As a Chinese enterprise engaged in the cross-border business of films, we deeply understand that navigating the latest U.S. policy restrictions and ensuring maritime shipping compliance are crucial to avoiding operational risks, such as cargo detention, fines, market access bans, and delivery delays. Films are versatile products widely used in automotive, packaging, construction, electronics, and medical fields, thanks to their excellent barrier properties, transparency, wear resistance, and corrosion resistance. Due to their extensive application in various high-demand industries and direct relevance to product safety, environmental protection, and even industrial security, films imported from China are subject to stringent regulatory scrutiny in the U.S. market. In 2025-2026, the U.S. government, along with federal agencies including the Environmental Protection Agency (EPA), Consumer Product Safety Commission (CPSC), Customs and Border Protection (CBP), and Department of Commerce, has intensified regulatory enforcement on imported Chinese films, updating policies covering tariffs, chemical restrictions, safety certification standards, and labeling requirements. Below are two key summaries of the latest U.S. policy restrictions and the additional precautions that cross-border film enterprises must take when shipping by sea, designed to help peers reduce compliance risks and ensure smooth order delivery.
1. Comply with the Latest U.S. Policy Restrictions on Chinese Films
The U.S. imposes strict federal and state-level policy restrictions on imported Chinese films, with significant updates in 2025-2026 that directly affect cross-border operational costs and market access. Films have diverse specifications—varying in thickness, size, material composition (PET, PE, PP, PVC, and composite films), transparency, barrier grade, flame retardancy, and application scenarios (automotive-grade, food-packaging grade, industrial-grade, medical-grade)—which lead to tailored regulatory requirements. Enterprises must fully grasp these restrictions and strictly comply with them to avoid irreversible losses. The latest U.S. policy restrictions on Chinese films mainly focus on tariff policies, chemical restrictions (especially PFAS), safety certification standards, and labeling requirements.
First, tariff policies and classification rules have become more rigorous, increasing export costs significantly. Pursuant to the U.S. Harmonized Tariff Schedule (HTS) 2025 Revision 32 (effective December 5, 2025) and updates from the U.S. Trade Representative Office (USTR), Chinese-origin films are primarily classified under HTS 3925 (for plastic films and sheets) and HTS 3926 (for plastic film products), with specific 8-digit subcodes determined by material composition and application. For example, PET films for packaging are classified under HTS 39251000, while PE composite films for automotive use fall under HTS 39252000. The Most-Favored-Nation (MFN) duty rate for films ranges from 5.2% to 10.8% depending on the product type, material composition, and application scenario, and critically, they remain subject to the 10% additional Section 301 tariff, resulting in a total combined tariff rate of 15.2% to 20.8%. Importantly, films are not included in the 178 product categories eligible for the Section 301 tariff exemption extension (announced by USTR on November 26, 2025, extending through November 10, 2026), meaning all Chinese-origin films must pay the full additional tariff with no exceptions.
Notably, the de minimis tariff exemption for Chinese-origin products valued at $800 or less has been completely eliminated since August 29, 2025, per CBP announcement issued on August 15, 2025, in accordance with Executive Order 14324. This policy directly impacts film shipments: due to their material costs (especially high-performance automotive-grade, medical-grade, and flame-retardant films) and large volume, even small batches (usually 30-50 rolls of industrial-grade films or 10-20 rolls of high-precision medical-grade films) easily exceed $800, forcing all commercial consignments to undergo formal customs clearance and pay applicable tariffs. From August 29, 2025, to February 28, 2026, enterprises can choose either the ad valorem tariff method or the specific tariff method for tax calculation, but they can only select one method per month; after February 28, 2026, all film shipments to the U.S. via international postal networks must use the ad valorem tariff method, which calculates tariffs based on the effective IEEPA tariff rate of the country of origin—for Chinese products, this is 10% reciprocal tariff plus 20% basic tariff, in addition to the existing 10% Section 301 tariff. Tariffs must be paid by the 7th working day of the month following the customs declaration month; late payment will incur fines of 0.05% of the goods’ value per day. Additionally, all postal items containing films valued at or under $800 are subject to a duty rate of either 30% of their value or $25 per item (increasing to $50 per item after June 1, 2025), replacing any other duties.
Any shipment valued over $2,500 still requires formal customs declaration, and films subject to anti-dumping/countervailing duties, quotas, or ineligible for de minimis exemption are not covered by any temporary preferential policies. CBP has intensified audits on tariff classification of films in 2026, requiring detailed product descriptions specifying material composition (e.g., PET, PE, PP, composite materials), physical parameters (thickness, length, width, transparency, barrier coefficient), product type (industrial-grade, automotive-grade, medical-grade, flame-retardant grade), and application scenario (automotive interiors, food packaging, industrial workshops, medical devices) to support proper HTS coding. CBP has also emphasized that vague product descriptions such as “Plastic Films” or “Packaging Films” are no longer acceptable and will result in declaration rejection or detention. Misclassification leads to backdated duty payments, fines of up to 100% of the goods’ value, and potential shipment detention. Additionally, Executive Orders 14358 and related updates (effective November 2025) reaffirm the 10% Section 301 tariff on Chinese plastic products, including films, with no indication of near-term reductions. Furthermore, imported films are subject to the 9% import value-added tax rate, which enterprises must factor into cost calculations. It is also worth noting that U.S. tariff increase plans have been extended to January 1, 2027, giving Chinese film cross-border enterprises a 12-month adjustment window, but compliance with current policies remains the top priority.
Second, chemical restrictions, especially on Per- and Polyfluoroalkyl Substances (PFAS), have become increasingly strict at both federal and state levels, directly affecting film production and export. Films, especially those used for outdoor areas, food packaging, industrial workshops, and automotive interiors, may contain PFAS in their raw materials, additives, or surface treatments to enhance corrosion resistance, water resistance, and stain resistance. Under the EPA’s Toxic Substances Control Act (TSCA) regulations, all imported films must report PFAS content if manufactured or imported since January 1, 2011. The EPA has set legally enforceable Maximum Contaminant Levels (MCLs) for six PFAS chemicals in products involving water contact or frequent human contact, including PFOA, PFOS, PFHxS, PFNA, PFBS, and HFPO-DA, with limits as low as 4.0 ppt for PFOS. For films used in food packaging, children’s products, or medical devices, even trace amounts of PFAS (≥100 ppm, measured as total organic fluorine) require EPA reporting and compliance with these MCLs. Enterprises should also verify PFAS content in packaging materials, as the U.S. TPCH (Toxic Packaging Clearinghouse) has issued guidelines requiring confirmation of intentional PFAS addition in packaging, with testing recommended for total fluorine content to ensure compliance. Specifically, if the total fluorine content in packaging materials is below 100 ppm and meets quality control standards, the product may be deemed free of intentionally added PFAS; if it is 100 ppm or higher, further investigation is required to confirm whether PFAS were intentionally added.
The EPA released a proposed revision to PFAS reporting rules in November 2025, extending the original April 13, 2026, deadline and introducing exemptions for technically unavoidable trace impurities, but enterprises must not rely on these exemptions until the final rule is published. More critically, several U.S. states have implemented stricter restrictions on PFAS in plastic products, including films. California has enforced strict restrictions through AB 1817 (effective January 1, 2025), which explicitly prohibits the manufacture, distribution, and sale of plastic products containing PFAS—films are clearly included in the scope. The specific requirements are: no intentional addition of PFAS to films or their raw materials; the total organic fluorine content in films shall not exceed 100 ppm starting January 1, 2025, and shall be reduced to no more than 50 ppm starting January 1, 2027. Manufacturers selling films in California must also provide a certificate of conformity confirming the absence of regulated PFAS, signed by an authorized official. New Jersey, effective January 12, 2026, via S1221, prohibits the sale of new films with intentionally added PFAS, exempting used products and unavoidable impurities. In addition to California and New Jersey, Washington State and Minnesota (both effective January 1, 2025) prohibit the sale of films with intentionally added PFAS; Rhode Island (effective January 1, 2025) bans the sale of films containing any PFAS. Failure to comply with state chemical restrictions can result in severe state-level fines—up to $2,500 per day in California and $10,000 per day in New Jersey—and permanent market exclusion in the respective states.
Additionally, films are subject to strict restrictions on other harmful chemicals, including heavy metals (lead, cadmium, mercury), phthalates, and formaldehyde. The CPSC has updated its chemical restriction standards for plastic products in 2026, requiring that the lead content in films shall not exceed 90 ppm (0.009%), and the cadmium content shall not exceed 100 ppm (0.01%). For films used in children’s products (e.g., toy packaging, children’s food packaging) or medical devices, the lead content limit is further reduced to 10 ppm (0.001%), and phthalate content (including DEHP, DBP, BBP, DINP, DIDP, DNOP) shall not exceed 0.1%. For food-packaging grade films, compliance with FDA regulations on migratable substances is mandatory, ensuring no harmful chemicals leach into food. Enterprises must conduct strict quality control on raw materials and finished products, and provide third-party test reports to confirm compliance with these chemical limits when importing to the U.S.
Third, safety certification and standards are mandatory prerequisites for market access, with differentiated requirements based on application scenarios. Films imported into the U.S. must comply with relevant federal standards and obtain mandatory certifications to ensure their safety, durability, and environmental performance. The core certifications for films vary by application: for general industrial and packaging-grade films, compliance with ASTM D1709 (tensile property standard for plastic films) and ASTM D1922 (puncture resistance standard for plastic films) is mandatory, along with ISO 9001 (quality management system) certification; for automotive-grade films used in vehicle interiors (e.g., window films, interior decorative films), compliance with ASTM D3985 (standard for automotive plastic films) and ISO 14001 (environmental management system) certification are necessary, in addition to compliance with FMVSS (Federal Motor Vehicle Safety Standards) No. 302 (flammability standard for automotive interior materials); for food-packaging grade films, compliance with FDA 21 CFR Part 177 (plastic materials for food contact) is mandatory to ensure no harmful substances leach into food; for medical-grade films used in medical devices or packaging, compliance with ISO 13485 (medical device quality management system) and FDA 21 CFR Part 820 (quality system regulation for medical devices) is required; for flame-retardant films used in commercial buildings or industrial workshops, compliance with UL 94 (flame retardancy standard for plastics) is required, with a minimum flame-retardant grade of V-0 for most indoor applications.
Certification processes involve type testing and factory audits by accredited third-party laboratories, ensuring that films meet strict requirements for material purity, tensile strength, puncture resistance, flame retardancy, high and low temperature resistance, and service life. For example, automotive-grade window films must undergo impact testing at -40°C to 80°C to confirm adaptability to extreme temperature environments and avoid brittleness or deformation; food-packaging grade films must undergo migration testing to ensure no harmful substances leach into food under different temperature and humidity conditions; medical-grade films must pass biocompatibility testing to avoid adverse reactions when in contact with human skin or medical devices. Testing frequency is mandated: at least once for the first 200 rolls of each film specification, and every 1500 rolls thereafter. For films designed for high-risk applications (e.g., medical device packaging, industrial workshops with flammable materials), more frequent testing and stricter quality control are required to avoid potential safety hazards.
Labeling requirements for films are strict and multifaceted, with mandatory markings in English. The country of origin (“Made in China”) must be clearly, permanently marked on the product itself (not just the packaging) using printing, engraving, or tamper-proof labels—removable stickers may be deemed non-compliant by CBP. The origin label must be sufficiently visible (font size not less than 10pt) and placed in a prominent position on the product or its packaging (e.g., the outer surface of the packaging box, the edge of the film roll). Material composition (e.g., “PET Film, 100% PFAS-Free,” “PE Composite Film”), physical parameters (e.g., “Thickness: 0.1mm, Length: 1000m, Width: 1000mm, Transparency: 90%”), product type (e.g., “Automotive-Grade Window Film, Flame-Retardant Grade V-0”), and application scenario (e.g., “For Food Packaging Only,” “Medical Device Packaging Safe”) must be accurately labeled on each product or its packaging. For food-packaging grade films, labels must also include FDA compliance marks and a statement confirming compliance with food contact safety standards. For medical-grade films, labels must indicate ISO 13485 certification number and FDA registration number. Additionally, packaging materials must comply with TPCH guidelines, with labels confirming that no intentionally added PFAS are present if applicable.
For automotive-grade films, labels must clearly display the ASTM D3985 standard number and FMVSS 302 compliance marks. For flame-retardant films, labels must indicate the UL 94 flame-retardant grade and certification number. For California-bound shipments, Prop 65 warning labels are required if the films contain lead, cadmium, formaldehyde, or other regulated chemicals above threshold levels. California’s Prop 65, officially the Safe Drinking Water and Toxic Enforcement Act of 1986, targets various chemicals that may cause cancer or reproductive toxicity, requiring operators to provide clear and reasonable warnings for potential risks in consumer products, with approximately 700 chemicals currently regulated. All labels must be durable (resistant to wear, moisture, and corrosion) and easily visible to consumers and inspectors. Additionally, safety warnings (e.g., “Do Not Use in High-Temperature Environments Exceeding 80°C,” “Not for Medical Use Without FDA Approval”) are mandatory to avoid improper use and potential safety hazards.
2. Key Precautions for Maritime Shipping of Films to the U.S.
Maritime shipping is the primary logistics method for Chinese film enterprises exporting to the U.S., given the large order quantity, large volume, heavy weight, and long-distance transportation requirements. However, it requires strict adherence to packaging standards, documentation requirements, customs procedures, and inspection risk management. Given the 2026 CBP, CPSC, EPA inspection protocols that prioritize imported plastic products, Chinese-origin shipments, and products for industrial/automotive/medical use—along with the updated PFAS and safety certification requirements—enterprises must pay extra attention to the following points to avoid cargo detention, damage, or fines. Films are characterized by vulnerability to compression deformation, surface scratches, creases, and moisture absorption during long maritime transit; their structural integrity and performance require targeted packaging and handling measures to protect product quality and compliance.
First, ensure packaging compliance and product protection. Films, especially thin-gauge films (thickness ≤0.05mm) and high-precision medical/automotive-grade films, are prone to creasing, surface scratches, and edge damage if not properly packaged. They are sensitive to moisture (films may absorb moisture in high-humidity environments, leading to mold growth, reduced transparency, and decreased tensile strength), salt spray (maritime environment salt spray can cause surface corrosion and discoloration, especially for metalized films), and high temperature (which may cause film softening, adhesion, and deformation). Maritime humidity is high, and cabin temperatures may fluctuate significantly (ranging from 0°C to 40°C), increasing the risk of product damage or performance degradation. Therefore, enterprises must prioritize moisture resistance, anti-compression, anti-wear, and anti-adhesion measures in packaging.
Films should be sorted by specification (thickness, size, product type) and each roll should be wrapped tightly with moisture-proof PE film or kraft paper to prevent surface wear, moisture absorption, and adhesion, then placed in thickened cardboard boxes or plastic containers with foam inserts or corrugated paper supports around the edges to avoid compression deformation and edge damage during transit. For large-width films (width ≥2000mm) or long-length rolls (length ≥5000m), they should be fixed on sturdy plastic or wooden cores, wrapped with waterproof and moisture-proof cloth, and secured with PFAS-free straps to maintain structural stability. Each package should contain a fixed quantity of film rolls (e.g., 10 rolls of thin-gauge films or 5 rolls of large-width films per package) and be labeled with product specifications, material composition, and application scenario to facilitate identification. For high-precision medical-grade or automotive-grade films with strict surface requirements, additional protective layers (such as anti-scratch film) should be added to avoid surface scratches. For food-packaging or medical-grade films, separate packaging should be used to avoid cross-contamination, and the packaging should be marked with “Food-Contact Safe” or “Medical-Grade Product” to remind handlers of special requirements.
The packaged products should be fixed on wooden pallets (compliant with ISPM 15 standards) with PFAS-free straps to ensure stability during transit. Wooden pallets must be heat-treated (HT) or fumigated (MB), and display visible IPPC marks with country code, treatment enterprise number, and method. A fumigation certificate is mandatory for wooden pallets to avoid quarantine delays at U.S. ports, in line with U.S. wooden packaging inspection requirements. Pallets must be strong enough to withstand stacking pressure during transit—thickened wooden pallets (load-bearing ≥1200 kg) are recommended for large-weight film rolls—to avoid deformation or damage to the products inside. Attention must also be paid to weight and volume limits: general-purpose 20-foot containers have a typical cargo weight limit of 17.3 tons and volume limit of 33 cubic meters, while 40-foot high-cube containers are limited to 19.5 tons and 76 cubic meters (including packaging). Films are relatively light but bulky; enterprises should optimize packaging (e.g., using compact rolling, reducing redundant packaging) to maximize container utilization, avoiding overweight or over-volume shipments. Overweight or over-volume shipments may incur heavy fines or require offloading and redistribution at the port, leading to delivery delays and additional costs (such as demurrage and detention fees).
External packaging (cardboard boxes, plastic containers, or pallets) must display clear compliance marks, including ISPM 15 marks for wooden pallets, permanent “Made in China” origin labels, 8-digit HTS code (39251000, 39252000, or other applicable subcodes), relevant certification marks (ASTM, ISO 9001, FDA, UL 94 as applicable), safety compliance indicators, and shipping marks. Shipping marks must include consignee name, destination port (with state and zip code to avoid misdelivery), package number (e.g., PACKAGE NO. 1/50), gross/net weight, and dimensions, with origin labels separated from other details for visibility. For California-bound shipments, Prop 65 warning labels and PFAS compliance labels (if applicable) must be visible on outer packaging, including compliance with SB 682 requirements for future PFAS restrictions. For food-packaging grade films, FDA compliance marks must be prominently displayed. For medical-grade films, FDA registration numbers and ISO 13485 certification marks must also be displayed. The final unloading port must be clearly indicated on the packaging and shipping documents to avoid transit confusion. Additionally, packaging materials should prioritize sustainability, in line with U.S. environmental trends—preferably using recyclable or reusable materials, and meeting New York State’s environmental requirements that packaging materials must have a recyclable ratio of ≥50%.
A Container Packing Certificate and photos of the packing process (including moisture-proof measures, anti-compression wrapping, fixing methods, labeling, and packaging material compliance) can serve as supporting evidence in case of disputes with customs or carriers. Additionally, marking “Films – For [Application: Automotive/Food Packaging/Medical], Material: [PET/PE/Composite], Specifications: [Thickness/Length/Width/Transparency]” clearly on outer packaging helps CBP quickly identify the product and speed up clearance. Enterprises should also confirm that packaging materials do not contain intentionally added PFAS, and obtain relevant certification from suppliers if necessary, in line with TPCH guidelines and California’s SB 682 proposals. They should also maintain records of packaging material compliance, including PFAS test reports, indefinitely in accordance with risk management policies.
Second, ensure documentation accuracy and completeness, as this is the foundation of smooth customs clearance. Enterprises must prepare a complete set of English-language documents, including a commercial invoice, packing list, bill of lading (B/L), sales contract, certificate of origin, relevant safety certifications (ASTM, ISO 9001, FDA, UL 94 as applicable), CPSC safety test reports (in line with applicable standards), TSCA Compliance Statement, PFAS test reports and EPA filing confirmation, material composition reports, material safety data sheets (MSDS) for film raw materials and additives, fumigation certificates (if wooden pallets are used), and compliance statements for special-grade films (e.g., food-packaging, medical-grade). As required for maritime shipping, all key documents must be complete to avoid clearance delays—document deficiencies may result in cargo detention, with daily late fees calculated at 0.05% of the goods’ value. CBP may also require any film shipment to be declared formally, regardless of the tariff method specified. For food-packaging grade films, additional FDA test reports and compliance statements must be prepared. For medical-grade films, FDA registration documents and biocompatibility test reports must be included to confirm compliance with safety standards.
The commercial invoice must include a detailed product description (e.g., “Food-Packaging Grade PET Films, 100% PFAS-Free, Thickness 0.08mm, Length 1000m, Width 800mm, Transparency 92%, Compliant with ASTM D1709 and FDA 21 CFR Part 177, Model FM-PET-08”) with explicit technical specifications, avoiding vague terms to prevent classification disputes. It must also explicitly state the 8-digit HTS code, declared value reflecting the actual transaction price, and a detailed breakdown of tariff components (MFN, Section 301, import value-added tax) to facilitate CBP calculation. For mixed shipments containing different types of films (e.g., industrial-grade vs. automotive-grade, flame-retardant vs. non-flame-retardant, different thicknesses or material compositions), separate line items with distinct product descriptions, certification documents, and tariff calculations are mandatory, in line with U.S. customs requirements for separate declaration of different HS codes. For food-packaging grade films, the invoice must also indicate compliance with FDA 21 CFR Part 177 and include relevant certification numbers. CBP cross-references prices with market data for films; underdeclaring can result in fines of 20%-100% of the goods’ value and trigger additional scrutiny. Given that films have different price points based on material composition, thickness, and application, accurate pricing documentation is particularly important.
The packing list must detail each container’s contents, including the quantity (rolls), specifications (material composition, thickness, length, width, product type, flame-retardant grade), application scenario, gross/net weight, dimensions, and packaging materials of each film variant. It must also specify compliance details, such as PFAS test results, certification numbers (ASTM, ISO 9001, FDA, UL 94 etc.), and whether the product requires special handling (e.g., moisture-proof, anti-adhesion packaging). For food-packaging grade films, the packing list must also include FDA test results. For medical-grade films, FDA registration numbers and biocompatibility test reports must be included. All documents must be consistent in product specifications, HTS codes, declared values, and certification details to avoid CBP suspicion. Documents should be submitted to the customs broker at least 7 days before vessel arrival to facilitate pre-clearance, especially for shipments containing large-width films, medical-grade films, or mixed variants.
Additionally, enterprises should keep electronic copies of all documents for at least 5 years for future audits, as the CPSC, EPA, and CBP may conduct post-clearance inspections within 3 years of import. Enterprises should also maintain records of packaging material compliance, including PFAS test reports and supplier certifications, in line with U.S. regulatory requirements for supply chain documentation and TPCH guidelines. For films subject to California’s SB 682, enterprises should also maintain records of PFAS content to prepare for future regulatory enforcement. Strictly complying with customs clearance procedures is also essential: the Importer Security Filing (ISF), or “10+2 filing,” must be submitted to CBP at least 48 hours before vessel departure, as mandated by U.S. federal regulations for maritime shipping. Late or incomplete submissions incur fines up to $5,000 per shipment and cargo detention.
Proactive inspection risk management is also necessary, as CBP, CPSC, and EPA prioritize film shipments for audits to verify tariff classification, PFAS content, safety certification, labeling accuracy, packaging standards, and product quality. Inspections take 5-12 business days (longer for medical-grade films or large-width films) and cost $1,000-$3,500 per shipment, with additional lab testing fees if compliance is questioned. To minimize risk, enterprises should maintain detailed supply chain records and optimize shipment schedules, booking cargo space 6-8 weeks in advance during peak seasons to avoid congestion delays. Additionally, for food-packaging or medical-grade films, enterprises should proactively prepare relevant compliance documents to speed up inspection and clearance.
In summary, Chinese film cross-border enterprises must fully understand and strictly comply with the latest U.S. policy restrictions—including tariff policies, PFAS restrictions, safety certifications, and labeling requirements—and pay extra attention to packaging, documentation, and customs clearance details when using maritime shipping. Proactive compliance management, accurate documentation, strict adherence to shipping standards, and thorough supply chain record-keeping are the keys to avoiding risks, reducing costs, and ensuring long-term, stable market access to the U.S. during the 12-month tariff adjustment window ending January 1, 2027.