85391000
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 filament or discharge lamps, including sealed beam lamp units and ultraviolet or infra-red lamps; arc-lamps; light-emitting diode (LED) light sources
Sealed beam lamp units
Definition and scope of subheading 8539 10 - sealed beam lamps
Subheading 8539 10 covers sealed beam lamp units - light sources in which the filament, reflector and lens form a single sealed unit. They are used mainly in older automotive headlamps, aviation lighting and industrial applications. The key criterion is sealed beam construction - a complete optical unit with a built-in filament lamp. Ordinary halogen lamps without integrated reflectors are classified under 8539 21 or 8539 29. LED lamps and fluorescent lamps are classified under separate subheadings.
Regulatory requirements - Ecodesign and RoHS 2
Lamps under 8539 10 are subject to Ecodesign regulations (2009/125/EC) and related implementing measures on light sources, including Regulation (EU) 2019/2020. Many categories of incandescent lamps have been phased out of the EU market under energy efficiency policy. Specialised lamps (automotive, aviation, industrial) may benefit from Ecodesign exemptions. RoHS 2 restricts hazardous substances. WEEE 2 covers collection and recycling. CBAM does not apply.
Duty rates for subheading 8539 10
MFN rates should be verified in TARIC. The incandescent lamp market is shrinking due to Ecodesign regulations. Preferential rates under FTAs. Imports from Russia and Belarus may be restricted. VAT is charged.
Sealed beam lamp units - automotive applications
Importing sealed beam lamp units (CN 8539 10) into the European Union requires compliance with RoHS 2 (2011/65/EU), WEEE 2 (2012/19/EU) and CE marking. An EORI number and correct customs declaration are mandatory. MFN duty rates should be verified in TARIC, as ITA preferences or EU FTA rates (e.g. CETA, EPA, EU-Korea) may apply. Import from Russia and Belarus is subject to EU sanctions. Ecodesign Regulation (EU) 2019/2020 sets energy requirements for light sources. National import VAT applies at the destination Member State rate.
Frequently asked questions
Are sealed beam lamps subject to Ecodesign?
Sealed beam lamps under 8539 10 are subject to Ecodesign regulations on light sources. However, many specialised lamps (automotive, aviation, stage) benefit from Ecodesign exemptions as no LED alternatives with identical optical parameters exist. Importers should verify whether the specific sealed beam type is covered by an exemption.
How are halogen lamps classified in the CN?
Sealed beam lamps are classified under 8539 10. Tungsten halogen lamps without integrated reflectors under 8539 21. Other filament lamps up to 200 W under 8539 22. Other filament lamps under 8539 29. LED lamps under 8539 52. Fluorescent lamps under 8539 31/32/39.
Are lamps subject to CBAM?
No. CBAM covers only emissions-intensive goods. Lamps under 8539 10 belong to Chapter 85 and fall outside CBAM scope.
What regulations apply when importing sealed beam lamp units CN 8539 10?
Importing sealed beam lamp units (CN 8539 10) requires RoHS 2 (2011/65/EU), WEEE 2 (2012/19/EU) compliance, CE marking and an EORI number. Check the duty rate in TARIC. Import VAT applies.
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