Companies used to export solar thermal products (or even import) will be familiar with the need to apply a reference code, more specifically a Harmonized System (HS) code, used for international trade classification and customs purposes. These codes can be used for export or import declarations and may be subject to different trade restrictions, tariffs or preferences depending on the country of origin or destination.
Over the years, the code applied to solar thermal products was a more generic code HS 841919. This code is part of the HS chapter 84, which covers machinery and mechanical appliances and refers specifically to instantaneous or storage water heaters.
This has been revised and the new code for solar thermal products is HS841912. This code specifically refers to solar water heaters.
Why did it change?
It has been reported that problems with the classification of solar thermal thermosiphon systems as instantaneous electric water heaters were creating problems (legal cases, high tariffs) to solar thermal companies in particular countries.
As a result, Solar Heat Europe has requested the European Commission and the World Customs Organisation to look into the misclassification of solar thermal products.
The new code applied to solar thermal products avoids this issue, namely when other products under the more generic code HS841919 have higher tariffs or trade restrictions.
What should you do?
We strongly recommend using the new code. We can expect that solar thermal, in most cases, has a more beneficial status in terms of tariffs and trade restrictions than other products, in particular non-renewable ones.
Apart from that, it will help to have a clear indication of the trade balance of solar thermal products, allowing to identify trade amounts and trade flows.
It is essential for the proper recognition of our sector to have a clear indication of the trade balance, more notably to highlight the EU exports of solar thermal products. In order to do so, we need to have a good representation of the actual trade data by means of the use of the solar thermal HS code (HS HS841912).
Where to get more information?
For more information about the new HS84191200 code, you can contact our Secretariat at members@solarheateurope.eu and check some of the online resources proposed below: