Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, plastic materials and their semi-finished and finished products. This chapter is subdivided based on the source, chemical structure, processing stage, and use of plastics, and is the core chapter for classifying plastic commodities in international trade. Heading 3920 covers plates, sheets, film, foil and strip of other non-cellular plastics, not reinforced, laminated or supported. This heading mainly targets semi-finished plastic materials for further processing or direct use, but excludes cellular plastics (3921) or reinforced plastics (3921). The first 2 digits 39 represent Chapter 39 Plastics and articles thereof; digits 3-4, 20, represent heading 3920, i.e., plates, sheets, film, foil and strip of other non-cellular plastics; digits 5-6, 94, represent subheading 3920.94, specifically plates, sheets, film and foil of phenolic resins. Phenolic resin is a thermosetting resin with heat resistance and chemical corrosion resistance, and is therefore listed under a separate subheading. This commodity is plate, sheet, film and foil made of phenolic resin, belonging to non-cellular plastic semi-finished products, and is not reinforced or laminated with other materials. Therefore it is classified under 3920.94, rather than 3921 (other plates, sheets, etc. of plastics) or 3909 (phenolic resins in primary forms).
Chapter
Chapter 39 covers plastics and articles thereof, including polymers in primary forms, synthetic resins, plastic materials and their semi-finished and finished products. This chapter is subdivided based on the source, chemical structure, processing stage, and use of plastics, and is the core chapter for classifying plastic commodities in international trade.
Heading
Heading 3920 covers plates, sheets, film, foil and strip of other non-cellular plastics, not reinforced, laminated or supported. This heading mainly targets semi-finished plastic materials for further processing or direct use, but excludes cellular plastics (3921) or reinforced plastics (3921).
Digit Breakdown
The first 2 digits 39 represent Chapter 39 Plastics and articles thereof; digits 3-4, 20, represent heading 3920, i.e., plates, sheets, film, foil and strip of other non-cellular plastics; digits 5-6, 94, represent subheading 3920.94, specifically plates, sheets, film and foil of phenolic resins. Phenolic resin is a thermosetting resin with heat resistance and chemical corrosion resistance, and is therefore listed under a separate subheading.
Classification Basis
This commodity is plate, sheet, film and foil made of phenolic resin, belonging to non-cellular plastic semi-finished products, and is not reinforced or laminated with other materials. Therefore it is classified under 3920.94, rather than 3921 (other plates, sheets, etc. of plastics) or 3909 (phenolic resins in primary forms).
📝 Declaration Elements
Product name: The specific name of the declared commodity, such as phenolic resin board, phenolic resin film, etc., which must be consistent with the actual goods. Material: Clearly state phenolic resin, and indicate whether fillers, reinforcing materials, etc. are contained. Appearance: Describe the shape (plate, sheet, film, foil), color, surface condition, etc. Specifications and dimensions: Provide thickness, width, length and other dimensional information, usually in millimeters. Whether reinforced or laminated: Declare whether it is combined with other materials or reinforced, which affects classification. Use: Explain the main use, such as electrical insulation, mechanical processing, etc. Product name: phenolic resin board; Material: phenolic resin (not reinforced); Appearance: brown opaque board; Specifications: thickness 2 mm, width 1000 mm, length 2000 mm; Reinforced: no; Use: used for processing electrical insulation parts. Failure to indicate whether reinforced may lead to incorrect classification under 3921. Inaccurate declaration of thickness affects subheading determination. Vague material description, failing to clearly identify it as phenolic resin.
Product name
The specific name of the declared commodity, such as phenolic resin board, phenolic resin film, etc., which must be consistent with the actual goods.
⚠️ Only writing 'plastic board' without indicating that the material is phenolic resin.
Material
Clearly state phenolic resin, and indicate whether fillers, reinforcing materials, etc. are contained.
⚠️ Mistakenly declaring it as other resins such as epoxy resin or polyester resin.
Appearance
Describe the shape (plate, sheet, film, foil), color, surface condition, etc.
⚠️ Failing to distinguish whether it is a plate or film, leading to classification disputes.
Specifications and dimensions
Provide thickness, width, length and other dimensional information, usually in millimeters.
⚠️ Omitting thickness, making it impossible to determine whether it is foil (usually thickness <= 0.25 mm).
Whether reinforced or laminated
Declare whether it is combined with other materials or reinforced, which affects classification.
⚠️ Failing to declare reinforcement, leading to incorrect classification under 3921.
Use
Explain the main use, such as electrical insulation, mechanical processing, etc.
⚠️ The description of use is too general, such as 'for industrial use'.
Example： Product name: phenolic resin board; Material: phenolic resin (not reinforced); Appearance: brown opaque board; Specifications: thickness 2 mm, width 1000 mm, length 2000 mm; Reinforced: no; Use: used for processing electrical insulation parts.
Common Mistakes：
Failure to indicate whether reinforced may lead to incorrect classification under 3921.
Inaccurate declaration of thickness affects subheading determination.
Vague material description, failing to clearly identify it as phenolic resin.
🎯 Classification Logic
The core basis for classification is: 1. The material is phenolic resin; 2. The form is plate, sheet, film or foil; 3. Non-cellular; 4. Not reinforced, laminated or supported. If the above conditions are met, it is classified under 3920.94. If it is cellular or reinforced material, it is classified under 3921. If it is in primary form, it is classified under 3909. 3921.90 Other plates, sheets, film and foil of plastics: 3921 covers cellular plastics or reinforced/laminated plastics, while 3920.94 covers non-cellular and non-reinforced plates and sheets of phenolic resin. 3909.40 Phenolic resins in primary forms: 3909 covers primary forms (liquid, powder, granules, etc.), while 3920.94 covers semi-finished plates, sheets, film and foil. 3920.92 Plates, sheets, film and foil of amino-resins: The materials are different. 3920.92 covers amino-resins (such as urea-formaldehyde, melamine), while 3920.94 covers phenolic resins. 3920.99 Plates, sheets, film and foil of other plastics: 3920.99 covers other plastics not elsewhere specified. Phenolic resin has a specific subheading and should preferentially be classified under 3920.94. Is the material phenolic resin? Is it non-cellular plastic? Is it not reinforced or laminated? Is the form plate, sheet, film or foil? Is it not in primary form?
Basis
The core basis for classification is: 1. The material is phenolic resin; 2. The form is plate, sheet, film or foil; 3. Non-cellular; 4. Not reinforced, laminated or supported. If the above conditions are met, it is classified under 3920.94. If it is cellular or reinforced material, it is classified under 3921. If it is in primary form, it is classified under 3909.
Confused Codes：
3921.90 - Other plates, sheets, film and foil of plastics
3921 covers cellular plastics or reinforced/laminated plastics, while 3920.94 covers non-cellular and non-reinforced plates and sheets of phenolic resin.
3909.40 - Phenolic resins in primary forms
3909 covers primary forms (liquid, powder, granules, etc.), while 3920.94 covers semi-finished plates, sheets, film and foil.
3920.92 - Plates, sheets, film and foil of amino-resins
The materials are different. 3920.92 covers amino-resins (such as urea-formaldehyde, melamine), while 3920.94 covers phenolic resins.
3920.99 - Plates, sheets, film and foil of other plastics
3920.99 covers other plastics not elsewhere specified. Phenolic resin has a specific subheading and should preferentially be classified under 3920.94.
Self-Check：
✓ Is the material phenolic resin?
✓ Is it non-cellular plastic?
✓ Is it not reinforced or laminated?
✓ Is the form plate, sheet, film or foil?
✓ Is it not in primary form?
❓ FAQ
How can I check the tariff rate for 3920.94? You can check the latest tariff rate through the website of the General Administration of Customs of China or the International Trade Single Window. Tariff rates may change due to country, trade agreements, etc., and the latest official publication should prevail. If phenolic resin board is reinforced with glass fiber, which code should it be classified under? If reinforcing materials such as glass fiber are added, it does not belong to 3920.94 and should be classified under 3921.90 (other plates, sheets, film and foil of plastics, reinforced). How are phenolic resin film and phenolic resin foil distinguished? They are usually distinguished by thickness. Foil generally has a thickness not exceeding 0.25 mm, while film is thinner but has no strict definition. Accurate thickness must be provided at declaration so that customs can determine it. What is the main difference between 3920.94 and 3920.92? 3920.94 is made of phenolic resin, while 3920.92 is made of amino-resin. The two have different materials, chemical structures and uses, and the resin type must be clearly identified during classification. If phenolic resin board is used for cutting into parts, does this affect classification? If it only undergoes simple processing such as cutting, it is still classified under 3920.94; if it is further processed into articles, it may be classified under other headings of Chapter 39 or Chapter 84, etc. How should the appearance of phenolic resin board be described at declaration? The color, transparency, whether the surface is smooth, whether there is texture, etc. should be described, such as 'brown opaque smooth board'. What are the declaration elements for phenolic resin plates, sheets, film and foil? They mainly include product name, material, appearance, specifications and dimensions, whether reinforced or laminated, and use. The specific requirements shall be subject to customs requirements. If phenolic resin board is laminated with other materials, which code should it be classified under? If laminated with other materials, it is reinforced or laminated plastic and should be classified under 3921.90, not 3920.94.
Q: How can I check the tariff rate for 3920.94?
A: You can check the latest tariff rate through the website of the General Administration of Customs of China or the International Trade Single Window. Tariff rates may change due to country, trade agreements, etc., and the latest official publication should prevail.
Q: If phenolic resin board is reinforced with glass fiber, which code should it be classified under?
A: If reinforcing materials such as glass fiber are added, it does not belong to 3920.94 and should be classified under 3921.90 (other plates, sheets, film and foil of plastics, reinforced).
Q: How are phenolic resin film and phenolic resin foil distinguished?
A: They are usually distinguished by thickness. Foil generally has a thickness not exceeding 0.25 mm, while film is thinner but has no strict definition. Accurate thickness must be provided at declaration so that customs can determine it.
Q: What is the main difference between 3920.94 and 3920.92?
A: 3920.94 is made of phenolic resin, while 3920.92 is made of amino-resin. The two have different materials, chemical structures and uses, and the resin type must be clearly identified during classification.
Q: If phenolic resin board is used for cutting into parts, does this affect classification?
A: If it only undergoes simple processing such as cutting, it is still classified under 3920.94; if it is further processed into articles, it may be classified under other headings of Chapter 39 or Chapter 84, etc.
Q: How should the appearance of phenolic resin board be described at declaration?
A: The color, transparency, whether the surface is smooth, whether there is texture, etc. should be described, such as 'brown opaque smooth board'.
Q: What are the declaration elements for phenolic resin plates, sheets, film and foil?
A: They mainly include product name, material, appearance, specifications and dimensions, whether reinforced or laminated, and use. The specific requirements shall be subject to customs requirements.
Q: If phenolic resin board is laminated with other materials, which code should it be classified under?
A: If laminated with other materials, it is reinforced or laminated plastic and should be classified under 3921.90, not 3920.94.
⚠️ 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.