Product classification
HS code for Specialty 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 specialty film under HS 3702.39
Specialty film under HS code 3702.39 is classified based on its physical form and chemical properties. This code specifically covers photographic film in rolls that is sensitized and unexposed. To qualify for this heading, the film must not have sprocket holes (perforations) and must have a width not exceeding 105 mm. Furthermore, this specific subheading is reserved for films that do not use silver halide emulsions and are not intended for color photography. These films are often used in specialized industrial, medical, or technical imaging applications where standard silver-based photography is not required. The classification depends heavily on the absence of perforations and the specific width, as these factors determine the machinery the film is compatible with and its intended industrial use.
- Covers
- Sensitized unexposed technical film in rolls
- Non-perforated industrial imaging film
- Monochrome specialty rolls under 105mm width
- Diazo or photo-polymer sensitized films
- Graphic arts film without sprocket holes
- Microfilm rolls without silver halide
- Also under 3702.39
- Agfa Structurix (specialized variants)
- Fujifilm (industrial films)
- Kodak (niche industrial films)
Codes often confused with 3702.39
Common mistake. This product is often confused with HS code 3702.31, which is for film with silver halide emulsion for color photography. Another common error is using 3702.41, which applies to rolls of a width exceeding 610 mm. If the film has sprocket holes, it must be classified under different subheadings of 3702, such as 3702.52. Importers must verify the chemical coating and the presence of perforations to avoid these common errors.
Top exporters and importers of HS 370239 (the code used for specialty film), 2025
In 2025, the largest exporter of HS 370239 (the code used for specialty 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 specialty 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 specialty film
Brazil classifies specialty 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 specialty film
What is the HS code for Specialty film?
The HS code for Specialty 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)). The HS code for sensitized, unexposed specialty film in rolls, without sprocket holes and under 105mm width (non-silver halide), is 3702.39.
How do I classify Specialty film for customs?
Specialty 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.
Can this code be used for X-ray film?
No, X-ray film in rolls is typically classified under HS code 3702.10, regardless of the width or emulsion type.
Which countries are the top exporters of specialty film (HS 370239)?
In 2025, the top exporters of HS 370239 (the code used for specialty 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 specialty film (HS 370239)?
In 2025, the top importers of HS 370239 (the code used for specialty 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 Specialty film the same in all countries?
The base HS code 370239 for Specialty 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 specialty film in Brazil?
In Brazil, specialty film (HS 370239) is classified under NCM 3702.39.00.