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Classification of bathing boards and heating mats

With the Implementing Regulations (EU) 2017/2245 and (EU) 2017/2247, the Commission defines the classification of bathing boards and heating mats in the Combined Nomenclature (CN). Accordingly, a bathing board is to be classified under subheading 3924 90 00 as”other household or household articles, sanitary or toilet articles made of plastics” with a third country duty rate of currently 6,5 % and a heating mat as”other electric heating appliances” with a third country duty rate of currently 2,7 %.

1. Classification of the bath boards

Regulation (EU) 2017/2245 applies to goods made of plastic with a non-slip surface and a dimension of approx. 35 x 69 cm. The so-called bath boards have water drainage holes, a handle and an integrated soap holder. The underside has four feet, which can be adjusted according to the width of the bathtub. It can be an entry and exit aid for the user, be used as a seat or as a shelf for bathing products.

The classification in subheading 3924 90 00 should be made because the product does not constitute furniture because it is not intended to be placed on the floor, hung up, fixed to the wall or stacked on top of each other. Therefore, according to note 2 to Chapter 94, classification as furniture is excluded. It should therefore be classified under CN code 3924 90 00 as’other household or household articles, sanitary or toilet articles of plastic’.

2. Classification of heating mats

Regulation (EU) 2017/2247 covers so-called heating mats measuring approximately 190 x 80 x 4 cm and weighing approximately 11.5 kg. The fabric is padded and has a heating element. The lower part of the mat consists of a 1 cm thick layer of foam. The upper side is covered on the outside with flat and smooth artificial stones containing tourmaline. The product has a control device connected by a cable and a power connection, a display for temperature indication, a button for setting the desired temperature and an on/off switch. It is used to treat various parts of the human body with heat. It can be used while lying or sitting and the temperature can be set to 30 to 70 °C. The stones emit far infrared rays after heating.

It should be classified under subheading 8516 79 90, since it cannot be classified under heading 9019 as a massager because the product does not work with friction, vibration or other mechanical movements and is not intended to massage the body. The product has the special property of storing and releasing heat without any friction. A classification as bed equipment (heading 9404) is also excluded, since the goods are not intended to equip beds. The product serves as a heat therapy device for domestic use. It should therefore be classified as’other electric heating appliances’ under CN code 8516 79 70.

3. Significance for similar goods

Classification regulations basically concern only goods which are identical to those mentioned in them, but could be used as a means of classifying similar goods. Companies should now check whether their imports are affected by these regulations. For example, binding tariff information (vZTA) issued to them could have become invalid. Incorrect classification always carries the risk of criminal or fine-law consequences.

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Attorney Dr. Tristan Wegner

Ihr Ansprechpartner

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