Playing cards

CN subheading 950440 covers playing cards of all kinds: standard 52-card poker decks, bridge decks, tarot decks, canasta sets, piquet decks, as well as collectible trading card game (TCG) cards such as Magic: The Gathering, Pokemon TCG, Yu-Gi-Oh! and Disney Lorcana. The decisive classification criterion is the gaming purpose: the article must take the form of cards (cardboard, plastic-coated or laminated) intended for use in a card game, whether competitive, social or collectible. Tarot cards used exclusively as a divination tool rather than for play may require a separate classification analysis. Cards with non-standard formats designed as educational aids or memory games for children may fall in subheading 950390 (toys and games). Classification follows GRI rules 1, 3a and 6. Subheading notes and HS Explanatory Notes for heading 9504 must be consulted. In cases of doubt, a BTI ruling is recommended.

Import of playing cards under subheading 950440 is subject to different regulatory requirements depending on the intended audience. Cards marketed as toys for children under 14 fall under the Toy Safety Directive 2009/48/EC and require CE marking, an EU Declaration of Conformity and technical documentation confirming compliance with the essential safety requirements, including EN 71-3 (migration of elements from printed materials accessible to children). For cards marketed exclusively to adults, toy directive requirements do not apply; however, the General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, applicable from 13 December 2024, requires general product safety, a risk assessment and a responsible economic operator in the EU for all consumer products. Printing inks and dyes used in card production are subject to chemical restrictions under REACH Regulation (EC) No 1907/2006: aromatic amines from azo dyes listed on the ECHA candidate list, formaldehyde in laminating adhesives, and SVHC substances must not exceed applicable thresholds. Plastic packaging materials are subject to the Packaging and Packaging Waste Regulation (EU) 2025/40 and the Single-Use Plastics Directive (EU) 2019/904 in terms of recycled content targets. The importer must file a correct customs declaration with the CN code, EORI number and required commercial documents.

MFN customs duty rates for subheading 950440 must be verified in the EU TARIC database before each import. Playing cards and TCG sets are produced across multiple countries - China, the United States, Japan, Belgium and others - so preferential duty rates under specific EU free trade agreements must be individually verified for each country of origin. Conditions for preferential rates include compliance with applicable rules of origin and presentation of valid proof: an REX declaration, EUR.1 certificate or invoice declaration. A key classification issue is the distinction between a deck of cards (subheading 950440) and a board or tabletop game containing cards as one component (subheading 950490 or 950300), where the cards form part of a larger set. Mixed sets are classified by the product giving the essential character under GRI 3b, or by the subheading last in numerical order under GRI 3c. Importers of collectible TCG cards should verify that the customs value correctly reflects any royalty payments or intellectual property fees that customs authorities may require to be included in the value. All applicable rates and trade measures must be verified in the EU TARIC database.

Subheading CN 9504 40 covers playing cards poker bridge TCG. When importing into the EU, verify applicable duty rates in TARIC, check CE marking requirements (if applicable), and prepare the required customs documentation. Tariff classification should be based on the General Rules of Interpretation (GIR) of the Combined Nomenclature. If classification is uncertain, applying for Binding Tariff Information (BTI) from the competent customs authority is recommended. Also verify whether the product is subject to import restrictions, sanctions, or licensing requirements.