Backed

Subheading 7607 20 of the Combined Nomenclature (CN) covers aluminium foil of aluminium alloys, with a thickness not exceeding 0.2 mm, both backed and not backed. Aluminium alloys for the purposes of CN Chapter 76 are materials in which aluminium predominates by weight, but the aluminium content is below 99% or specified impurity limits are exceeded, as defined in the Notes to Chapter 76. Alloy foil is produced primarily from 3000-series alloys (Al-Mn, e.g. 3003, 3004) and 8000-series alloys (Al-Fe, e.g. 8006, 8011, 8079). The 8000-series alloys, thanks to their iron and silicon content, offer higher mechanical strength, better thermal processing resistance and excellent cold-rolling ductility to very low thicknesses - making them the industry standard for blister and technical foil. The decisive classification criterion is chemical composition (alloy, not unalloyed aluminium) - regardless of the presence or absence of a backing, the product is classified in subheading 7607 20. Principal applications include pharmaceutical blister packaging (PVC/aluminium and aluminium/aluminium blisters), confectionery wrapping foil (chewing gum, chocolate), capacitor foil for aluminium electrolytic capacitors, technical foil for cable insulation and EMI shielding, and foil for aseptic and sterile packaging. Distinction from subheadings 7607 11/7607 19 (unalloyed foil) requires confirmation of chemical composition by mill test certificate. Where classification is uncertain, a BTI application is recommended.

From 1 January 2026, aluminium alloy foil covered by subheading 7607 20 is fully subject to the CBAM mechanism under Regulation (EU) 2023/956. The CBAM obligation is particularly significant for this subheading given the substantial share of imports from countries with carbon-intensive primary aluminium production, especially China. The importer must be registered as an authorised CBAM declarant and submit quarterly declarations containing embedded emissions data at the level of each consignment - expressed in tonnes of CO2 equivalent per tonne of product. CBAM certificates are purchased at the EU ETS allowance price and reconciled by 31 May of the following year. Embedded emissions depend on the share of primary and secondary aluminium and the producer's energy mix. Imports from countries with an equivalent ETS system (e.g. Switzerland) may benefit from partial or full CBAM exemption. Additional TARIC Q-series codes must be included in the customs declaration. Required import documentation includes: a commercial invoice with technical parameters (alloy grade, thickness, width, temper, EN standard, backed or not), transport document (CMR, B/L or AWB), mill test certificate with full chemical analysis and thickness specification, proof of preferential origin, and the importer's EORI number. Blister foil and foil in contact with food or pharmaceuticals must comply with Regulation (EC) No 1935/2004 and applicable GMP requirements. Current duty rates must be verified in the EU TARIC system.

Aluminium alloy foil of subheading 7607 20 imported from China may be subject to anti-dumping (AD) measures applied by the European Union. EU anti-dumping measures on aluminium foil from China cover both unalloyed and alloy foil - the European Commission has imposed, reviewed and renewed these measures on multiple occasions. Importers are required to verify the current status, scope and rates of AD measures in TARIC for the specific CN code and exporting country code before every import. Aluminium products of CN Chapter 76 may additionally be subject to safeguard measures with a tariff rate quota (TRQ) system - imports above the quarterly quantitative limit attract additional duties that can significantly affect transaction viability. Imports of aluminium products from Russia and Belarus are subject to EU sanctions restrictions - the current sanction status must be verified before concluding any contract. Preferential rates under EU free trade agreements (CETA with Canada, JEFTA with Japan, FTAs with South Korea, the United Kingdom, Vietnam and Ukraine) can reduce the duty burden significantly, 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 20 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.