Other locks

Subheading 8301 40 of the Combined Nomenclature covers locks of base metal not falling within subheadings 8301 10 to 8301 30. This subheading primarily covers locks used in residential and commercial construction: mortise locks (deadbolts), multipoint locking systems, cylinder locks, and sash locks for interior and exterior doors. Locks classified here are mechanical or electromechanical devices operated by a key, PIN code, access card, or electronic signal. Classification is carried out in accordance with the General Rules for the Interpretation of the CN (GRI). Note 1 to Chapter 83 excludes from this chapter goods classified in Section XV (base metals), so the function and completeness of the article is the decisive criterion. Multipoint locks, increasingly used in burglar-resistant doors of resistance classes RC2 to RC6, represent a growing product category within 8301 40. Importers should pay close attention to the distinction from heading 8302 (builders hardware) and subheading 8301 20 (vehicle locks). Electronic or smart locking systems are classified in 8301 40 provided their primary function remains the mechanical bolting of doors.

Importing construction locks classified under subheading 8301 40 into the European Union is subject to the Union Customs Code (Regulation (EU) No 952/2013). The importer must hold an EORI number and submit a customs declaration in the AIS/IMPORT system. Required documents include: a commercial invoice, transport document (CMR, B/L or AWB), product technical specification and a certificate of origin for preferential duty rates. Locks intended for burglar-resistant doors are subject to EN 12209 (mechanical locks for buildings) and EN 1303 (cylinders for locks) and may require certificates from notified bodies. Electromechanical and electronic locks may be subject to the Low Voltage Directive (LVD) 2014/35/EU and the Electromagnetic Compatibility Directive (EMC) 2014/30/EU. Locks with wireless modules (Bluetooth, Zigbee, Z-Wave) fall within the scope of the Radio Equipment Directive (RED) 2014/53/EU. Products must comply with the RoHS Directive 2011/65/EU on the restriction of hazardous substances. The CE marking is required when the lock falls within the scope of a harmonised product standard. Importers should check anti-dumping measures in the TARIC system for steel and cast iron goods from specific third countries.

Correct classification of locks under subheading 8301 40 requires analysis of several criteria. First, the lock must be a self-contained bolting device operated by a key or electronic device - it is distinguished from bolts, latches and catches by the presence of a secret mechanism (key profile, PIN code, card). Second, the criterion of application: furniture locks are classified in 8301 30, vehicle locks in 8301 20, luggage locks in 8301 10. Remaining locks, including builders and industrial locks, fall into 8301 40. Cylinder cores (barrels) supplied loose as complete devices are classified in 8301 40 rather than as parts in 8301 60. Motor locks and power-assisted multipoint locks are classified in 8301 40 provided they fulfil the primary function of bolting. Where doubt arises, it is recommended to apply for Binding Tariff Information (BTI) ruling from the competent customs authority. BTI decisions are binding for 3 years throughout the EU. The EBTI database maintained by the European Commission contains previous classification rulings that may assist in classifying similar goods.

CN code 8301 40 covers other door locks. Import into the EU is subject to TARIC duty rates. Products must comply with EN standards for security and durability, including EN 12209 for door locks and EN 12320 for padlocks. Correct TARIC classification is essential as lock parts and complete locks carry different duty rates.