85168000
ELECTRICAL MACHINERY AND EQUIPMENT AND PARTS THEREOF; SOUND RECORDERS AND REPRODUCERS, TELEVISION IMAGE AND SOUND RECORDERS AND REPRODUCERS, AND PARTS AND ACCESSORIES OF SUCH ARTICLES›Electric 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 heating resistors
Definition and scope of subheading 8516 80 - electric resistance heaters
Subheading 8516 80 of the Combined Nomenclature covers electric resistance heaters, i.e. appliances using electric current through a resistance element to generate heat for space heating, water heating or heating other media. The scope includes electric convector heaters, oil-filled radiators with immersed heating elements, immersion heaters for water tanks, tubular heating elements for industrial applications, electric infrared radiant heaters, underfloor heating mats and electric towel warmers. The essential classification criterion is the use of a resistance heating element as the primary heat source. Heat pumps and air conditioners with heating functions are classified under heading 8415. Electric central heating boilers may fall under heading 8402 or 8403. Fan heaters are included under subheading 8516 80. Instantaneous water heaters may be classified under 8516 10. Where classification is uncertain, Binding Tariff Information ruling is recommended.
Regulatory requirements for electric heaters imported into the EU
Electric resistance heaters under subheading 8516 80 placed on the EU market are subject to the Low Voltage Directive LVD (2014/35/EU) and the EMC Directive (2014/30/EU), requiring CE marking. Harmonised standards EN 60335-2-30 (room heaters), EN 60335-2-43 (clothes dryers and towel warmers) and EN 60335-2-73 (immersion heaters) specify particular safety requirements. The RoHS 2 Directive (2011/65/EU) restricts hazardous substances. The WEEE 2 Directive (2012/19/EU) imposes waste collection obligations. Electric space heaters are subject to Ecodesign regulations - Commission Regulation (EU) 2015/1188 establishes Ecodesign requirements for local space heaters, though EU energy labelling is not required for portable electric heaters. The GPSR Regulation (EU) 2023/988 requires designation of an EU representative. CBAM does not apply to heaters from Chapter 85.
Duty rates and import conditions for heaters under subheading 8516 80
Current MFN duty rates for electric heaters under subheading 8516 80 should be verified in the European Commission's TARIC database. Electric heaters are not IT products covered by the ITA. Preferential duty rates may be available under EU FTAs, subject to rules of origin compliance and valid proof of origin. China and Turkey are significant exporters of electric heaters - importers should check TARIC for current trade measures. Import documentation includes commercial invoice with technical specifications covering heater type, power rating, voltage and application, transport documents, EORI number, CE declaration of conformity, RoHS documentation and WEEE registration data. High-power industrial heaters may require additional application documentation. National VAT is levied on import.
Ecodesign and energy labelling for appliances 8516 80
Heating appliances under CN 8516 80 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
Do electric space heaters under subheading 8516 80 have Ecodesign requirements?
Yes, partially. Electric space heaters intended for room heating are subject to Ecodesign Regulation (EU) 2015/1188 on local space heaters. This regulation establishes minimum energy efficiency requirements and emission limits for heaters placed on the EU market. Portable electric heaters do not require an EU energy label. Immersion heaters and industrial heating elements intended for integration into industrial equipment are not subject to these Ecodesign requirements. Current requirements should be verified in the applicable delegated regulations.
How to classify an underfloor heating mat in the CN?
Electric underfloor heating mats with a resistance element are classified under subheading 8516 80 as electric resistance heaters. The classification criterion is the use of a resistance heating element for heat generation. Heating mats are standalone heating devices, even if they require installation in a floor structure. Heating mats should be distinguished from heating cables, which may be classified under heading 8544. Heating mats are subject to LVD and EMC directives and require CE marking.
Does CBAM apply to electric heaters?
No. CBAM (Regulation (EU) 2023/956) covers only a closed list of goods from emission-intensive sectors: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. Electric heaters under subheading 8516 80 belong to Chapter 85 of the CN and fall outside the scope of CBAM. Importing electric heaters into the EU does not require CBAM registration, purchase of CBAM certificates, or CBAM declarations, regardless of the country of production.
Do heating appliances under 8516 80 require energy labels?
Some appliances under 8516 80 require energy labels, e.g., water heaters (851610). Cookers, toasters and coffee makers require CE (LVD + EMC) and RoHS 2.
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