Customs tariff classification: reversing cameras and LED floodlights

Commission Implementing Regulations (EU) 336/2014 and 337/2014 of 28 March 2014 regulate the classification of reversing cameras for cars and LED floodlights in the Combined Nomenclature:

Rear view cameras: VO (EU) 336/2014

Under this Regulation the following product is classified under CN code 8528 72 40:

“A retail product assembly (so-called wireless reversing camera system) for installation in motor vehicles, comprising the following components:

  • a day/night television camera with a CMOS sensor and a 2.4 mm lens,
  • a wireless video signal transmitter with an antenna,-
  • a 2.4 GHz wireless video signal receiver with a 7-inch (17.8 cm) color liquid crystal display (LCD) and 480 × 240 pixel resolution. It is equipped with function keys and an AV interface for connecting external audio or video devices.

The TV camera does not pick up sound. The goods are intended for use in cars, buses or trailers, for example, and enable the driver to see what is behind the vehicle.”

Since none of the equally important components of this product, namely the television transmitter (subheading 8525 50), television camera (subheading 8525 80) and television receiver (subheading 8528 72), gives the rear-view camera systems an essential character, they must be classified under heading 8528 72 40 as other multi-colour picture television with a liquid crystal display (LCD).

LED Floodlights: VO (EU) 337/2014

The following product is classified under CN code 9405 40 99 pursuant to this Regulation:

“Were: An electrical lighting article (so-called “LED floodlight”) in a rectangular aluminium housing with a glass cover and dimensions of about 23 × 19 × 13 cm.

The product comprises an aluminium reflector and has a retaining bracket on the back for adjusting the lighting angle.

It is equipped with a high-performance LED chip and a power supply unit with transformer.

The product has a power consumption of 95 W, a luminous efficacy of 100 lm/W and a beam angle of 120°.

The goods are used outdoors e.g. for lighting landscapes, buildings, construction sites, billboards, green spaces or gardens.”

Because of its wide beam angle, the product is used for illuminating large areas, it cannot be placed under position 9405 40 10 as a headlight.

It shall therefore be classified under CN code 9405 40 99 as other electrical lighting fittings.

Effects on a binding tariff information (vZTA)

If you have had a vZTA issued for these goods, this has become invalid due to the change in the legal provisions. However, the regulations stipulate that you may use the invalid vZTA for a further six months in certain cases (protection of confidence). This would require a so-called final contract of purchase or sale.

Our customs lawyers will be happy to assist you with your concerns.

 

Lawyer Dr. Tristan Wegner

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