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Technical note · Customs

HS 7606 or 8310? The line that moves duty by 50 points

The same panel carries a different code depending on how far it has been processed, and the difference decides whether a market is viable at all. Where the line falls, and how to declare a mixed container.

Published 29 Oct 2026Section CustomsRead 7 min
Short answer

Bare aluminium sheet and blanks are classified in 7606. Once the panel is printed, or carries reflective film, it becomes a sign of base metal in 8310. The difference is not cosmetic: in the United States it separates a duty burden of roughly 78 per cent from one of about 25 per cent, and in China it separates a zero export rebate from a thirteen per cent one.

The same panel, two classifications
7606 — aluminium plate, sheet, strip8310 — signs of base metal
What it coversUnprinted, unfilmed sheet and blankPrinted, filmed or otherwise finished sign face
US duty (2026)MFN + Section 232 (50%) + Section 301 (25%) ≈ 78%Section 301 only, 25%
EUMFN plus anti-dumping on flat-rolled; in CBAM scopeLow single-digit MFN; outside CBAM Chapter 76
China export rebate0% since December 202413%
Export licenceRequired from January 2026Not required
Unit valueMaterial price per tonneProduct price per square metre

Rates change. Treat this table as the shape of the problem, then confirm the current figure with a customs broker in the destination country before you quote.

Where the line actually falls

Classification follows the state of the goods, not the intention of the buyer. A blank that has been cut, punched and deburred is still 7606 — cutting is not enough. A blank that has been printed with a legend, or laminated with reflective film, has become an article of 8310, because it now has the essential character of a sign.

The awkward cases are the ones in between. Film applied but nothing printed: most customs authorities treat it as 8310, since the reflective face is what makes it a sign. Printed adhesive sheeting supplied in rolls, to be applied by the buyer: that is 3919, not 8310, and not 7606. When a consignment is genuinely ambiguous, the safe move is a written ruling from the destination customs — it takes weeks and it survives audits.

What this means commercially

For a buyer in a 232-affected market, the difference between a blank and a filmed face is the difference between an unviable product and a viable one. That is not a loophole: it is the tariff schedule rewarding a more processed article. But it only holds if the processing is real — film applied in the destination country does not retroactively change the classification of what was imported.

For a Chinese exporter, the same line decides the rebate: 7606 lost its 13 per cent rebate at the end of 2024 and needs an export licence from 2026, while 8310 kept the rebate and needs no licence. A factory that laminates film is, in effect, converting a zero-rebate commodity into a thirteen-per-cent-rebate product.

Declaring a mixed container

  • Declare each product line separately — blanks, filmed signs, channel and film rolls are four different codes and four different duty treatments.
  • Keep the packing list aligned to the declaration: carton numbers, pallet marks and quantities should match line by line, or the entry gets held for inspection.
  • Carry the mill certificate for the aluminium content and the film datasheet for the coated content; both are routinely requested on filmed signs.
  • Never describe a mixed container as “traffic safety products”. That phrase tells the broker nothing and guarantees a query.
FAQ

Questions on this note

Still unresolved? Send the question with your drawing — we answer in writing, not in a sales call.
Is a blank with holes punched still 7606?

Yes. Cutting, punching and deburring do not change the essential character of sheet. It becomes 8310 when it is printed or carries reflective film.

What about film supplied in rolls?

3919 — self-adhesive plastic sheet. It is neither an aluminium product nor a finished sign, which is why a container of blanks plus film has to be declared as two lines.

Does the classification change the origin rules?

Yes, and this is where it gets expensive. Processing that changes the tariff heading can change origin for preference purposes. If you are claiming a preferential rate, have the origin calculation checked before you ship, not after.

Keep looking

Related

Most orders ship with material and finished goods on the same container — these lines combine well.

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