Not backed - Rolled but not further worked

Subheading 7607 11 of the Combined Nomenclature (CN) covers aluminium foil of unalloyed aluminium (minimum 99% Al content), with a thickness not exceeding 0.2 mm, not backed - meaning the foil is self-supporting, without a carrier layer of paper, plastic or any other material. Unalloyed aluminium corresponds to the 1000-series grades under EN 573, most commonly 1050A, 1100, 1200 and 1235. The decisive classification criteria are: unalloyed aluminium composition, thickness not exceeding 0.2 mm (products at exactly 0.2 mm are classified under heading 7606), and the absence of a backing. Unbacked foil of this subheading is produced by cold rolling to very small thicknesses, typically from 6 to 150 micrometres, resulting in a one-side-matte finish from double-rolling of paired strips. Its excellent barrier properties against moisture, gases and light make it the dominant material for flexible packaging. Principal applications include kitchen foil for wrapping and baking, foil containers for foodservice, flexible packaging for food, tobacco and pharmaceutical products, reflective thermal insulation and cable wrapping. Distinction from subheading 7607 19 (unalloyed foil, backed) and 7607 20 (alloy foil) requires verification of chemical composition and the presence or absence of a backing layer. Where classification is uncertain, an application for Binding Tariff Information (BTI) in the EBTI system is recommended.

From 1 January 2026, unalloyed aluminium foil not backed covered by subheading 7607 11 is fully subject to the CBAM (Carbon Border Adjustment Mechanism) under Regulation (EU) 2023/956. The importer must be registered as an authorised CBAM declarant with the competent national authority and submit quarterly CBAM declarations containing embedded emissions data expressed in tonnes of CO2 equivalent per tonne of product for each consignment. CBAM certificates must be purchased at the EU ETS allowance price and reconciled by 31 May of the following year. Embedded emissions in aluminium foil depend on the share of primary and secondary aluminium in the production input and on the producer's energy mix - primary aluminium from electrolysis generates many times higher emissions than recycled secondary aluminium. Importers should obtain verified emissions data from their supplier or apply the conservative default values published by the European Commission. Additional TARIC Q-series codes must be indicated in the customs declaration. Standard import documentation includes: a commercial invoice with technical parameters (alloy grade, thickness, strip width, temper, EN standard), transport document (CMR, B/L or AWB), mill test certificate with chemical analysis and thickness specification, proof of preferential origin if claiming preferential duty rates, and the importer's EORI number. Foil intended for food contact must comply with the requirements of Regulation (EC) No 1935/2004 and be accompanied by the manufacturer's declaration of compliance. Current MFN duty rates must be verified in the EU TARIC system.

Unalloyed aluminium foil not backed of subheading 7607 11 imported from China may be subject to anti-dumping (AD) measures applied by the European Union. Anti-dumping measures on aluminium foil from China have been imposed, reviewed and renewed by the European Commission on multiple occasions - importers are required to verify the current status, scope and rates of AD measures in the TARIC system for the specific CN code and exporting country code before every import. Anti-dumping duty rates can be substantial and significantly increase the total import cost. Aluminium products of CN Chapter 76 may be subject to safeguard measures - importers should verify the availability and quarterly utilisation level of tariff rate quotas (TRQ) in TARIC. Imports above the TRQ limit attract additional duties. Imports of aluminium products from Russia and Belarus are subject to EU sanctions restrictions - the sanction status must be verified before placing any order. Preferential rates under EU free trade agreements (CETA with Canada, JEFTA with Japan, FTAs with South Korea, the United Kingdom, Vietnam and Ukraine) can significantly reduce the duty burden, provided rules of origin are met and a valid proof of preferential origin is submitted (EUR.1 certificate, invoice declaration or REX statement). The total import cost must include MFN or AD duty, CBAM certificates and VAT. All applicable trade measures must be verified in the EU TARIC system.

CN code 7607 11 of the Combined Nomenclature classifies unalloyed aluminium foil, not backed 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.