In the realms of photography and videography, items ranging from everyday cameras and photo paper to industrial testing films shall be carefully categorized under the appropriate customs HS codes during import and export procedures. Ensuring precise classification is critical not only for streamlining customs clearance but also for correctly determining tariff obligations. This article aims to offer a comprehensive insight into the customs HS code classification policies for photosensitive materials like photo paper and industrial film.
I. Photo Paper HS Code Classification
Color photo paper, frequently used in civilian photography, requires special consideration regarding its physical state and processing traits within the HS coding framework. According to the principles of the Harmonized Commodity Description and Coding System, the classification focuses are as follows:
(I) Core Tax Heading No. and Sub-headings
Unexposed color photo paper is categorically placed under Heading No. 3703.10 when in rolls wider than 610 mm, or under Heading No. 3703.20 for other forms.
1. Exclusion Guidelines: Photo paper products that have undergone exposure and development (such as developed photos) should be classified under Chapter 49 (Printed Materials). If subjected to deepprocessing like plastic sealing, other Heading No. may apply.
2. Base Material Constraints: Limited to substrates made of paper, cardboard, and textiles, like traditional barium-based paper. If substrates such as glass, cellulose acetate, or other plastics are used (as seen in some quick print photo papers), they should be classified under Heading No. 3701 or 3702.
3. Coating Specifications: A sensitive emulsion layer, such as silver halide, shall be present. This is known as silver salt paper and is distinct from ink-jet photo paper, which falls under Chapter 48.
4. Status and Specifications: The product shall remain unexposed until it reaches import. If exposure occurs unintentionally during transit, a test certificate shall be furnished.
(II) Typical Declaration Examples
Lucky CL—101 color photo paper (762 mm × 86 m roll) → 3703.10.10.
Fuji Crystal Archive photo paper (A4 single sheet) → 3703.20.10.
Kodak Royal photo paper (6-inch photo) → 4911.91.00.
(III) Key Customs Considerations
1. Declaration Criteria: The intended use, whether it is rolled, the specific dimensions, and its exposure status shall all be declared.
2. During the distinction from printed materials (Chapter 49), it's crucial to verify if the development and fixing processes are completed.
3. Mixed packaging products (like photo paper paired with developer kits) need classification based on their primary characteristics.
II. Classification of HS Codes for Industrial Films
Industrial film is the abbreviation of "industrial radiographic film". It is mainly used in professional fields such as industrial flaw detection and printing plate making, with high-sensitivity imaging performance. These are unexposed X-ray films designed specifically for industrial flaw detection purposes. Such films necessitate high-sensitivity imaging to identify internal metal defects. While they share common characteristics with medical X-ray films, they find broader applications in industrial settings. The classification is predominantly based on its application for industrial flaw detection and the characteristic of being unexposed.
(I) Core Tax Heading No. and Sub-headings
The HS codes assigned are Heading No. 3701 for single pieces and Heading No. 3702 for film in rolls.
In terms of their physical form, these films utilize polyester (PET) or acetate fiber as a base, available in rolls or single sheets, and are maintained in an unexposed state.
Exclusions include developed industrial flaw detection negatives, categorized under "photographic products" as Heading No. 3705, and PS plates for printing platemaking, classified under Heading No. 3701.30.
(II) Key Customs Considerations
Key declaration components shall include: the intended use, material, whether in rolls, single-use, and exposure status.
Distinction from similar goods: Medical film and industrial film share similar materials, but serve distinct functional purposes. The scope of medical films includes X-ray films and dry films; according to general classification rules, they should be categorized under Heading No. 3701.1 and Heading No. 3701.3, respectively.
III. Classification Distinctions for Other Photosensitive Materials
Apart from photo paper and industrial film, there are specialized types of photosensitive materials. Microfilm, for instance, is predominantly used for the microstorage of documents and records, falling under the Heading No. 3705. Microfilms of books and newspapers are classified under Heading No. 3705.0021, while other exposed and developed microfilms are categorized under Heading No. 3705.0029 due to differing utilizations.
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