40082100
4›Plates, sheets, strip, rods and profile shapes, of vulcanised rubber other than hard rubber
Of non-cellular rubber - Plates, sheets and strip
Definition and scope of subheading 400821
Subheading 400821 of the Combined Nomenclature covers plates, sheets and strip of non-cellular vulcanised soft rubber used as floor coverings and mats. Non-cellular rubber is vulcanised rubber without a porous structure – it has a uniform, compact mass with a density typically in the range of 1.1 to 1.5 g/cm3. Products covered by this subheading include anti-slip rubber mats for industrial halls, workshops and commercial kitchens, electrostatic dissipative (ESD) mats for electronics manufacturing areas, gymnastics and martial arts mats, rubber floor coverings for warehouse platforms and railway station concourses, and animal stall mats for livestock farming. Articles classified under 400821 are finished products intended for use as flooring or a mat – not semi-finished intermediates for further conversion. The base rubber may be natural rubber, SBR, NBR, EPDM, neoprene (CR) or rubber compounds. Recycled rubber products (bonded rubber crumb mats) may be classified under 400821 if they consist of non-cellular vulcanised rubber and have the physical form of a floor covering or mat. The subheading covers both profiled mats (with anti-slip studs, ribs or diamond pattern) and smooth mats, regardless of thickness.
Import procedures, applicable standards and market requirements
The import of rubber floor coverings and mats (CN 400821) into the EU requires a customs declaration with the appropriate TARIC code and country of origin. The commercial invoice should specify the rubber type, dimensions, thickness, Shore A hardness and any surface treatment or printing. Preferential tariff rates may be available under EU free trade agreements or GSP and require a valid proof of origin. Rubber mats for workplace use are subject to health and safety requirements in EU Member States, including ergonomic assessment under Directive 89/654/EEC (workplace requirements) in some applications. The harmonised standard EN 14041 applies to resilient floor coverings in buildings and may require a Declaration of Performance (DoP) and CE marking where the product is placed on the market as a construction product covered by this standard. Anti-static and ESD mats for electronics manufacturing must comply with EN 61340-5-1. Rubber mats in contact with foodstuffs must comply with Regulation (EC) No 1935/2004 on food contact materials. All rubber articles are subject to REACH (Regulation (EC) No 1907/2006), particularly PAH restrictions under Annex XVII, Entry 50, applicable to articles in contact with skin. The importer should obtain a current REACH compliance declaration and relevant test reports from the supplier prior to the first shipment.
Classification boundaries – avoiding tariff errors
Correct classification under 400821 requires careful distinction from adjacent subheadings. Mats and floor coverings of cellular (foam) rubber fall under subheading 400811 (plates and sheets of cellular rubber) – the absence of a porous structure is the decisive criterion for 400821. Rods, tubes and profiles of non-cellular rubber are classified under subheading 400829, not 400821. Floor coverings and mats made of plastics – PVC, polyethylene, polypropylene or polyurethane – are classified in Chapter 39, not Chapter 40 – the distinction turns on the chemical composition of the base polymer. Rubber floor mats bonded to a jute or other textile backing require analysis of the essential character: if the rubber layer determines the essential character of the product, classification under heading 4008 is appropriate; if the textile backing dominates, classification may fall under Chapter 57 (floor coverings) or Chapter 59 (technical textiles). Articles of hard rubber (ebonite) are classified under heading 4017. Recycled rubber crumb mats must be distinguished from loose rubber crumb (heading 4004) – only bonded, finished mats intended for use as floor coverings are classified under 400821. In doubtful cases, a binding tariff information (BTI) ruling should be obtained from the competent customs authority.
Frequently asked questions
How is a rubber mat (400821) distinguished from a plastic mat (Chapter 39)?
The key criterion is the chemical composition of the base polymer. Mats of vulcanised rubber – natural rubber, SBR, NBR, EPDM or neoprene – are classified under heading 4008, subheading 400821. Mats of plastics – PVC, polyethylene, polypropylene or polyurethane – are classified in Chapter 39. A technical data sheet from the manufacturer identifying the polymer type, or an FTIR analysis report, is the primary classification document. Vulcanised rubber exhibits high elastic recovery, tensile strength and characteristic thermoset behaviour, while thermoplastic PVC or polyurethane can be softened by heat and re-formed. The commercial invoice should clearly state the rubber type and confirm vulcanisation to support correct tariff classification.
Are recycled rubber crumb mats classified under subheading 400821?
Yes, provided they satisfy the conditions of the subheading. Mats produced from recycled rubber crumb – typically from shredded vehicle tyres – that have been bonded or compressed into a finished mat for use as floor covering can be classified under 400821, provided the base material is non-cellular vulcanised rubber and the article has the form of a floor covering or mat. Loose rubber crumb not bonded into a finished article is classified under heading 4004. The importer should describe the article clearly on the commercial invoice as a finished rubber mat (not granulate) and identify the base material to assist customs verification.
What are the key REACH requirements for rubber floor mats imported into the EU?
The most significant REACH requirement for rubber mats (400821) is the restriction on polycyclic aromatic hydrocarbons (PAHs) under Annex XVII, Entry 50, of Regulation (EC) No 1907/2006: the concentration of individual PAHs must not exceed 1 mg/kg in rubber articles intended to come into contact with the skin or oral cavity. For mats in contact with foodstuffs, compliance with Regulation (EC) No 1935/2004 is required. The presence of SVHC substances on the REACH Candidate List at concentrations above 0.1% by weight triggers notification and communication obligations. The importer should obtain a REACH compliance declaration or a laboratory PAH test report from an accredited testing body before placing the goods on the EU market.
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