85016100
ELECTRICAL MACHINERY AND EQUIPMENT AND PARTS THEREOF; SOUND RECORDERS AND REPRODUCERS, TELEVISION IMAGE AND SOUND RECORDERS AND REPRODUCERS, AND PARTS AND ACCESSORIES OF SUCH ARTICLES›Electric motors and generators (excluding generating sets)
AC generators (alternators), other than photovoltaic generators - Of an output not exceeding 75 kVA
Subcodes (2)
Scope of subheading 850161 - AC generators up to 75 kVA
Subheading 850161 of the Combined Nomenclature covers alternating current generators with an output not exceeding 75 kVA. These generators convert mechanical energy (from an internal combustion engine, water turbine, wind turbine or other prime mover) into AC electrical energy. In the range up to 75 kVA, they serve as emergency generators, generators for small generating sets, generators for small hydro and wind power plants, and welding generators. Typical designs are synchronous generators with electromagnetic excitation or permanent magnets. Classification requires confirmation that the device is an AC generator (not a motor) with apparent power up to 75 kVA. Apparent power is expressed in kVA (kilovolt-amperes), not in kW - it includes both active and reactive power. Generators above 75 kVA are classified under subheadings 850162–850164. Classification follows GRI rules 1 and 6 and the notes to Chapter 85.
Regulatory requirements for AC generators up to 75 kVA
Importing AC generators under subheading 850161 into the EU requires a customs declaration with the correct CN code and EORI number. Synchronous generators are subject to the LVD Directive (2014/35/EU) for voltages 50–1000 V AC. The EMC Directive (2014/30/EU) covers electromagnetic emission and immunity. Generators forming part of a generating set are subject to the Machinery Regulation (EU) 2023/1230 as a whole with the prime mover. Harmonised standards IEC 60034 (rotating machinery) and ISO 8528 (generating sets) define technical requirements. Generators for marine applications may require classification society certification (Lloyd's, DNV, Bureau Veritas). CBAM does not apply. RoHS 2 and WEEE have limited application to industrial generators. Documentation: commercial invoice, technical specification, transport document.
Customs duties and trade preferences for AC generators up to 75 kVA
MFN duty rates for AC generators under subheading 850161 should be verified in TARIC. Preferential rates available under FTAs (CETA, EPA, EVFTA, TCA) require compliance with rules of origin. Small generators are imported mainly from China, India, Japan and European countries. Demand for emergency and standby generators is increasing due to growing awareness of the need to secure power supply for critical infrastructure. Generators for small renewable energy plants (micro-hydro, small wind turbines) represent a growing market segment. Importers should check TARIC for current trade measures. Imports from sanctioned countries are subject to restrictions. VAT is charged on import. TARIC codes should be verified before customs clearance.
Import requirements for generators 8501 61
Electric generators under CN 8501 61 are used in conventional and renewable energy. MFN duty: 2.7%. Import requires a CE declaration (LVD + EMC). Wind turbine generators face additional requirements under Machinery Regulation (EU) 2023/1230. Customs value includes transport costs to the EU border.
Frequently asked questions
What is the difference between kVA and kW in generator classification under 850161?
AC generator output is expressed in kVA (kilovolt-amperes), which represents apparent power including both active power (kW) and reactive power (kvar). Active power in kW is lower than apparent power in kVA and depends on the power factor (cos φ) of the load: kW = kVA × cos φ. In customs classification of AC generators, kVA is used as the power measure, while for motors, shaft output in kW is used. Correct determination of power in kVA is critical for classification: up to 75 kVA falls under 850161, above 75 kVA to 375 kVA under 850162.
Is an AC generator imported separately from the engine subject to separate duty?
Yes, an AC generator imported as a standalone component is classified under subheading 850161 (up to 75 kVA) and subject to the duty rate applicable to generators. A complete generating set (engine + generator + frame) is classified under heading 8502 as a unit. If the generator and engine are imported together as elements of the same set but in parts, classification may require application of GRI rule 2a (incomplete goods). Duty rates should be verified in TARIC.
What technical standards apply to AC generators under subheading 850161?
AC generators are subject to IEC 60034 standards (rotating electrical machines) covering rated parameters, insulation classes (B, F, H), protection ratings (IP), cooling methods (IC) and duty cycles (S1-S10). Generating sets are subject to ISO 8528, defining operating classes, voltage and frequency tolerances. Marine generators require classification society certification. EN/IEC standards form the basis for CE declarations of conformity. Duty rates should be verified in TARIC.
What ecodesign requirements apply to motors under 8501 61?
Motors under CN 8501 61 are subject to Regulation (EU) 2019/1781. Three-phase motors must meet IE3 or IE4 efficiency class depending on power and market placement date.
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