Non-Cellular, Non-Reinforced Polyethylene Plates, Sheets, Film, Foil & Strip

Stretch wrap and shrink film made of polyethylene can fall under 392010 if they are non-cellular and not reinforced or laminated. However, if the film is combined with other materials (e.g., laminated to foil or fabric) or is cellular in structure, it would classify elsewhere. The key classification tests are: (1) is the material non-cellular, and (2) is it unreinforced and unlaminated?

Coextruded films present a classification challenge because they may consist of multiple polymer layers. If the essential character is polyethylene — typically when PE layers predominate by weight or thickness — classification under 392010 may be appropriate. However, if another polymer layer is functionally dominant, a different heading may apply. Consulting a licensed customs broker is advisable for multi-layer film structures, as CBP has issued binding rulings on specific coextruded constructions.