84717000
NUCLEAR REACTORS, BOILERS, MACHINERY AND MECHANICAL APPLIANCES; PARTS THEREOF›Automatic data-processing machines and units thereof; magnetic or optical readers, machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included
Storage units
Subcodes (6)
What does CN code 8471 70 cover?
CN code 8471 70 of the Combined Nomenclature covers storage units for automatic data processing (ADP) machines. This subheading includes hard disk drives (HDDs), solid-state drives (SSDs), optical drives (CD, DVD, Blu-ray), tape drives, disk arrays (RAID), NAS (Network Attached Storage) servers, external USB drives and other devices for persistent storage of digital data. The essential classification criterion is the device's intended use for data storage in conjunction with an ADP machine. Storage devices must be capable of communicating with an ADP machine - via SATA, SAS, NVMe, USB, Thunderbolt or network interfaces. USB flash drives (pen drives) may be classified under heading 8523 as semiconductor storage media, depending on the specific classification. Classification is carried out in accordance with the GRI, Rule 1, taking into account the notes to Chapter 84. The HS Explanatory Notes specify the scope of storage units.
Import requirements for mass storage devices
Importing storage devices under CN code 8471 70 into the EU is subject to the Union Customs Code. Storage devices as electronic equipment are subject to the EMC Directive 2014/30/EU, LVD Directive 2014/35/EU and RoHS Directive 2011/65/EU. CE marking is required. The WEEE Directive 2012/19/EU imposes recycling obligations. Storage devices with advanced hardware encryption technologies may be subject to dual-use technology controls. Regulation (EU) 2023/988 requires product safety assurance. Customs documentation includes a commercial invoice with technical specification (capacity, interface, speed), transport document and CE declaration of conformity. Importing used hard drives containing personal data is subject to GDPR (Regulation (EU) 2016/679) - the importer should ensure secure data deletion. The importer must hold an EORI number and be registered in the national WEEE register.
Customs duties and ITA for mass storage devices
Storage devices under CN code 8471 70 are covered by the WTO ITA. The MFN rate is 0%, eliminating duties on ADP storage devices. The rate should be confirmed in the current TARIC database. Products under Chapter 84 are not subject to CBAM. VAT is charged at import at the national rate. Preferential FTA rates are irrelevant given the zero MFN rate. Imports from countries subject to EU sanctions require verification of restrictions. Current rates and trade measures should be checked in TARIC. Hard drives and SSDs are among the most commonly imported IT components into the EU, from major production markets in East and Southeast Asia. Autonomous duty suspensions may cover specialised storage media.
EU directives and ecodesign for IT products 8471 70
Importing IT products under CN 8471 70 requires compliance with multiple EU regulations. RoHS 2 Directive (2011/65/EU) restricts lead, mercury, cadmium and other hazardous substances. The WEEE Directive requires producer registration in the national registry. The Ecodesign Regulation (EU) 2024/1781 introduces durability and repairability requirements. IT products benefit from ITA 0% duty. A CE declaration of conformity covering LVD and EMC is required.
Frequently asked questions
Is an SSD classified under code 8471 70?
Yes. Solid-state drives (SSDs) designed for use with ADP machines are classified under subheading 8471 70 as storage units. This applies to both internal SSDs (SATA, NVMe/M.2) and external SSDs (USB, Thunderbolt). The MFN customs duty rate is 0% under the ITA. The decisive criterion is the intended use for data storage in conjunction with an ADP machine. Flash memory cards (SD, microSD) may be classified under heading 8523.
Is a NAS server classified under code 8471 70 or 8471 49?
NAS server classification depends on its functionality. If the NAS is primarily a networked storage device - without the ability to independently process data as an ADP machine - it is classified under subheading 8471 70. If the NAS has advanced server functions (virtualisation, application hosting), it may qualify as a server under subheading 8471 49. The decision depends on the device's essential character. A BTI ruling is recommended in case of doubt.
Is a USB flash drive classified under code 8471 70?
USB flash drive classification is subject to classification debate. A flash drive may be classified under subheading 8471 70 as an ADP storage device or under heading 8523 as a semiconductor storage medium. The decision depends on the interpretation applied by customs authorities - the EBTI database contains BTI decisions in both directions. The key question is whether the flash drive is treated as an ADP peripheral device (8471) or as a data carrier (8523). The MFN rate is 0% in both cases.
What ecodesign requirements apply to products under 8471 70?
Products under CN 8471 70 are subject to the Ecodesign Regulation (EU) 2024/1781, requiring spare parts availability, repairability information and durability standards. RoHS 2 and WEEE also apply.
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