Of aluminium alloys

Subheading 7606 92 of the Combined Nomenclature covers flat-rolled products of aluminium alloys, in the form of plates, sheets and strip, with a thickness not exceeding 0.2 mm - commonly referred to as aluminium alloy foil. The 0.2 mm threshold is the critical criterion distinguishing this subheading from subheading 7606 12 (aluminium alloys, thickness exceeding 0.2 mm) and from heading 7607 (aluminium foil, thickness below 0.2 mm without backing). Products with a thickness of exactly 0.2 mm are classified in this subheading. Aluminium alloy foil is produced mainly from 3000-series alloys (e.g. 3003, 3004 - Al-Mn) and 8000-series alloys (e.g. 8011, 8079 - Al-Fe) by cold rolling to very small thicknesses. Products covered by this subheading are used in packaging (pharmaceutical blister packs, multilayer food packaging, trays), construction (thermal and acoustic insulation), the cable industry (cable shielding) and in the manufacture of electrolytic capacitors and batteries. Importers must hold a mill test certificate confirming the alloy composition and product thickness. Technical documentation must precisely specify both the chemical composition (alloy designation) and the nominal thickness with tolerances.

Aluminium alloy foil covered by subheading 7606 92 has been subject to the full CBAM mechanism since 1 January 2026 under Regulation (EU) 2023/956. The CBAM obligation is particularly significant for this product given the intensity of imports from Asian countries where aluminium production relies heavily on coal-based electricity. The importer must hold authorised CBAM declarant status and submit quarterly CBAM declarations containing embedded emissions data at the level of each imported lot of foil - expressed in tonnes of CO2 equivalent per tonne of product. CBAM certificates are purchased from the competent national authority at a price corresponding to EU ETS allowances and must be reconciled by 31 May of the following year. Embedded emissions depend on the share of primary and secondary aluminium and on the energy mix in the production process. Additional TARIC Q-series codes are required in the customs declaration. Standard import documentation includes: commercial invoice with technical parameters (alloy, thickness, width, temper), transport document (CMR, B/L or AWB), mill test certificate with chemical analysis and thickness specification, proof of origin for preferential rates, and the importer's EORI number. Foil intended for food contact must comply with the requirements of Regulation (EC) No 1935/2004. Current customs duties must be verified in the EU TARIC system.

Aluminium alloy foil of subheading 7606 92 is a globally intensively traded product category, imported into the EU primarily from China. Imports from China may be subject to anti-dumping (AD) measures applied by the European Union - importers are required to verify the current status of AD measures in TARIC for the specific subheading and exporting country code before each import, as measures may be active or under review. Anti-dumping measures on aluminium foil from China have been imposed and renewed by the European Commission on multiple occasions - importers should monitor the Official Journal of the EU for anti-dumping regulations relating to aluminium products. Aluminium products of CN Chapter 76 may be subject to safeguard measures with a TRQ system - imports above the quarterly quantitative limit attract additional duty. Imports of aluminium products from Russia and Belarus are subject to EU sanctions restrictions. Preferential rates under EU FTAs (CETA, JEFTA, South Korea, UK, Vietnam and Ukraine) can reduce the duty burden, provided a valid proof of preferential origin is submitted. When calculating the total import cost of aluminium alloy foil, importers must include MFN or AD duty, CBAM certificates and VAT. All trade measures must be verified in the EU TARIC system.

CN code 7606 92 of the Combined Nomenclature classifies aluminium alloy foil <= 0.2 mm within Chapter 76 of the EU customs tariff for aluminium. Classification depends on the degree of processing (unwrought aluminium, semi-finished products, finished articles), alloy composition (unalloyed aluminium, alloy series 1000-7000) and product form (ingots, bars, sheets, foil, tubes, profiles). Note 1 to Chapter 76 defines aluminium alloys by minimum aluminium content. Aluminium imports are subject to standard TARIC duty rates and potential anti-dumping duties for selected countries of origin.