Keys presented separately

Subheading 8301 70 of the Combined Nomenclature covers keys for locks, presented separately, made of base metals including steel, brass and aluminium. The subheading encompasses three principal categories: key blanks (uncut key profiles ready for milling to a specific lock profile), cut keys (finished keys cut to operate a specific lock) and patent keys (keys for high-security locks with patented profiles, frequently incorporating electronic elements such as transponders). Classification in subheading 8301 70 requires a clear distinction from complete lock-and-key sets, which are classified under the appropriate subheading of heading 8301 according to the type of lock. A key presented separately, regardless of its complexity, falls within 8301 70. Keys incorporating an RFID transponder or NFC chip remain in 8301 70 provided the essential character is that of a mechanical key blade. Notes to Chapter 83 CN clarify that articles of base metal serving a specific mechanical function are classified in this chapter on the basis of their primary function. Classification is carried out in accordance with the General Rules of Interpretation (GRI) of the Combined Nomenclature, in particular GRI 1 and 6. Where doubt exists, Binding Tariff Information (BTI) application is recommended.

Import of keys for locks covered by subheading 8301 70 into the European Union must comply with the Union Customs Code (Regulation (EU) No 952/2013). The importer must hold an EORI number and file a customs declaration electronically via the AIS/IMPORT system. Required documentation includes: a commercial invoice with a precise description of the goods (material, key type, weight), a transport document (CMR, B/L or AWB) and a goods specification. Patent keys and key blanks for high-security locks may be subject to restrictions arising from intellectual property rights protecting patented profiles. Importers should verify that the imported product does not infringe patents protected in the EU territory. Keys containing electronic components (transponder, NFC module) may additionally require conformity assessment under Directive 2014/53/EU (RED) if they incorporate a radio module. Preferential duty rates under free trade agreements are conditional on presenting a valid proof of origin (EUR.1, invoice declaration or REX statement). Current MFN duty rates must be verified in the TARIC database of the European Commission.

MFN (Most Favoured Nation) duty rates for keys for locks under subheading 8301 70 must be verified in the current TARIC database of the European Commission, as they may be subject to change by implementing acts. Preferential rates may be available under free trade agreements concluded by the EU, including with South Korea, Japan (EPA), Canada (CETA), the United Kingdom (TCA), and under the Generalised Scheme of Preferences (GSP) for developing countries. The use of a preferential rate is conditional on compliance with rules of origin and presentation of a valid proof of origin. Importers should check in TARIC whether any anti-dumping or countervailing measures apply to the relevant product and country of origin. The import of keys from China is an area closely monitored by EU customs authorities with regard to undervaluation of customs value. Imports from Russia and Belarus are subject to restrictions under EU sanctions packages. VAT is charged at the applicable national rate upon import. All duty rates and trade measures should be verified in the current TARIC database.

CN code 8301 70 covers keys for locks. 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.