The tariff classification of aluminum foil from India

N350314
July 11, 2025
CLA-2-76:OT:RR:NC:N5:116
CATEGORY: Classification
TARIFF NO.: 7607.11.3000; 9903.85.02; 9903.01.33
Ms. Shirley Moore Moore Customs Brokers Inc. 335 N Oakland Circle McDonough, Georgia 30253 RE: The tariff classification of aluminum foil from India Dear Ms. Moore: In your letter dated June 17, 2025, you requested a tariff classification ruling on behalf of your client, Raviraj Foils Limited. The product under consideration is light gauge aluminum foil. You indicate that this foil is made from type 1235 aluminum alloy and measures 0.007 mm in thickness. The foil will be imported in coils and has not been backed. The applicable subheading for the light gauge aluminum foil will be 7607.11.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for aluminum foil (whether or not printed, or backed with paper, paperboard, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0.2 mm: not backed: rolled but not further worked: of a thickness not exceeding 0.15 mm: of a thickness not exceeding 0.01 mm. The rate of duty will be 5.8 percent ad valorem. On March 12, 2025, Presidential proclamations 10895 and 10896 imposed additional tariffs on products of steel and aluminum. Additional duties for steel and aluminum products of 50 percent are reflected in Chapter 99, heading 9903.81.87 for steel and heading 9903.85.02 for aluminum. Products classified under subheading 7607.11.3000, HTSUS, may be subject to additional duties. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.85.02, in addition to the Chapter 72, 73 or 76 subheadings listed above. Please note that steel products admitted to a U.S. foreign trade zone under “privileged foreign status” before March 12, 2025, and entered for consumption on or after March 12, 2025, may be subject to additional duties under heading 9903.81.88, HTSUS. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries,

including India, will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.33, in addition to subheading 7607.11.3000, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/current. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Angelia Amerson at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division