铝膜
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 7607116090 | 40.3% | CN | US | Official Doc |
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🏭 Aluminum Film & Composite Membranes: HS Code Classification & Customs Clearance Guide | 2026 Tariff Analysis for US-China Trade
🌐 HS Code Reference & Customs Strategy | Latest 2026 Tariff Breakdown | Professional Compliance Guide
📌 I. Product Definition: What is "Aluminum Film"?
"Aluminum Film" (铝膜) is a broad term that can refer to different physical forms and material compositions in international trade. It is crucial to distinguish between:
- Pure Aluminum Foil/Film: Thin sheets of aluminum metal, often rolled.
- Aluminum-Plastic Composite Film: A laminated structure consisting of aluminum foil bonded with plastic polymers (PE, PP, PET, etc.).
⚠️ Key Distinction Point: - If the product is 100% aluminum metal in film form → It falls under Chapter 76 (Aluminum). - If the product is a laminated composite where plastic is a significant component → It may fall under Chapter 39 (Plastics) or Chapter 48 (Paper/Cardboard), depending on the structure and primary material characteristic.
📦 II. HS Code Classification Details (2026 Authoritative Reference)
Based on the provided data, here are the four potential HS Codes and the rationale for each classification:
| HS Code | Product Description | Summary / Rationale | Total Tax Rate |
|---|---|---|---|
7607.11.60.90 |
Aluminum Foil (Thin) | "Aluminum film" refers to the aluminum material in film form, matching the physical form of aluminum foil (including thin films). | 40.3% |
3921.90.50.50 |
Other Plastic Films | Aluminum-plastic composite film conforms to the 'film' form. Since it contains plastic components, it aligns with 'plastic-made' and 'other' categories without conflict. | 39.8% |
7607.20.10.00 |
Other Aluminum Foil | The name 'Aluminum' corresponds to the material requirement, and 'Film' matches the form requirement, fitting the characteristics of thin foil. | 13.7% |
3921.90.40.10 |
Other Plastic Sheets/Film | Aluminum-plastic composite film fits the 'plastic' material attribute and 'film' form characteristic. It belongs to the 'other' category outside of 'paper-reinforced'. | 39.2% |
🔍 Critical Analysis: - Why Two Different Aluminum Codes?
7607.11vs7607.20. The distinction often lies in the thickness, rolling process, or specific usage.7607.11typically covers rolled foil, while7607.20might cover other forms or specific thickness ranges not covered in 11. - Why Two Different Plastic Codes?3921.90.50vs3921.90.40. This depends on the specific plastic polymer type or whether the film is reinforced (e.g., with paper or metal, but classified primarily as plastic based on essential character rules).
💰 III. 2026 Latest Tariff Rate Breakdown (Including Surcharges)
✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN)
✅ Effective Date: November 10, 2025 (and subsequent imports)
🎯 1. 7607.11.60.90 – Aluminum Foil (Thin)
| Item | Detail |
|---|---|
| Base Tariff | 5.3% |
| Section 301 Surcharge | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Effective Rate | 40.3% |
| Calculation Basis | CIF Value × 40.3% |
| De Minimis Exemption | ❌ Not Applicable (High value threshold exceeded, standard trade rules apply) |
| Legal Basis | Section 301 (USITC Footnote), Section 122 (Presidential Proclamation) |
📌 Explanation: - This classification assumes the product is primarily aluminum. - The 25% is the standard Section 301 tariff for aluminum products from China. - The 10% is an additional Section 122 tariff, potentially applied under national security or trade balance provisions. - Total Cost Impact: High. Importers must budget for over 40% tax burden.
🎯 2. 3921.90.50.50 – Other Plastic Films (Composite)
| Item | Detail |
|---|---|
| Base Tariff | 4.8% |
| Section 301 Surcharge | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Effective Rate | 39.8% |
| Calculation Basis | CIF Value × 39.8% |
| De Minimis Exemption | ❌ Not Applicable |
| Legal Basis | Section 301 (USITC Footnote), Section 122 |
📌 Explanation: - If the customs authority determines the plastic layer gives the product its essential character, this code may apply. - The tariff structure is nearly identical to the aluminum-only code due to the same surcharges. - Savings: Only 0.5% lower than the pure aluminum foil code. Negligible difference.
🎯 3. 7607.20.10.00 – Other Aluminum Foil (Lowest Tax Option)
| Item | Detail |
|---|---|
| Base Tariff | 3.7% |
| Section 301 Surcharge | 0.0% |
| Section 122 Tariff | +10.0% |
| Total Effective Rate | 13.7% |
| Calculation Basis | CIF Value × 13.7% |
| De Minimis Exemption | ❌ Not Applicable |
| Legal Basis | Section 122 Only |
📌 Explanation: - This is the most cost-effective classification if applicable. - The 0% Section 301 rate is critical. This implies that this specific subheading (
7607.20.10.00) might be excluded from the most aggressive 301 tariffs, or it refers to a specific type of aluminum foil (e.g., non-rolled, specific alloy) that is exempt. - Caution: This classification is strict. It applies only if the product perfectly matches the definition of "Other Aluminum Foil" under this subheading. Misclassification here can lead to severe penalties.
🎯 4. 3921.90.40.10 – Other Plastic Sheets/Film (Composite)
| Item | Detail |
|---|---|
| Base Tariff | 4.2% |
| Section 301 Surcharge | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Effective Rate | 39.2% |
| Calculation Basis | CIF Value × 39.2% |
| De Minimis Exemption | ❌ Not Applicable |
| Legal Basis | Section 301 (USITC Footnote), Section 122 |
📌 Explanation: - Similar to
3921.90.50.50, this is a plastic-composite classification. - The 39.2% rate is still very high. - Difference from 50.50: The base rate is slightly lower (4.2% vs 4.8%), resulting in a 0.6% total savings.
🛠️ IV. Customs Clearance Practical Advice (Pitfall Avoidance)
✅ 1. Document Preparation Checklist (Mandatory)
| Document | Required | Purpose |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Detail thickness, material composition (Al% vs Plastic%), and lamination structure. |
| ✅ Cross-Sectional Diagram | ✔️ | Visually prove the layer structure (e.g., Al/PE/PET) to support composite classification. |
| ✅ Material Safety Data Sheet (MSDS) | ✔️ | Confirm no hazardous materials that could trigger additional inspections. |
| ✅ Commercial Invoice | ✔️ | Clearly state "Aluminum Film" or "Aluminum-Plastic Composite Film" and HS Code. |
| ✅ Packing List | ✔️ | Ensure weights and dimensions match the invoice. |
| ✅ Certificate of Origin (CO) | ✔️ | Essential for verifying Chinese origin and applying correct surcharges. |
| ✅ Pre-Ruling Document | ✔️ | Highly Recommended – Obtain an Advance Ruling from CBP to confirm the correct HS Code. |
✅ 2. Classification Strategy & Risk Management
| Scenario | Recommended HS Code | Risk Level | Reason |
|---|---|---|---|
| Pure Aluminum Foil | 7607.11.60.90 |
Medium | Standard classification, but high tax (40.3%). |
| Composite Film (Plastic Essential Character) | 3921.90.50.50 or 3921.90.40.10 |
Medium | Slightly lower tax than pure aluminum, but requires proof of plastic dominance. |
| Specific Aluminum Foil (Exempt from 301) | 7607.20.10.00 |
High Risk / High Reward | Best Tax Rate (13.7%). Must strictly meet the subheading definition. Misclassification leads to heavy fines. |
| Unknown Composite | None | Fatal | Guessing HS Code leads to delays, audits, and back taxes. |
🔥 Golden Rule: "Structure Defines Code, Composition Dictates Tax!" - If the aluminum layer is merely a barrier (thin) and the plastic provides structural integrity → Consider Chapter 39. - If the product is primarily aluminum foil with a plastic coating → Stick to Chapter 76.
✅ 3. Special Cases & Optimization
| Case | Handling Advice |
|---|---|
| Thin Foil vs. Composite | If the aluminum layer is <0.02mm, it might be treated as foil. If thicker, it may be plate/sheet. Check Chapter 76 Notes. |
| Section 301 Exclusions | Check if your specific product model was removed from the Section 301 exclusion list (if any). Most aluminum/plastic films are still included. |
| Section 122 Applicability | The 10% Section 122 tariff is relatively new and may change. Verify with current Customs Bulletins. |
| Country of Origin Marking | Ensure "Made in China" is clearly marked on the product and packaging to avoid anti-dumping duties. |
🌍 V. Global Market Comparison (2026 Snapshot)
| Market | Likely HS Code | Tariff Rate (China Origin) | Key Certification |
|---|---|---|---|
| 🇺🇸 USA | 7607.11.60.90 / 3921.90.50.50 |
13.7% - 40.3% | None specific, but ASTM standards may apply. |
| 🇪🇺 EU | 7607.11.00 / 3920.91.00 |
~0% - 5% | REACH, RoHS |
| 🇨🇳 China | 7607.11.00 / 3921.90.90 |
5% - 10% | CCC (if applicable) |
| 🇻🇳 Vietnam | 7607.11.00 |
0% (if FTA applies) | None |
📌 Conclusion: - USA is the most expensive market due to Section 301 and Section 122 tariffs. - EU and China offer significantly lower tariffs but have stricter environmental regulations (REACH, RoHS). - Strategy: Consider sourcing from or assembling in Vietnam, Mexico, or Thailand to mitigate US tariffs, if supply chain allows.
📌 VI. Common Mistakes & Pitfalls (Lessons Learned)
❌ Mistake 1: Using "Aluminum Film" as the only description. 👉 Consequence: Customs may classify as the highest duty rate or request further documentation. ✅ Fix: Use precise terms like "Aluminum-Plastic Composite Laminated Film" or "Rolled Aluminum Foil, 0.02mm".
❌ Mistake 2: Ignoring the Section 122 Tariff. 👉 Consequence: Underpayment by 10%, leading to penalties and interest. ✅ Fix: Always include Section 122 in your cost calculation for US imports.
❌ Mistake 3: Assuming all Aluminum Foil is taxed the same.
👉 Consequence: Missing out on the 13.7% rate (7607.20.10.00) by misclassifying as 7607.11.60.90 (40.3%).
✅ Fix: Conduct a technical review of the foil's thickness and processing to see if it qualifies for the lower-tariff subheading.
❌ Mistake 4: Composite Film Misclassification.
👉 Consequence: Declaring as pure plastic (3921) when it's primarily aluminum, or vice versa, leading to audits.
✅ Fix: Provide a detailed material breakdown and layer structure diagram.
🎯 VII. Conclusion: Strategic Compliance for Cost Efficiency
🎯 Key Takeaways:
1. 7607.20.10.00 is the Holy Grail: If your product qualifies, the 13.7% tax rate is significantly cheaper than the 39-40% rates for other codes.
2. Composite Films are Expensive: Whether classified as aluminum or plastic, composite films face high tariffs due to Section 301 and 122.
3. Documentation is Key: Precise descriptions, material specs, and cross-section diagrams are essential to defend your HS Code choice.
4. Plan Ahead: Consider pre-rulings and supply chain diversification to manage tariff risks.
📌 Pro Tip:
📞 Consult a Licensed Customs Broker: Before shipping, engage a broker to file for an Advance Ruling with U.S. Customs and Border Protection (CBP). This provides legal certainty and protects you from retroactive duties.
📣 Act Now:
🚀 Optimize Your Supply Chain, Minimize Tariff Exposure, and Ensure Smooth Clearance.
💼 Every Percent of Tax Saved is Pure Profit!
✨ Precision Classification, Predictable Costs, Successful Trade! 💼
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About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) — Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) — More specific grouping within the chapter
- Subheading (6 digits) — Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) — Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate — The standard duty rate applied to WTO members
- General rate — Applied to countries without trade agreements
- Trade remedy duties — Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.