Thermometers and pyrometers, not combined with other instruments - Liquid-filled, for direct reading

Subheading 9025 11 of the Combined Nomenclature covers thermometers filled with a liquid and designed for direct reading by the user. The term direct reading means that the temperature measurement result is visible on a graduated glass scale or another scale integrated into the instrument - without the intermediary of an electrical or electronic transducer. Products classified here include: laboratory glass thermometers filled with coloured ethyl or isopropyl alcohol (red or blue), used in laboratories, pharmacies and educational institutions; aquarium, pool and drinking water thermometers filled with safe organic liquid; oven and confectionery thermometers filled with silicone oil or glycol; industrial thermometers for measuring temperatures of liquids and gases filled with kerosene or pentane (for cryogenic ranges); and meteorological maximum-minimum thermometers for weather stations. Mercury-filled direct-reading thermometers formally fall within this subheading but their import, manufacture and placing on the EU market are prohibited since 3 April 2009 under Regulation (EC) No 1102/2008, and the prohibition has been confirmed and extended by Regulation (EU) 2017/852 (Minamata Convention on Mercury) since 1 January 2021. Electronic digital thermometers with thermistor or thermocouple sensors are classified under subheading 9025 19. Classification follows GRI 1 and 6 of the Combined Nomenclature and notes to Chapter 90.

The import of mercury-containing direct-reading thermometers into the EU territory is absolutely prohibited. The prohibition derives from Regulation (EU) 2017/852 of the European Parliament and of the Council of 17 May 2017 on mercury, which implements the obligations of the Minamata Convention on Mercury (2013). Regulation (EU) 2017/852 prohibits the manufacture, import and export of direct-reading mercury thermometers except for limited applications in high-precision reference instruments (derogations require a Commission decision). The earlier Regulation (EC) No 1102/2008 applied from 3 April 2009 and covered medical and household mercury thermometers. Mercury is also listed as a Substance of Very High Concern (SVHC) on the REACH candidate list - products containing mercury above 0.1% by weight are subject to mandatory information obligations under Article 33 of REACH Regulation (EC) No 1907/2006. Mercury-free liquid thermometers (alcohol, glycol, kerosene) may be freely imported subject to compliance with general product safety requirements: Regulation (EU) 2023/988 on general product safety and, where electronic components are included, the RoHS Directive 2011/65/EU. For the import of laboratory glass thermometers, the following documents are required: commercial invoice with technical description and customs value, transport document, mercury-free declaration and REACH compliance statement, and - for preferential duty rates - a valid proof of origin. The importer must hold a valid EORI number. Current import requirements should be verified in the EU TARIC database.

Liquid-filled direct-reading thermometers under subheading 9025 11 are measuring instruments with a relatively low unit value. Applicable MFN duty rates for specific 8-digit CN codes within this subheading must be verified in the current EU TARIC database of the European Commission, as the Combined Nomenclature is revised annually and rates may change. The EU may apply autonomous tariff suspensions for specialised laboratory thermometers not manufactured in sufficient quantities within the Union - these suspensions are updated annually by the Council of the EU and published in the Official Journal of the EU. Leading manufacturers of liquid-filled laboratory thermometers are based in Germany, the United Kingdom, the Czech Republic and China. Preferential duty rates may be available under EU free trade agreements: the EU-UK TCA, CETA with Canada, the EU-Switzerland agreement, the EU-Japan EPA and the EU-Korea FTA. GSP and GSP+ preferences are available for imports from developing countries. To benefit from a preferential rate, a valid proof of origin must be presented: EUR.1 movement certificate, invoice declaration or REX statement. Importers should verify in TARIC that no anti-dumping measures apply for the specific country. Products in Chapter 90 are not subject to CBAM. VAT is applied on top of the customs value at the domestic rate applicable to measuring instruments.

Subheading CN 9025 11 covers liquid-filled thermometers for direct reading: alcohol, glycol, and other types. Mercury thermometers are subject to a market ban in the EU (REACH Regulation, Annex XVII entry 18a) except for special applications (calibration, reference standards). Import of mercury thermometers requires demonstrating a permitted use. Electronic thermometers are classified under 9025 19.