Subheading 960622 of the Combined Nomenclature covers buttons made of base metals, not covered with textile material. This category includes garment and decorative buttons manufactured from steel, copper and its alloys (brass, bronze), zinc, aluminium, tin, nickel and their alloys, used in clothing, leather goods, military and uniform articles, and as decorative elements. It covers sew-through buttons (with two or four holes), shank buttons and decorative metal buttons, including military, uniform and naval buttons with engraved or relief designs. The essential condition for classification under this subheading is that the button is not covered with textile material. Buttons plaited or covered with fabric are classified under subheading 960629. Classification is based on the Notes to Chapter 96 of the Combined Nomenclature. The term base metals is defined in the Notes to Section XV of the CN and includes iron, steel, copper, nickel, aluminium, lead, zinc, tin and other metals. Importers must distinguish buttons of base metal (960622) from buttons of plastics (960621), buttons of precious metal classified under Chapter 71 of the CN, and from snap-fasteners, buckles and clasps classified under heading 9607 or 8308. In cases of doubt, applying for Binding Tariff Information (BTI) ruling is strongly recommended.

Importing base metal buttons under subheading 960622 into the European Union requires compliance with the Union Customs Code (Regulation (EU) No 952/2013). The importer must hold an EORI number and submit a customs declaration with the correct CN code. Standard required documents include: a commercial invoice with a description of the goods stating the type of metal and button type, transport document (CMR, B/L or AWB) and product specification. Metal buttons intended for prolonged contact with skin must comply with the EU nickel restriction incorporated into REACH Regulation Annex XVII (entry 27), limiting nickel release to a maximum of 0.5 μg/cm²/week for articles intended for direct and prolonged skin contact. Products made of stainless steel or copper alloys intended for body contact must comply with REACH requirements regarding substances of very high concern (SVHC). Articles containing lead or lead compounds are subject to the RoHS Directive (2011/65/EU) and REACH restrictions on lead. Products containing asbestos or hexavalent chromium are subject to absolute prohibitions. A proof of origin (EUR.1 certificate, invoice declaration or REX statement) is required for preferential duty rates. Current MFN duty rates should be verified in the TARIC database.

MFN duty rates for base metal buttons under subheading 960622 should be verified in the current TARIC database of the European Commission. Metal buttons are manufactured and imported from a wide range of countries, notably China, Taiwan, South Korea, India, Japan and Turkey. Importers should consult TARIC to check whether any anti-dumping, countervailing or other trade restriction measures apply — for metal goods from China, anti-dumping measures may be particularly relevant. Imports from countries covered by EU Free Trade Agreements, including South Korea, Japan, Vietnam, Singapore and the United Kingdom, may qualify for preferential duty rates below the MFN level. Turkey benefits from a customs union with the EU for industrial goods, which may affect import conditions. Claiming preferences requires compliance with the applicable rules of origin and presentation of a valid proof of origin. The Generalised Scheme of Preferences (GSP) may be available for imports from eligible developing countries. Imports from Russia and Belarus may be subject to restrictions arising from EU sanctions packages. VAT at the applicable national rate is charged in addition to customs duties. All current duty rates and trade measures should be verified in TARIC prior to importing.

Subheading CN 9606 22 covers base metal buttons. 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.