Winding wire - Of copper

Subheading 854411 of the Combined Nomenclature covers copper winding wire - insulated copper wire with round or rectangular cross-section, coated with insulating enamel, intended for winding coils of electric motors, transformers, electromagnets and other electromagnetic devices. The insulation consists of a thin layer of polyurethane, polyester, polyamide-imide or polyimide varnish, resistant to temperatures from class 120 to class 240 degrees Celsius. Copper winding wire under 854411 must be distinguished from uninsulated copper wire (Chapter 74, heading 7408) and from other winding wire (854419), which covers winding wire made of other metals such as aluminium. The key classification criterion is that the wire must be copper and insulated, and its intended use is coil winding. Winding wires with a copper core and aluminium cladding (CCA) are classified based on the predominant material. Classification follows the GIR, rules 1 and 6, taking into account the notes to Chapter 85.

Copper winding wire under subheading 854411, as an industrial component, is not directly subject to the RoHS 2 Directive (2011/65/EU), but the importer should be aware that finished equipment containing windings from this wire must comply with RoHS 2, which in practice requires winding wire suppliers to provide documentation on restricted substance content. Winding wire is not subject to the WEEE 2 Directive, as it is an industrial component rather than finished equipment. CBAM does not apply to insulated wire under Chapter 85. However, it should be noted that bare copper wire under Chapter 74 may be subject to anti-dumping measures on copper products from certain countries. Import requires an EORI number, a customs declaration filed in the AIS/IMPORT system, and a commercial invoice containing technical specifications (diameter, insulation class, copper grade). Proof of origin is required for preferential duty rates.

Current MFN customs duty rates for subheading 854411 should be verified in the European Commission's TARIC database. Copper winding wire is an important trade commodity, with China, Japan and India being key exporters. Preferential duty rates may be available under EU FTAs, subject to rules of origin being met and valid proof of origin being presented. The importer should check in TARIC whether any anti-dumping or countervailing duties apply to copper winding wire from a specific country of origin. The EU has historically applied anti-dumping measures on certain copper products from China. Imports from Russia and Belarus may be subject to sanctions restrictions. Current 10-digit TARIC codes should be verified before customs clearance. National VAT is charged on every import. Rules of origin for winding wire typically require sufficient processing in the exporting country, which includes the enamelling process.

Importing copper winding wire (CN 8544 11) into the European Union requires compliance with RoHS 2 (2011/65/EU), WEEE 2 (2012/19/EU) and CE marking. An EORI number and correct customs declaration are mandatory. MFN duty rates should be verified in TARIC, as ITA preferences or EU FTA rates (e.g. CETA, EPA, EU-Korea) may apply. Import from Russia and Belarus is subject to EU sanctions. National import VAT applies at the destination Member State rate.