HS code · 4-digit heading
HS Code 37.04 – Photographic plates, film, paper, paperboard and textiles, exposed but not developed
What HS 37.04 covers
Heading 3704 covers 'Photographic plates, film, paper, paperboard and textiles, exposed but not developed.' This classification is unique as it captures the intermediate stage in the photographic process—materials that have been exposed to light, thus containing a latent image, but have not yet undergone chemical development. It encompasses all the base materials from headings 3701, 3702, and 3703 (plates, film, paper, paperboard, and textiles) once they have been exposed. The crucial boundary is 'not developed,' meaning the image is not yet visible or fixed. This heading is particularly important for customs valuation, as an exposed but undeveloped film or plate can hold significant intellectual or artistic value, even though it's not yet a finished product. Key sub-categories are defined by the original material type (e.g., exposed 35mm film, exposed X-ray film, exposed photographic paper). For trade compliance, accurate classification is paramount to avoid issues related to valuation, potential intellectual property concerns, and ensuring proper handling for sensitive materials that could be damaged by X-rays during customs inspection. Historically, the transport of exposed but undeveloped materials was common for processing at specialized labs. This heading serves as a critical bridge within Chapter 37, marking the transition from raw sensitised material to an object with potential informational or artistic content, prior to its final developed state.
- Covers
- Exposed 35mm film rolls (undeveloped)
- Exposed medium format film (undeveloped)
- Exposed large format sheet film (undeveloped)
- Exposed X-ray film (undeveloped)
- Exposed instant print film packs (undeveloped)
- Exposed photographic printing paper (undeveloped)
- Exposed photographic plates (undeveloped)
- Exposed cinematographic raw stock (undeveloped, if not covered by 3706)
- Exposed micrographic film (undeveloped)
- Exposed aerial photography film (undeveloped)
- Exposed scientific photographic plates (undeveloped)
- Exposed dental X-ray film (undeveloped)
- Exposed photolithographic paper (undeveloped)
- Exposed photographic canvas (undeveloped)
- Exposed security X-ray film (undeveloped)
- Exposed infrared film (undeveloped)
- Exposed UV sensitive plates (undeveloped)
- Exposed high-resolution film (undeveloped).
- Examples
A team of researchers returns from an archaeological expedition in Egypt with exposed (undeveloped) large format sheet film, which is then air-freighted to a specialized darkroom facility in Germany for careful processing. A hospital in a remote part of Africa sends its exposed (undeveloped) X-ray film to a diagnostic center in France for development and expert analysis, transported via secure courier services. An independent filmmaker ships exposed (undeveloped) 35mm motion picture raw stock from a shoot in Canada to a film laboratory in the United States for development and scanning. Additionally, a nature photographer based in Iceland might send several rolls of exposed 120 film to a custom lab in the UK, and a forensic team could transport exposed photographic plates from a crime scene in one country to a specialized lab in another.
Subheadings under 37.04 1
Codes often confused with 37.04
Common mistake. The most common misclassification for 3704 is confusing it with either 'sensitised, unexposed' materials (3701, 3702, 3703) or 'exposed and developed' materials (3705, 3706). The critical distinction is 'exposed but not developed.' Traders might mistakenly declare undeveloped film as raw stock (3702), leading to incorrect valuation, or as fully developed film (3705), which can have different customs implications, especially if intellectual property is involved. Misclassifying can lead to issues with duties, proper handling requirements (e.g., avoiding further X-ray exposure), and potential delays if customs agents are unsure of the item's state. The 'undeveloped' status is the absolute key.
Top exporters and importers of HS code 3704, 2025
In 2025, the largest exporter of HS code 3704 in UN Comtrade data was Ireland, with 25% of world exports; the largest importer in UN Comtrade data was the United States, with 25% of world imports. Countries that did not report 2025 data are estimated from partner records, which can understate them.
Top exporters 2025 · share of world exports
- 1 Ireland $5.2M 25% of world exports
- 2 France $3.5M 17% of world exports
- 3 Spain $2.8M 13% of world exports
World total: $21M Reported figures on UN Comtrade ↗
Top importers 2025 · share of world imports
- 1 United States $7.0M 25% of world imports
- 2 France $2.2M 8.1% of world imports
- 3 Ireland $2.0M 7.2% of world imports
World total: $28M Reported figures on UN Comtrade ↗
How these figures are built
109 countries reported 2025 trade to UN Comtrade in HS 2022, and their own totals are used. Countries that did not report are estimated from what other countries recorded trading with them. Those estimates miss trade with other non-reporting countries, so they can be low, and a non-reporting country can rank higher than shown or be missing from the list. World totals add both and leave out trade between two non-reporting countries. Figures are in current US dollars; reported imports are mostly valued CIF and exports FOB, and exports include re-exports. The UN Comtrade links show the underlying records; they can also list a few reporters left out here (regional groups and older HS editions).
Source: UN Comtrade (United Nations Statistics Division), 2025 annual data.
Questions about HS 37.04
What is HS code 3704?
HS code 3704 is a 4-digit heading in the Harmonized System that covers: Photographic plates, film, paper, paperboard and textiles, exposed but not developed. Heading 3704 covers 'Photographic plates, film, paper, paperboard and textiles, exposed but not developed.' This classification is unique as it captures the intermediate stage in the photographic process—materials that have been exposed to light, thus containing a latent image, but have not yet undergone chemical development. It encompasses all the base materials from headings 3701, 3702, and 3703 (plates, film, paper, paperboard, and textiles) once they have been exposed. The crucial boundary is 'not developed,' meaning the image is not yet visible or fixed. This heading is particularly important for customs valuation, as an exposed but undeveloped film or plate can hold significant intellectual or artistic value, even though it's not yet a finished product. Key sub-categories are defined by the original material type (e.g., exposed 35mm film, exposed X-ray film, exposed photographic paper). For trade compliance, accurate classification is paramount to avoid issues related to valuation, potential intellectual property concerns, and ensuring proper handling for sensitive materials that could be damaged by X-rays during customs inspection. Historically, the transport of exposed but undeveloped materials was common for processing at specialized labs. This heading serves as a critical bridge within Chapter 37, marking the transition from raw sensitised material to an object with potential informational or artistic content, prior to its final developed state.
What products fall under HS code 3704?
Exposed 35mm film rolls (undeveloped), exposed medium format film (undeveloped), exposed large format sheet film (undeveloped), exposed X-ray film (undeveloped), exposed instant print film packs (undeveloped), exposed photographic printing paper (undeveloped), exposed photographic plates (undeveloped), exposed cinematographic raw stock (undeveloped, if not covered by 3706), exposed micrographic film (undeveloped), exposed aerial photography film (undeveloped), exposed scientific photographic plates (undeveloped), exposed dental X-ray film (undeveloped), exposed photolithographic paper (undeveloped), exposed photographic canvas (undeveloped), exposed security X-ray film (undeveloped), exposed infrared film (undeveloped), exposed UV sensitive plates (undeveloped), exposed high-resolution film (undeveloped).
What are common misclassifications for HS code 3704?
The most common misclassification for 3704 is confusing it with either 'sensitised, unexposed' materials (3701, 3702, 3703) or 'exposed and developed' materials (3705, 3706). The critical distinction is 'exposed but not developed.' Traders might mistakenly declare undeveloped film as raw stock (3702), leading to incorrect valuation, or as fully developed film (3705), which can have different customs implications, especially if intellectual property is involved. Misclassifying can lead to issues with duties, proper handling requirements (e.g., avoiding further X-ray exposure), and potential delays if customs agents are unsure of the item's state. The 'undeveloped' status is the absolute key.
Which countries are the top exporters of goods under HS code 3704?
In 2025, the top exporters of HS code 3704 in UN Comtrade data were Ireland ($5.2M, 25% of world exports), France ($3.5M) and Spain ($2.8M). World exports came to about $21M, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Countries that did not report 2025 data are estimated from partner records, which can understate them.
Which countries are the top importers of goods under HS code 3704?
In 2025, the top importers of HS code 3704 in UN Comtrade data were the United States ($7.0M, 25% of world imports), France ($2.2M) and Ireland ($2.0M). World imports came to about $28M, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Countries that did not report 2025 data are estimated from partner records, which can understate them.
How is HS code 3704 structured?
HS code 3704 is a 4-digit heading under Chapter 37 of the Harmonized System. The first 2 digits (37) identify the chapter, and digits 3-4 (04) specify the heading. This code contains multiple 6-digit subheadings for precise product classification.