85169000
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
Parts
Definition and scope of subheading 8516 90 - parts for electro-thermic appliances
Subheading 8516 90 of the Combined Nomenclature covers parts for electro-thermic appliances classified under heading 8516, including electric irons, microwave ovens, electric cookers, coffee makers, toasters, heaters and other heating devices. The main commercially relevant parts categories are resistance heating elements (coils, tubular heaters, ceramic heaters), thermostats and temperature regulators, iron soleplates, magnetrons for microwave ovens, water tanks for coffee machines, housings and covers, control panels and electronic programmers. The essential classification criterion is the part being solely or principally intended for appliances under heading 8516. General-purpose parts used across multiple appliance types (e.g. power cords, plugs) are classified under their proper tariff headings. Magnetrons as electronic components may fall under heading 8540 - however, a magnetron clearly intended for a microwave oven typically remains under 8516 90. Classification is based on Section XVI and Chapter 85 Notes.
Regulatory requirements for electro-thermic appliance parts
Parts for electro-thermic appliances under subheading 8516 90 may be subject to various EU directives depending on their specific application. The RoHS 2 Directive (2011/65/EU) restricts hazardous substances in components intended for appliances within its scope. Individual parts may be subject to the LVD Directive (2014/35/EU) if they constitute safety-critical elements of the end appliance. Parts in contact with food (cooking appliance soleplates, coffee machine tanks) must comply with Regulation (EU) No 1935/2004 on food contact materials. CE marking is not required for spare parts sold separately as components, provided they do not constitute standalone products covered by a New Approach directive. CBAM does not apply to electro-thermic appliance parts from Chapter 85. Import is subject to the Union Customs Code (Regulation (EU) No 952/2013). EORI number and correct CN code declaration are required.
Duty rates and import conditions for parts under subheading 8516 90
Current MFN duty rates for electro-thermic appliance parts under subheading 8516 90 should be verified in the European Commission's TARIC database. These parts 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 is the primary supplier of replacement parts for household appliances - importers should check TARIC for current trade measures. Import documentation includes commercial invoice with precise technical description of the part (type, intended use, appliance compatibility), transport documents, EORI number, and where applicable, RoHS documentation and food contact material certificates. Correct CN classification is critical - parts must be clearly identified as intended for heading 8516 appliances. National VAT is levied on import.
Ecodesign and energy labelling for appliances 8516 90
Heating appliances under CN 8516 90 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
How to classify a replacement magnetron for a microwave oven?
A magnetron intended as a replacement part for a microwave oven is classified under subheading 8516 90 as a part of an electro-thermic appliance under heading 8516, provided it is clearly identifiable as intended for a microwave oven. Alternatively, a magnetron as a vacuum electronic tube may be classified under heading 8540. The deciding criterion is Section XVI Note 2(b), which states that parts suitable for use solely or principally with a particular machine are classified with that machine. A BTI ruling is recommended in doubtful cases.
Do parts under subheading 8516 90 require CE marking?
CE marking is not required for spare parts sold separately as components, provided they do not constitute standalone products covered by a New Approach directive. However, the manufacturer or importer of the finished appliance is responsible for ensuring that after the part is installed, the appliance continues to comply with LVD, EMC and other applicable directives. Parts in contact with food must comply with Regulation (EU) No 1935/2004 regardless of CE marking.
Does CBAM apply to parts under subheading 8516 90?
No. CBAM (Regulation (EU) 2023/956) covers only goods from emission-intensive sectors: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. Parts for electro-thermic appliances under subheading 8516 90 belong to Chapter 85 of the CN and fall outside the scope of CBAM. Importing these parts into the EU does not require CBAM registration, purchase of CBAM certificates, or CBAM declarations.
Do heating appliances under 8516 90 require energy labels?
Some appliances under 8516 90 require energy labels, e.g., water heaters (851610). Cookers, toasters and coffee makers require CE (LVD + EMC) and RoHS 2.
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