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85161000
ELECTRICAL MACHINERY AND EQUIPMENT AND PARTS THEREOF; SOUND RECORDERS AND REPRODUCERS, TELEVISION IMAGE AND SOUND RECORDERS AND REPRODUCERS, AND PARTS AND ACCESSORIES OF SUCH ARTICLESElectric instantaneous or storage water heaters and immersion heaters; electric space-heating apparatus and soil-heating apparatus; electrothermic hairdressing apparatus (for example, hairdryers, hair curlers, curling tong heaters) and hand dryers; electric smoothing irons; other electrothermic appliances of a kind used for domestic purposes; electric heating resistors, other than those of heading 8545

Electric instantaneous or storage water heaters and immersion heaters

Scope

CN 851610 covers electric instantaneous (tankless) and storage water heaters. Instantaneous heaters heat water as it flows through without storage. Storage heaters (boilers) heat and store water in an insulated tank (5-500 litres). The heading also covers immersion heaters - resistive heating elements for submerging directly in water.

Regulatory requirements

LVD, EMC, RoHS 2, WEEE 2, and GPSR apply. Ecodesign Regulation (EU) No 814/2013 sets minimum energy efficiency requirements. Energy labelling is required (Delegated Regulation (EU) No 812/2013). Standard EN 60335-2-21 applies. CE marking mandatory. Drinking water contact materials must meet safety requirements.

Customs duties

MFN rates in TARIC. Not subject to CBAM. Classification requires electric water heating. National VAT applies.

Ecodesign and energy labelling for appliances 8516 10

Heating appliances under CN 8516 10 are subject to EU ecodesign and energy labelling regulations. Water heaters (851610) require energy labels A+ to F. Microwave ovens and cooking plates must comply with LVD and EMC. MFN duty: 2.7%. Since 2024, USB-C requirements apply to devices with cable power under 100 W. WEEE registration and RoHS 2 are required.

Frequently asked questions

Are electric storage water heaters classified under 851610?
Yes. Electric storage water heaters (boilers) with resistive heating elements and insulated tanks are classified under CN 851610. This covers tanks from 5 to 500 litres, wall-mounted and freestanding.
Do instantaneous water heaters require energy labels?
Yes. Electric water heaters (both instantaneous and storage) are subject to EU ecodesign and energy labelling regulations. An A-G energy label must appear on the device and in advertising materials.
Are immersion heaters classified under 851610?
Yes. Immersion heaters - resistive heating elements for direct submersion in water - are classified under CN 851610.
Do heating appliances under 8516 10 require energy labels?
Some appliances under 8516 10 require energy labels, e.g., water heaters (851610). Cookers, toasters and coffee makers require CE (LVD + EMC) and RoHS 2.