HS code 7607: how aluminium foil is classified
Six digits decide your duty rate, your licensing requirements and whether an anti-dumping measure applies to your shipment. Most of the disputes we see start with this line on an invoice.
Aluminium foil sits under HS heading 7607. Three subheadings matter: 7607.11 for rolled but not further worked, unbacked foil; 7607.19 for other unbacked foil; 7607.20 for backed foil. Countries add their own 8- or 10-digit splits on top of these six digits.
The HS system is harmonised only to six digits. Everything beyond that is national, which is why the same roll of foil can carry a different full code in Hamburg, Lagos and Jebel Ali — and why a supplier quoting a Chinese export code is only giving you half an answer.
The structure of 7607
| Code | Description | Typical product |
|---|---|---|
| 7607.11 | Not backed, rolled but not further worked | Plain household and catering foil |
| 7607.19 | Not backed, other | Foil that has been embossed, perforated, printed or otherwise worked |
| 7607.20 | Backed | Foil laminated to paper, plastic or board |
The dividing line between 7607.11 and 7607.19 is "further worked". Plain foil, even if slit and rewound into a retail roll, stays in 7607.11 — slitting and rewinding are considered finishing, not working. Embossing it, perforating it or printing directly onto the foil moves it to 7607.19.
Printing the carton does not change the classification of the foil inside. Printing on the foil itself is a different matter and may move the product to 7607.19. If you are buying printed foil rather than foil in a printed box, get the classification confirmed in writing by your broker before ordering.
Where thickness and width enter
Below six digits, national codes frequently subdivide by thickness. China's own export schedule, for example, splits unbacked foil at the 0.007 mm boundary. Other jurisdictions subdivide differently, and some use width bands.
This matters practically because anti-dumping scope is often written around thickness and width, not just the code. The EU measures on Chinese foil cover 0.008–0.018 mm, up to 650 mm wide, over 10 kg per roll. A 20 μm product sits outside that band; an 18 μm product sits on the edge of it.
The four ways it goes wrong
1. Using the Chinese export code abroad
The code on a Chinese export declaration is a Chinese domestic code. It may map to the same six digits and diverge entirely at eight. Your import declaration must use your own country's schedule.
2. Classifying by end use instead of by product
"Kitchen foil" is not a classification. The system classifies by material, form and processing — not by where the product is sold.
3. Assuming backed and unbacked are interchangeable
7607.20 covers laminated foil, which carries a different duty rate in most schedules and is usually outside anti-dumping scopes written for plain foil. A laminate is not a workaround for a duty on foil; it is a different product for different purposes.
4. Letting the supplier choose
The importer of record is legally responsible for the declaration. If the supplier's suggested code turns out to be wrong, the assessment, penalties and interest land on you.
How to verify a code
- Start from the product — thickness in mm, width, whether backed, whether further worked.
- Use your own tariff schedule, not the supplier's invoice.
- Check binding tariff information where available — the EU issues BTIs, and similar advance rulings exist in many jurisdictions.
- Cross-check against the anti-dumping scope, which is defined separately from the tariff code and may be narrower or wider.
Frequently asked questions
Is 7607.11 the right code for household foil rolls?
Usually yes, at the six-digit level, for plain unbacked foil that has been slit and rewound into a retail roll. Your national eight- or ten-digit code may differ, and it is the national code that determines the duty rate.
Does the carton change the classification?
No. Packaging is not part of the product classification — the foil is classified as foil whether it arrives in a printed dispenser box or a plain carton. Only working on the foil itself changes the subheading.
Can I use a different code to reduce duty?
No. That is customs fraud, and the liability sits with the importer of record. Duty can be reassessed retroactively with penalties. See the anti-dumping guide for the legitimate routes.
Sources
- World Customs Organization, Harmonized System Explanatory Notes, heading 7607.
- European Commission TARIC database.
- Related: Anti-dumping duties by country.