Padlocks

Subheading 8301 10 of the Combined Nomenclature covers padlocks of base metal, including brass, steel and aluminium padlocks. Padlocks are portable locking devices opened by a key, combination dial or dual-mechanism, designed without permanent attachment to a structure. This category includes construction and industrial padlocks, bicycle locks with shackle mechanisms, luggage padlocks, high-security padlocks with hardened steel shackles, and disc or laminated padlocks. Classification under subheading 8301 10 requires clear distinction from locks for motor vehicles (8301 20), locks for furniture (8301 30) and locks for buildings (8301 40). The defining criterion is the portable nature of the locking mechanism and the absence of permanent installation. Classification follows the General Rules for Interpretation (GRI) of the Combined Nomenclature, particularly Rules 1 and 6. Notes to Section XV and Chapter 83 CN define the scope of base metal goods. In case of doubt, Binding Tariff Information (BTI) ruling from the competent customs authority is recommended.

Importing padlocks under subheading 8301 10 into the European Union requires compliance with the Union Customs Code (Regulation (EU) No 952/2013). The importer must hold an EORI number and submit an electronic customs declaration in the AIS/IMPORT system with the correct 8-digit CN code. Required documents include a commercial invoice with product description and value, transport document (CMR, B/L or AWB), goods specification and a certificate of origin for preferential tariff rates. Padlocks of base metal are subject to the General Product Safety Regulation (EU) 2023/988. Products intended for consumers must meet general safety requirements and be properly labelled. High-security padlocks certified to EN 12320 may require additional technical documentation. A declaration of conformity and instructions in an EU language are advisable for consumer-facing products. Imports from third countries are subject to standard customs controls and product safety checks. Current MFN rates should be verified in the European Commission's TARIC database.

MFN duty rates for padlocks of base metal under subheading 8301 10 should be verified in the current European Commission TARIC database, as they may be subject to change. Preferential duty rates may be available under EU free trade agreements, including CETA (Canada), the EU-Japan EPA, the EU-South Korea Agreement, and the EU-UK Trade and Cooperation Agreement (TCA), as well as under the Generalised Scheme of Preferences (GSP) for developing countries. The condition for applying a preferential rate is compliance with rules of origin and presentation of valid proof of origin, such as a EUR.1 certificate, invoice declaration or REX statement. Importers should check in TARIC whether anti-dumping or countervailing measures apply to padlocks from the specific country of origin. Imports of padlocks from China and other Asian manufacturing countries may be subject to trade defence measures. Imports from Russia and Belarus may be subject to EU sanctions restrictions. VAT at the national rate applies on import. All current duty rates and trade measures must be verified in TARIC.

CN code 8301 10 covers padlocks of base metal. Import into the EU is subject to TARIC duty rates. Products must comply with EN standards for security and durability, including EN 12209 for door locks and EN 12320 for padlocks. Correct TARIC classification is essential as lock parts and complete locks carry different duty rates.