have undergone surface treatment or been combined with other materials.
Digit Breakdown
The first 2 digits '39' represent Chapter 39 on 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 '93' represent subheading 3920.93, specifically plates, sheets, film and foil of amino resins. Amino resins include urea-formaldehyde resins, melamine-formaldehyde resins, etc., and their products must meet the conditions of not being reinforced, not laminated, and non-cellular. If amino resin plates or sheets have been reinforced or combined with other materials, they may be classified under 3921.
Classification Basis
This product is plate, sheet, film or foil made of amino resin, belongs to non-cellular plastic semi-finished products, and has not been reinforced, laminated, or combined with other materials, and is therefore classified under 3920.93. If it were cellular plastic, it would be classified under 3921.1; if it were a reinforced or laminated product, it would be classified under 3921.9; if it were amino resin in primary forms, it would be classified under 3909. Correctly distinguishing the processing state and material combination is key.
📝 Declaration Elements
Product name: The specific name of the declared commodity, such as amino resin board, melamine-formaldehyde resin film, etc., which must be consistent with the HS code description. Material: Clearly specify the specific type of amino resin, such as urea-formaldehyde resin, melamine-formaldehyde resin, etc., and indicate whether fillers are contained. Appearance: Describe appearance features such as shape (plate, sheet, film, foil), color, transparency, surface treatment, etc. Specifications and dimensions: Declare dimensions such as length, width, and thickness; thickness must be accurate to the millimeter in order to distinguish film from foil. Whether reinforced or laminated: State whether it has been reinforced, laminated, or combined with other materials; this is the key to distinguishing 3920 from 3921. Whether cellular: Clearly state whether it is cellular plastic; cellular plastic should be classified under 3921, and non-cellular under 3920. Use: Explain the main use, such as decorative panels, insulating materials, packaging materials, etc., to assist classification. Product name: Melamine-formaldehyde resin decorative board; Material: melamine-formaldehyde resin (containing wood flour filler); Appearance: opaque, patterned surface, rectangular board; Specifications: length 2440mm, width 1220mm, thickness 1.2mm; Whether reinforced or laminated: not reinforced, not laminated; Whether cellular: non-cellular; Use: used for surface decoration of furniture. Failure to indicate the specific type of amino resin, making it impossible to distinguish it from phenolic resin, etc. Inaccurate declaration of thickness; the boundary between film and foil (usually 0.25mm) affects subheading classification. Misreporting surface printing or coating as lamination, resulting in incorrect classification under 3921.
Product name
The specific name of the declared commodity, such as amino resin board, melamine-formaldehyde resin film, etc., which must be consistent with the HS code description.
⚠️ Writing only 'plastic board' without indicating the amino resin material, leading to classification disputes.
Material
Clearly specify the specific type of amino resin, such as urea-formaldehyde resin, melamine-formaldehyde resin, etc., and indicate whether fillers are contained.
⚠️ Confusing amino resin with phenolic resin, or failing to specify filler components.
Appearance
Describe appearance features such as shape (plate, sheet, film, foil), color, transparency, surface treatment, etc.
⚠️ Failing to distinguish the thickness boundary between film and foil, or ignoring features such as surface embossing.
Specifications and dimensions
Declare dimensions such as length, width, and thickness; thickness must be accurate to the millimeter in order to distinguish film from foil.
⚠️ Incorrect thickness units (such as centimeters mistaken for millimeters), or failure to provide complete dimensions.
Whether reinforced or laminated
State whether it has been reinforced, laminated, or combined with other materials; this is the key to distinguishing 3920 from 3921.
⚠️ Misreporting surface coating as lamination, resulting in incorrect classification under 3921.
Whether cellular
Clearly state whether it is cellular plastic; cellular plastic should be classified under 3921, and non-cellular under 3920.
⚠️ Misreporting microporous structures as non-cellular, or ignoring residual blowing agents.
Use
Explain the main use, such as decorative panels, insulating materials, packaging materials, etc., to assist classification.
⚠️ The use description is too broad, such as 'industrial use', and cannot provide effective information.
Example： Product name: Melamine-formaldehyde resin decorative board; Material: melamine-formaldehyde resin (containing wood flour filler); Appearance: opaque, patterned surface, rectangular board; Specifications: length 2440mm, width 1220mm, thickness 1.2mm; Whether reinforced or laminated: not reinforced, not laminated; Whether cellular: non-cellular; Use: used for surface decoration of furniture.
Common Mistakes：
Failure to indicate the specific type of amino resin, making it impossible to distinguish it from phenolic resin, etc.
Inaccurate declaration of thickness; the boundary between film and foil (usually 0.25mm) affects subheading classification.
Misreporting surface printing or coating as lamination, resulting in incorrect classification under 3921.
🎯 Classification Logic
The core basis for classification is: 1) the material is amino resin; 2) the form is plate, sheet, film, or foil; 3) non-cellular; 4) not reinforced, laminated, or combined with other materials. According to HS notes, 3920 includes all non-cellular plastic semi-finished products, but excludes products reinforced with textile materials of Chapter 54, Chapter 55, etc. The thermosetting characteristics of amino resins do not affect classification, but it must be confirmed that they have not been combined with other materials. If the product has been reinforced or laminated, even if the material is amino resin, it should still be classified under 3921. 3921.90 Other plates, sheets, film and foil of plastics: 3921.90 covers reinforced, laminated, or cellular plastic plates, sheets, film and foil, while 3920.93 is limited to non-cellular, non-reinforced amino resin products. The core difference lies in the processing state. 3909.20 Amino resins in primary forms: 3909.20 is amino resins in primary forms (such as blocks, powder, granules), while 3920.93 is semi-finished products already processed into plates, sheets, film and foil. The difference lies in shape and processing stage. 3920.94 Plates, sheets, film and foil of phenolic resins: 3920.94 is made of phenolic resin, while 3920.93 is made of amino resin. The difference lies in the resin type, which must be determined through chemical composition analysis. 3920.99 Plates, sheets, film and foil of other plastics: 3920.99 is for plastics not elsewhere specified; if amino resin plates, sheets, film and foil meet the conditions for 3920, they should be classified under 3920.93 in preference to 3920.99. Confirm that the material is amino resin, not phenolic or other resin. Confirm that the product is non-cellular plastic. Confirm that the product has not been reinforced, laminated, or combined with other materials. Confirm that the product form is plate, sheet, film, or foil. Confirm that specifications such as thickness and dimensions are accurately declared.
Basis
The core basis for classification is: 1) the material is amino resin; 2) the form is plate, sheet, film, or foil; 3) non-cellular; 4) not reinforced, laminated, or combined with other materials. According to HS notes, 3920 includes all non-cellular plastic semi-finished products, but excludes products reinforced with textile materials of Chapter 54, Chapter 55, etc. The thermosetting characteristics of amino resins do not affect classification, but it must be confirmed that they have not been combined with other materials. If the product has been reinforced or laminated, even if the material is amino resin, it should still be classified under 3921.
Confused Codes：
3921.90 - Other plates, sheets, film and foil of plastics
3921.90 covers reinforced, laminated, or cellular plastic plates, sheets, film and foil, while 3920.93 is limited to non-cellular, non-reinforced amino resin products. The core difference lies in the processing state.
3909.20 - Amino resins in primary forms
3909.20 is amino resins in primary forms (such as blocks, powder, granules), while 3920.93 is semi-finished products already processed into plates, sheets, film and foil. The difference lies in shape and processing stage.
3920.94 - Plates, sheets, film and foil of phenolic resins
3920.94 is made of phenolic resin, while 3920.93 is made of amino resin. The difference lies in the resin type, which must be determined through chemical composition analysis.
3920.99 - Plates, sheets, film and foil of other plastics
3920.99 is for plastics not elsewhere specified; if amino resin plates, sheets, film and foil meet the conditions for 3920, they should be classified under 3920.93 in preference to 3920.99.
Self-Check：
✓ Confirm that the material is amino resin, not phenolic or other resin.
✓ Confirm that the product is non-cellular plastic.
✓ Confirm that the product has not been reinforced, laminated, or combined with other materials.
✓ Confirm that the product form is plate, sheet, film, or foil.
✓ Confirm that specifications such as thickness and dimensions are accurately declared.
❓ FAQ
How are HS codes 392093 and 392190 distinguished for amino resin plates, sheets, film and foil? 392093 applies to non-cellular, non-reinforced, non-laminated amino resin plates, sheets, film and foil; 392190 applies to reinforced, laminated, or cellular plastic plates, sheets, film and foil. The key difference is whether the product has undergone reinforcement, lamination, or foaming treatment. If the amino resin plate or sheet is only surface-printed and not combined with other materials, it is still classified under 392093. How can it be determined whether an amino resin plate or sheet has been laminated? Lamination refers to combining two or more layers of materials together by adhesive or hot pressing. If the amino resin plate or sheet is only surface-coated with varnish or printed, and not laminated with other materials, it is not considered laminated. If it is combined with paper, cloth, metal foil, etc., it is classified under 392190. What is the thickness boundary between amino resin film and foil? According to HS notes, film generally refers to thin sheets with a thickness not exceeding 0.25mm, and foil refers to flexible sheet materials with an even thinner thickness (usually less than 0.15mm). However, customs authorities in different countries may make minor adjustments, and the thickness should be accurately provided at declaration based on actual measurement. How can the tariff rate for amino resin plates, sheets, film and foil be checked? The tariff rate must be checked according to the customs tariff of the destination country. For example, China Customs can be checked through the Import and Export Tariff of the People's Republic of China or the website of the General Administration of Customs. Tariff rates may change due to trade agreements, country of origin, and other factors, so the latest official data should be used. How should the specific type of amino resin be described when declaring? The chemical name should be indicated, such as urea-formaldehyde resin, melamine-formaldehyde resin, aniline-formaldehyde resin, etc. If it is a mixed resin, the main components and proportions must be stated. Avoid vague expressions such as 'amino plastic' to ensure accurate classification. If amino resin plates, sheets, film and foil are used for food packaging, are there special regulatory requirements? Yes. Materials used for food contact must comply with the food safety regulations of the destination country, such as China's GB 4806 standard, U.S. FDA 21 CFR, and EU 10/2011, etc. A declaration of conformity must be provided at declaration, but the HS code remains 392093, and regulatory conditions may be added. Is the export tax rebate for amino resin plates, sheets, film and foil related to the code? The export tax rebate depends on the tax policy of the home country and is usually linked to the HS code. Enterprises need to check the latest export tax rebate rate and ensure that the declared code is accurate so as not to affect the rebate. It is advisable to consult the local tax authority or customs broker.
Q: How are HS codes 392093 and 392190 distinguished for amino resin plates, sheets, film and foil?
A: 392093 applies to non-cellular, non-reinforced, non-laminated amino resin plates, sheets, film and foil; 392190 applies to reinforced, laminated, or cellular plastic plates, sheets, film and foil. The key difference is whether the product has undergone reinforcement, lamination, or foaming treatment. If the amino resin plate or sheet is only surface-printed and not combined with other materials, it is still classified under 392093.
Q: How can it be determined whether an amino resin plate or sheet has been laminated?
A: Lamination refers to combining two or more layers of materials together by adhesive or hot pressing. If the amino resin plate or sheet is only surface-coated with varnish or printed, and not laminated with other materials, it is not considered laminated. If it is combined with paper, cloth, metal foil, etc., it is classified under 392190.
Q: What is the thickness boundary between amino resin film and foil?
A: According to HS notes, film generally refers to thin sheets with a thickness not exceeding 0.25mm, and foil refers to flexible sheet materials with an even thinner thickness (usually less than 0.15mm). However, customs authorities in different countries may make minor adjustments, and the thickness should be accurately provided at declaration based on actual measurement.
Q: How can the tariff rate for amino resin plates, sheets, film and foil be checked?
A: The tariff rate must be checked according to the customs tariff of the destination country. For example, China Customs can be checked through the Import and Export Tariff of the People's Republic of China or the website of the General Administration of Customs. Tariff rates may change due to trade agreements, country of origin, and other factors, so the latest official data should be used.
Q: How should the specific type of amino resin be described when declaring?
A: The chemical name should be indicated, such as urea-formaldehyde resin, melamine-formaldehyde resin, aniline-formaldehyde resin, etc. If it is a mixed resin, the main components and proportions must be stated. Avoid vague expressions such as 'amino plastic' to ensure accurate classification.
Q: If amino resin plates, sheets, film and foil are used for food packaging, are there special regulatory requirements?
A: Yes. Materials used for food contact must comply with the food safety regulations of the destination country, such as China's GB 4806 standard, U.S. FDA 21 CFR, and EU 10/2011, etc. A declaration of conformity must be provided at declaration, but the HS code remains 392093, and regulatory conditions may be added.
Q: Is the export tax rebate for amino resin plates, sheets, film and foil related to the code?
A: The export tax rebate depends on the tax policy of the home country and is usually linked to the HS code. Enterprises need to check the latest export tax rebate rate and ensure that the declared code is accurate so as not to affect the rebate. It is advisable to consult the local tax authority or customs broker.
⚠️ 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.