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Classification of disposable insoles

The Commission’s Implementing Regulation (EU) No 2018/838 establishes the classification of disposable deposits for children’s pots in the Combined Nomenclature (CN). These disposable inserts are to be classified under heading No 3924 90 00 as’other household or household articles, sanitary or toilet articles of plastics’. Businesses should check whether they are affected by this Classification Regulation and to what extent it affects the validity of Binding Tariff Information (BTI).

Disposable inserts made of plastic, paper and polyacrylate granules

Affected are disposable inserts for children’s pots, consisting of a plastic bag.

At the bottom of this plastic bag is an insert of multi-layer absorbent paper and a superabsorbent polymer of polyacrylate granulate. This super-absorbent polymer turns into a gel on contact with urine.

Classification of disposable insoles as plastic goods

The Commission considers that disposable deposits are to be classified under CN subheading 3924 90 00 as plastic goods.

A classification of disposable inserts in heading No 4818 as’toilet paper or similar paper’ is excluded, since it is not the paper which would constitute the essential component of the goods, but the superabsorbent polymer.

Classification in heading No 9619 as”hygienic sanitary towels and tampons, diapers and diaper inserts […]” is excluded, since the goods are not designed to adapt to the human body.

Consequently, the product should be classified under subheading 3924 90 00. One reason for this is the combination of the composition of the goods made of plastics and other materials. Where a product retains the essential character of a plastic product, a product shall be classified in Chapter 39. Since the essential component of the fabric is the superabsorbent polymer made of a polyacrylate granulate, the paper content of the fabric would only serve the carrying and packaging function. Those explanations give rise to a classification as’other household or household articles, sanitary or toilet articles of plastics’ under CN code 3924 90 00.

Validity for similar goods

The Classification Regulations only apply to goods which correspond to the above-mentioned goods, but they can be used as an aid to classify similar goods.

Therefore, companies should now check whether their imports are affected by these regulations. For example, binding tariff information (BTIs) issued to them could have become invalid due to new classification regulations. Incorrect classification always carries the risk of criminal or fine-law consequences.

Have your listing checked now.

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Attorney Dr. Tristan Wegner

Ihr Ansprechpartner

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