Product classification
HS code for Roll film: 3702.39
Photographic film, in rolls, (other than with silver halide emulsion and for colour photography), sensitised, unexposed, without sprocket holes, of a width not exceeding 105mm (other than of paper, paperboard or textiles).
Classification of roll film under HS 3702.39
HS code 3702.39 applies to photographic film in rolls, sensitized and unexposed, that does not utilize a silver halide emulsion and is not intended for color photography. Additionally, this code is restricted to film without sprocket holes and with a width not exceeding 105mm. This classification is highly specific, excluding many common types of consumer and professional films. Chapter 37 governs these items, and the hierarchy of heading 3702 requires a process of elimination. First, the film must be in a roll. Second, it must not be for X-ray use (3702.10). Third, it must meet the width and emulsion criteria. Code 3702.39 serves as a "catch-all" for specialized technical films, such as those used in certain types of microfilming, graphic arts, or industrial applications that do not rely on traditional silver-based chemistry or color-sensitive layers. The absence of sprocket holes is a key technical requirement for this subheading, as perforated films are classified elsewhere in the 3702 hierarchy.
- Covers
- Diazo film rolls (non-silver)
- Photo-resist film for electronics manufacturing
- Microfilm rolls without silver halide emulsion
- Technical graphic arts film under 105mm width
- Sensitized film for offset printing plates
- Also under 3702.39
- Agfa Structurix (specialized variants)
- Fujifilm (industrial films)
- Kodak (niche industrial films)
Codes often confused with 3702.39
Common mistake. This code is often confused with 3702.32, which is for film with silver halide emulsions. If the film is for color photography, it must be classified under 3702.31. Furthermore, if the film has sprocket holes (perforations), it cannot be classified under 3702.39 and must move to subheadings like 3702.52 or 3702.96 depending on its width and length. Width is also a strict boundary; rolls exceeding 105mm are classified under different subheadings.
Top exporters and importers of HS 370239 (the code used for roll film), 2025
In 2025, the largest exporter of HS 370239 (the code used for roll film) in UN Comtrade data was the United States, with 58% of world exports; the largest importer in UN Comtrade data was the United States, with 31% of world imports. Countries that did not report 2025 data are estimated from partner records, which can understate them.
Figures cover everything classified under HS 370239, not only roll film.
Top exporters 2025 · share of world exports
- 1 United States $9.8M 58% of world exports
- 2 Taiwan* ~$1.4M 8.1% of world exports · partner records ↗
- 3 Spain $1.3M 7.6% of world exports
World total: $17M Reported figures on UN Comtrade ↗
Top importers 2025 · share of world imports
- 1 United States $6.5M 31% of world imports
- 2 Spain $2.4M 11% of world imports
- 3 India $1.9M 8.9% of world imports
World total: $21M 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 marked * did not, so their figures add up what other countries recorded trading with them, and their exports are valued at buyers' CIF prices. 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. UN Comtrade records Taiwan as "Other Asia, not elsewhere specified". Saudi Arabia's exports under that code are left out: they are far too large to be trade with Taiwan, so mostly undisclosed partners. 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.
Brazil NCM code for roll film
Brazil classifies roll film under NCM 3702.39.00: HS 3702.39 with 00 added.
Source: Siscomex NCM table, updated Oct 2026. The Portuguese text on each NCM page is the official one.
Questions about roll film
What is the HS code for Roll film?
The HS code for Roll film is 370239 (Photographic film; in rolls, (other than with silver halide emulsion and for colour photography), sensitised, unexposed, without sprocket holes, of a width not exceeding 105mm (other than of paper, paperboard or textiles)).
How do I classify Roll film for customs?
Roll film is classified under HS code 370239 — Photographic film; in rolls, (other than with silver halide emulsion and for colour photography), sensitised, unexposed, without sprocket holes, of a width not exceeding 105mm (other than of paper, paperboard or textiles). This is a 6-digit subheading level code.
What is the HS code for Roll film (non-silver, <105mm)?
The correct HS code for this specific type of photographic roll film is 3702.39.
What does "sensitized and unexposed" mean?
It means the film has been treated with a chemical layer that reacts to light or radiation but has not yet been used to take an image.
Which countries are the top exporters of roll film (HS 370239)?
In 2025, the top exporters of HS 370239 (the code used for roll film) in UN Comtrade data were the United States ($9.8M, 58% of world exports), Taiwan (about $1.4M) and Spain ($1.3M). World exports came to about $17M, 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 roll film (HS 370239)?
In 2025, the top importers of HS 370239 (the code used for roll film) in UN Comtrade data were the United States ($6.5M, 31% of world imports), Spain ($2.4M) and India ($1.9M). World imports 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.
Is the HS code for Roll film the same in all countries?
The base HS code 370239 for Roll film is internationally standardized for the first 6 digits across 200+ countries. Individual countries may add additional digits for national tariff lines and specific classifications.
What is the NCM code for roll film in Brazil?
In Brazil, roll film (HS 370239) is classified under NCM 3702.39.00.