Nicholas Giannatti
17930 Great Lakes Parkway
Hiram, Ohio 44236

RE: The tariff classification of polyethylene terephthalate film from China

Dear Mr. Giannatti:

In your letter dated May 31, 2022, you requested a tariff classification ruling.

Item 12010 is a polyethylene terephthalate (PET) film with a thickness of 0.02 mm to which a 0.01 mm coating of polyethylene-co-vinyl-acetate has been added. The coating is a hot melt adhesive that is not tacky at room temperature. The purpose of the film is to wrap around multiconductor cables. After wrapping, the film is heated to activate the coating to fuse the film to itself, binding the conductors together in order to protect the conductors.

The applicable subheading for the PET film will be 3920.62.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other plates, sheets, film, foil and strip, of plastics, noncellular and not reinforced, laminated, supported or similarly combined with other materials: of poly(ethylene terephthalate):other. The general rate of duty will be 4.2 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3920.62.0090, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.02, in addition to subheading 3920.62.0090, HTSUS, listed above.

The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at and, respectively.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on the World Wide Web at

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Christina Allen at [email protected]


Steven A. Mack
National Commodity Specialist Division