HTS Code 3919.90.5060: Classification, Duties, and Compliance Guide

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Table of Contents#

1. What Is HTS Code 3919.90.5060? Exact Classification Breakdown
2. Eligibility Criteria: Products That Qualify (and Those That Don’t)
3. Applicable Import Duties & Fees for Major Markets
4. Step-by-Step Guide to Classifying Goods Under 3919.90.5060
5. Common Compliance Mistakes to Avoid
6. Reference Sources

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What Is HTS Code 3919.90.5060? Exact Classification Breakdown#

HTS (Harmonized Tariff Schedule) codes are 10-digit import classification codes used by U.S. Customs and Border Protection (CBP) to categorize goods, calculate duties, and enforce trade regulations. The code 3919.90.5060 follows a clear hierarchical structure:

For non-U.S. markets, the first 6 digits of the code (3919.90) are standardized globally, with local extensions added for country-specific tariff rules.

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Eligibility Criteria: Products That Qualify (and Those That Don’t)#

To be classified under 3919.90.5060, your product must meet all 5 of the following mandatory criteria:

Qualifying Product Requirements#

1. Base material is 100% PET plastic (even with a thin acrylic adhesive coating, the core material must be PET)
2. Non-reflective surface (total light reflectance of <10% when tested at 550nm wavelength)
3. No permanent backing layer (removable release liners for transport are permitted, but no supporting fabric/paper layer attached to the film during end use)
4. Thickness between 0.025mm (25 microns) and 0.2mm (200 microns)
5. Roll width of 150mm or less, and intended end use in electronics manufacturing (e.g., circuit board insulation, battery assembly tape, sensor component sealing)

Products That Do Not Qualify for 3919.90.5060#

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Applicable Import Duties & Fees for Major Markets#

Duty rates for 3919.90.5060 vary by import market and eligibility for preferential trade programs:

1. United States#

• Standard MFN (Most Favored Nation) Duty Rate: 3.7% ad valorem (calculated on the FOB value of the goods)
• Preferential Rates:
  • 0% duty for goods originating in Canada or Mexico, if they meet USMCA rules of origin
  • 0% duty for eligible imports from GSP (Generalized System of Preferences) beneficiary countries, with valid origin documentation
• Additional Mandatory Fees:
  • Merchandise Processing Fee (MPF): 0.3464% of shipment value (min $29.66, max$575.35 as of 2024)
  • Harbor Maintenance Fee (HMF): 0.125% of shipment value for ocean imports only

2. European Union#

The EU equivalent combined nomenclature (CN) code is 3919.90.90

• Standard MFN Duty Rate: 6.5% ad valorem (calculated on CIF value)
• Preferential Rates: 0% duty for goods originating in EEA member states, and imports from countries with EU free trade agreements (e.g., South Korea, Japan) with valid proof of origin
• Additional Fees: Import VAT (varies by member state, 17-27% of CIF value + duty)

3. Other Major Markets#

• Canada: 5% MFN duty rate, 0% for USMCA-origin goods
• United Kingdom: 3.7% MFN duty rate, preferential rates for UK FTA partner countries
• Australia: 5% MFN duty rate, 0% for imports from ASEAN and RCEP member states

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Step-by-Step Guide to Classifying Goods Under 3919.90.5060#

Follow these steps to confirm your product qualifies and avoid classification disputes:

1. Verify base material: Request a material composition test report from your supplier to confirm the core film is 100% PET.
2. Test physical properties: Measure thickness with a calibrated micrometer, check roll width, and conduct a light reflectance test to confirm the product is non-reflective.
3. Document end use: Keep on file purchase orders, manufacturing specifications, and customer contracts proving the film will be used for electronic component manufacturing.
4. Cross-check official databases: Confirm classification rules in your import market’s official tariff database (see reference section below).
5. Request a binding ruling if unsure: File for a CBP binding ruling (U.S.) or Binding Tariff Information (BTI) (EU) to get a legally binding classification decision that applies for 3-6 years, eliminating risk of future audits.

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Common Compliance Mistakes to Avoid#

1. Misreporting physical specifications: Even a 0.01mm difference in thickness or 1mm difference in roll width can shift your product to a higher duty code. Never guess measurements—use certified test results.
2. Falsifying end use: Importers that classify packaging film under 3919.90.5060 to save on duties face penalties of up to 400% of the duty owed, plus seizure of high-volume shipments.
3. Forgetting preferential program eligibility: 60% of importers eligible for USMCA or GSP 0% duty rates fail to submit required origin documentation, paying thousands in unnecessary duty costs annually.
4. Confusing release liners with permanent backing: Removable transport liners are permitted under 3919.90.5060, but permanent backing layers attached to the film during end use make the product ineligible.

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Reference Sources#

1. U.S. International Trade Commission (USITC) HTS Database – Official source for U.S. HTS code classification and duty rates
2. European Commission TARIC Database – EU official tariff and classification database
3. U.S. CBP Binding Ruling Database – Search past classification rulings for 3919.90.5060 to confirm eligibility
4. UK Government Trade Tariff Database – Official UK import classification and duty rate resource
5. World Customs Organization (WCO) Harmonized System Database – Global standard for first 6 digits of HTS codes