The tariff classification of PET/Aluminum composite film from Germany

N362921
July 28, 2026
CLA-2-76:OT:RR:NC:N5:116
CATEGORY: Classification
TARIFF NO.: 7607.20.5000
John Boomhover CV International Inc. 3735 Glen Lake Blvd., Suite 100C Charlotte, NC 28208 RE: The tariff classification of PET/Aluminum composite film from Germany Dear Mr. Boomhover: In your letter dated July 7, 2026, you requested a tariff classification ruling. The samples which you provided will be retained by this office. The product under consideration is described as a PET/Aluminum composite film consisting of a 12-micron (0.012 mm) thick layer of PET film, a 6.35-micron (0.00635 mm) thick layer of aluminum foil, and a 2-micron (0.002 mm) thick 2K-PU adhesive which bonds the PET film and foil together. The panels are used in the production of electronic devices as a passive component. You suggest classification of the PET/Aluminum composite film in 3921.90.4090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other plates, sheets, film, foil and strip, of plastics: other: flexible: other. We disagree. The product is comprised of a single layer of aluminum sheet dry laminated to a polyethylene terephthalate (PET) film with adhesive. To be classified in Chapter 39, products comprised of plastic and other materials must retain the essential character of articles of plastic. While the PET film is the thicker layer, the PET and aluminum are of virtually the same weight. The aluminum sheet is not embedded within the PET, nor does it separate two layers of plastic. Further, you indicate that the finished product will be used in the production of electronic devices, and the aluminum layer is required as an electrically conductive component (electrode material). It is the opinion of this office that the finished product does not retain the essential character of plastic and is therefore excluded from classification in 3921.90.4090, HTSUS. The applicable subheading for the PET/Aluminum composite film will be 7607.20.5000, 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 M. Cohen at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division