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With the implementing regulation (EU) 2020/622 of 29 April 2020, the European Commission has regulated the tariff classification of the control unit of car radios.

The product concerned is the rectangular front panel of a car radio, the so-called control panel of the car radio, which is equipped with several buttons to activate various functions of the radio.

The panel is made of plastic and the keys and switches have inscriptions engraved by laser. The control panel is always sold without electrical or electronic components.

Correct customs tariff number for the control panel of car radios

The control panel is an essential part of the car radio and is therefore henceforth to be classified under customs tariff number 8529 90 92.

The product is thus classified as an “other part” for radio receivers within the meaning of customs tariff heading 8527.

The European Commission has justified this on the grounds that the control panel has a direct function in the use of the car radio. It is only by activating the buttons and keys on the control panel that the radio and its functions can be used – in this respect the control panel is an essential part of the operation of the radio.

Furthermore, the design and operation of the radio would preclude any other use. The unique function is thus directly linked to the car radio.

The Commission therefore also rejects classification under tariff heading 8529 90 49. The control panel is not “furniture or housing” within the meaning of tariff heading 8529, but only the front panel of a car radio.

This is also in line with the Tariff Explanatory Notes, which explicitly exclude parts of “furniture and cabinets” from tariff heading 8529 90 41 and 8529 90 49.

Invalidity of binding tariff information (BTI)

If you have been issued a Binding Tariff Information (BTI) for the control panel of car radios, it has become invalid due to changes in legislation. However, the Regulation stipulates that you can continue to use the BTI issued to you for three months after the entry into force of the Commission Regulation.

Our customs lawyers would be happy to advise you on how to find the correct customs tariff number and whether you wish to file an appeal against a customs decision.

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