The tariff classification of aluminum laminate film from Germany

N359641
March 31, 2026
CLA-2-76:OT:RR:NC:N5:116
CATEGORY: Classification
TARIFF NO.: 7607.20.5000
Mr. Lucas Theo Rehaag German American Chamber of Commerce, Inc. 120 Wall Street, 20th Floor New York, NY 10005 RE: The tariff classification of aluminum laminate film from Germany Dear Mr. Rehaag: In your letter dated March 10, 2026, you requested a tariff classification determination for your client, Aluminium Féron GmbH & Co. KG of Düren, Germany. The samples which you provided will be retained by this office. The product under consideration is identified as aluminum laminate film used in the furniture industry. The material is a 5-layer composite structure, composed of 1) a 0.07-millimeter (mm) layer of disposable protective film, 2) a 0.02 to 0.04 mm topcoat, 3) a 0.08 mm layer of aluminum foil, 4) a 0.015 mm of adhesive, and 5) a 0.125 mm layer of Polyethylene Terephthalate (PET) Film. The adhesive is used to bond the aluminum layer to the PET layer. The function of the PET layer is to provide support, additional strength, stability, and protection to the foil. The principal use of the aluminum foil layer is to deliver the visual and tactile characteristics of real metal, including authentic metallic reflectivity and light diffusion. The applicable subheading for the aluminum adhesive foil will be 7607.20.5000, 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: Backed: Other.” The general rate of duty will be free. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either

the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Neil Cohen at [email protected].
Sincerely,
(for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division