Classifying computers and software

This guide will help you classify computers and software correctly for the purposes of the tariff.

Computers, computer parts and computer software covered in Chapter 84 and Chapter 85 of the European Classification of Goods (CN) may be classified according to

  • their function
  • their design, build and performance
  • whether they've got more than one function, including functions unrelated to computers
  • whether they're part of a complete system or an individual separate unit

Complete computers

Items that are classified under heading 8471 as 'automatic data processing machines' - computers - are machines that must be capable of all the following operations

  • storing the processing programs that run on them - and at least the data that's needed to run a program
  • being freely programmed in accordance with the requirements of the user
  • performing arithmetical computations specified by the user
  • executing, without human intervention, a processing program for which they need to modify their execution by making logical decisions throughout the process

Note 5a to Chapter 84 defines the term 'automatic data processing machine' for the purposes of heading 8471. Essentially, goods that are classified as computers must be able to use standard operating software and to perform functions like word processing and spreadsheet applications. They must incorporate a hard disk drive.

A computer may take the form of a system made up of several separate units - for example a keyboard, monitor, base unit and so on. With some exceptions, a unit is treated as part of a computer system if it meets all of the following conditions

  • it's of a type solely or principally used in a computer system
  • it can be connected to the central processing unit (CPU) either directly or through one or more other units
  • it can accept or deliver data in a form usable by the system, such as codes or signals

Keyboards, X-Y coordinate input devices like joysticks and mouse devices, and disk storage units only need to meet the last two conditions.

Desktop and tower systems

Standard desktop and tower systems must have at least

  • CPU - the base unit or 'system box'
  • input unit - for example a keyboard
  • output unit - for example a monitor

They can also include other units like printers and scanners. Built in 'extras' such as network cards and television cards are also treated as part of the system. Desktop and tower computer systems are classified under subheading 8471 49 00 00.

Servers

Network file servers that have both a keyboard and a monitor are, like desktop computer systems, classified under subheading 8471 49 00 00.

Network file servers that don't have both a keyboard and a monitor are classified as individual separate units. The base unit itself is classified under subheading code 8471 50 00 90. If a monitor is present (D-sub 15-pin only - not video), then that would be classified separately under subheading code 8528 52 10 00, while a keyboard would be classified separately under subheading 8471 60 60 90.

Printer servers and firewall systems aren't treated as computer servers, but as data communication apparatus. They're classified under subheading 8517 62 00 00.

Small portable computers

These include laptop and notebook computers and personal digital assistants with similar capabilities to laptops. To be classified under subheading 8471 30 00 00 they must weigh less than 10 kilograms and have at least

  • CPU
  • keyboard
  • display
  • means of loading programs

To classify a portable computer correctly, please also refer to the following item descriptions.

Palm-held portables

These are electronic personal organisers that don't usually have a full keyboard. They generally have pre-defined functions like a diary and an address book. They're classified under subheading 8543 70 90 99.

Other portable computers

Portable computers that don't meet the above requirements can include touch screen, luggable and industrial computers. There's no maximum weight, but they must include at least the following within the same housing

  • CPU
  • input unit
  • output unit

A touch screen usually counts as both an input and an output unit.

These types of portable computer are classified under subheading 8471 41 00 00.

Separate computing units - monitors, screens and projectors

Output devices such as monitors, screens and computer projectors are classified as separate units if they don't make up part of a complete system like a desktop computer. The subheading code under which they're classified depends mainly on

  • their type - for example cathode ray tube (CRT) or liquid crystal display (LCD)
  • their purpose - for computer output only or dual use

Note that when computer monitors and projectors are separate units, they're never classified under heading code 471.

Plasma, LCD and other flat panel display monitors

It is necessary to decide whether an LCD monitor not combined with any other apparatus is classified under subheading 8528 52, or as an 'other' monitor under subheading 8528 59 00.

Subheading 8528 52 covers: monitors capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471, not being a CRT monitor.

Subheading 8528 59 00 covers other monitors than mentioned above.

To decide which subheading applies, an overall assessment of the functions performed by the monitor is necessary as well as their degree of performance. This assessment may take into account features such as aspect ratio, resolution, screen size, etc.

The following Commission Implementing Regulations have classified various monitors in the two subheadings 8528 52 and 8528 59

Monitors that are not capable of receiving a signal directly from a computer, or cannot receive a signal from a computer at all, are classified under subheading code 8528 59 00.

Commission Implementing Regulation 459/2014 classifies various products as monitors under subheading code 8528 59 00. Products that include a USB interface that is designed purely for eg the transfer of media files or for reproducing audio or video from a USB memory stick etc, will be classified under subheading code 8528 59 00. Please see such products in Annex I, II and IV to the Regulation.

LCD or light-emitting diode (LED) monitors that include a television tuner are classified under subheadings 8528 72 40 00 or 8528 72 80 00 as reception apparatus for television respectively.

Cathode ray tube (CRT) Monitors are classified under subheadings 8528 42 00 00 or 8528 49 00.

Projectors

Those only capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471 are classified under subheading 8528 62 00 00.

Dual purpose projectors can display signals from a computer and also from other devices, such as

  • video and DVD recorders
  • television tuners
  • camcorders

These types of dual purpose projectors are often known as video projectors. Flat panel projectors using technologies like LCD and digital light processing (DLP) and other types of projector, such as CRT, are classified under subheading 8528 69

  • monochrome apparatus – 8528 69 20 00
  • others – 8528 69 80

LED video wall

These are module screen panels designed for outdoor viewing such as in a sports stadium, entertainment venues etc. The units comprise several modules made of tiles, each tile contains red, green and blue LED, the panel is presented with a video processor and a signal processor allowing images and video to be displayed. They’re classified under subheading code 8528 52 99 00. However, LED tiles whether or not connected in tiles without a video processor and therefore unable to display a video source directly onto the screen are classified under subheading code 8529 90 92 99.

Commission Implementing Regulations 2015/712 and 875/2014 classified a LED video wall under subheading 8528 59 39 (currently 8528 52 99) and a LED tile under subheading 8529 90 92.

LCD video wall

These LCD modules are intended for multiple screen configuration up to eg 5x5, are designed for indoor viewing such as video presentation, public information, still or moving image advertising etc. The integrated computer is designed for video processing and control of the network. The LCD modules are classified under subheading 8528 52 91 00.

Commission Implementing Regulation 877/2014 classified a LCD Video Wall under subheading 8528 59 31 (currently 8528 52 91).

Other types of screen

Electronic whiteboards are classified under subheading 8471 60 70 00.

Non-electric projection screens are classified in Chapter 90 under subheading 9010 60 00 00.

Computer printers and scanners

Computer printers and scanners are classified as separate units if they don't make up part of a complete computer system. Note that when printers - including multifunctional machines - are separate units, they're never classified under heading 8471.

Computer printers

All types of printer - laser, inkjet, thermal transfer, ribbon and so on - are classified under subheading 8443 32 10 90 as long as they're intended as output devices for computers. Other types of printer are classified under subheading 8443 39 00 00.

Scanners

Flat-bed and film-type scanners are classified under subheading 8471 60 70 00.

Combined printers and scanners

Multifunctional machines that combine a laser printer, scanner, photocopier and sometimes a fax are classified under subheadings 8443 31, 8443 32 or 8443 39.

Ink cartridges

Ink cartridges with a print head are classified under subheading 8443 99 10 90.

Ink cartridges without a print head are classified in Chapter 39 under subheading 3923 30 10 00 if they're empty, and in Chapter 32 under subheading 3215 90 70 90 if they've been refilled. Cartridges with a 'chip' to measure the ink level are also classified under subheading 3215 90 70 90.

Computer keyboards, mouse devices and other computing input devices

Computer input devices, such as keyboards, are classified as separate units if they don't make up part of a complete computer system.

Computer keyboards

Computer keyboards are classified under subheading code 8471 60 60 00.

X-Y coordinate input devices

Input units like mouse devices, trackballs, graphic tablets and light pens are classified under subheading 8471 60 70 00. This subheading code includes both standard corded devices and cordless units.

Electronic whiteboards are also input devices and are classified under subheading 8471 60 70 00.

Computer hubs, adapters and other network units

Network units include machines for receiving, converting, transmitting and regenerating voice, images or other data. They include various types of switching and routing apparatus. Note that when network apparatus are separate units, they're never classified under heading 8471.

All of the following items are classified under subheading 8517 62 00 00

  • modems, including external modems and Integrated Services Digital Network (ISDN) adapters
  • external local area network (LAN) units, including adapters, bridges and hubs
  • wide area network (WAN) units, including gateways and ISDN cards
  • network cards for ethernet, token ring and other network technology

Wireless fixed access units (Wi-Fi) are also classified under this subheading code. These are transmitter/receiver units that enable wireless access to fixed line networks. They can take the form of printed circuit boards or complete units in a housing.

Wireless Global System for Mobile Communication (GSM) and General Packet Radio Service (GPRS) modules

These are transmitter/receiver units that allow remote wireless access to personal digital assistant (PDA) equipment through cellular mobile telephone networks. They're also classified under subheading 8517 62 00 00.

Cables fitted with connectors

Coaxial cables fitted with connectors are classified under subheading 8544 20 00 00.

Cables used to connect modems to telephone sockets are classified under subheading 8544 42 10 00.

Data cables and power cables used for voltage not exceeding 1,000 volts are classified under subheading 8544 42 90 00.

Computer sound, picture and graphics devices

Webcams and other digital cameras that don't record, save or store images are classified as television cameras under subheading 8525 80 19 90. They're designed to form images for onward transmission, by line or by radio, to other apparatus.

Other digital cameras

These are cameras that record or save images on a memory card or module, disk, tape or other storage device.

Still image digital cameras with video capture capabilities are classified under subheading code 8525 80 91 or under subheading code 8525 80 99 if they meet the following criteria

  • they are capable, using the maximum storage capacity, of recording in a quality at or exceeding 800 x 600 pixels at 23 frames per second, at least 30 minutes in a single sequence of video
  • some cameras can continuously record video for longer than 30 minutes, but the captured images are recorded in separate files that last less than 30 minutes - unless the camera is automatically switched off after 30 minutes, the capturing of images in separate files that last less than 30 minutes does not influence the duration of the continuous video recording capability of the camera

Video cameras - digital camcorders - are classified under subheading 8525 80 99 00 if the files can be transferred to the apparatus from an automatic data-processing machine or another external device via the USB or DV-in interface.

Note that when webcams, digital cameras and digital camcorders are separate units, they're never classified under heading 8471.

There are several Commission Implementing Regulations relating to cameras

The CJEU has also issued a Judgment in Case C-178/14 Vario Tek GmbH v Hauptzollamt Dusseldorf on the classification of video camera with no zoom function

Speakers

Speakers can be passive or active units. Active units include an amplifier in the housing or cabinet. The subheading code under which speakers are classified depends on the number of 'drive units' - the actual loudspeaker cones or ribbons - in each cabinet.

Speakers with a single drive unit in each cabinet are classified under subheading 8518 21 00 00.

Speakers with more than one drive unit in each cabinet are classified under subheading 8518 22 00 90.

Note that when speakers - and microphones - are separate units, they're never classified under heading 8471.

MP3 players

MP3 players are classified as sound recording or reproducing apparatus. The subheading code under which they're classified depends on whether or not they've got a built-in radio or video device.

MP3 players with no radio are classified under subheading 8519 81 95 90. Those with a built-in radio are classified under subheading 8527 13 99 00. If they can record or play video, they're classified under subheading 8521 90 00 90 whether they've got a radio or not.

Graphics cards

These can be basic 2D graphics adapters, 2D/3D cards or 3D graphics accelerators that work through an existing graphics card, or through a grabbing or editing card. They're classified under subheading 8471 80 00 00.

Sound cards

Sound cards on their own are classified under subheading 8471 80 00 00.

Television tuner cards

Television PCI tuner card assemblies are classified under subheading 8528 71 11 00. Products contained in a housing are considered to have lost their character as electronic assemblies, and are classified under subheading 8528 71 19 00.

Other separate computing units

Various other computer units are classified as separate units if they don't make up part of a complete computer system.

Base units

Base units, or 'system boxes', should contain at least a central processing unit (CPU) and main memory. They're classified under subheading 8471 50 00 00.

External drives

Central storage units, like Redundant Array of Independent Disks (RAID) systems for networks, can be magnetic disk, tape or optical drives. They're classified under subheading 8471 70 20 00.

RAID controllers without drives are classified under subheading 8471 70 98 00.

External drives for use with a single computer are classified according to the drive type, as follows

  • optical drives, such as CD, DVD and MO (magneto-optical) drives, are classified under subheading 8471 70 30 00 whether they're read-only or read and write (CD drives can retrieve signals from CD-Roms, audio CDs and photo CDs and include a jack for earphones, a volume control or a start/stop button)
  • hard disk drives, including removable disk drives and micro drives, are classified under subheading 8471 70 50 00
  • floppy drives, including super floppy, are classified under subheading 8471 70 70 00
  • tape drives are classified under subheading 8471 70 80 00
  • pen drives - portable USB memory devices - are classified under subheading 8523 5110 00

CD and DVD duplicators

Standalone machines for bulk copying CD or DVD disks are classified under subheading 8521 90 00 90.

Card readers

The following types of card reader are all classified under subheading 8471 90 00 00

  • magnetic card readers
  • smart card readers (a smart card is a card which has embedded in it one or more electronic integrated circuits - a microprocessor, random access memory (RAM) or read-only memory (ROM) - in the form of 'chips' which can contain contacts, a magnetic stripe or an embedded antenna, but doesn't include any other active or passive circuit elements)
  • memory card readers - including Compact Flash, Smart Media, Secure Digital (SD), Multimedia Card (MMC), Memory Stick, XD Picture Card and PC Card

Global Positioning System (GPS) Modules

These units provide a position determining function to devices like personal digital assistants (PDAs) and laptops by means of a cable or wireless connection. They're classified under subheading 8526 91 20 20 if they are in the form of an assembly, or under subheading 8526 91 20 90.

External USB hubs

These are classified under subheading code 8517 62 00.

Dongles

Dongles are USB interface devices that provide a means of communicating (Bluetooth or WI-FI) with a computer. Dongles are classified under subheading 8517 62 00 00.

Hardware encryption devices connected to a computer via USB interface for deactivation to software or to protect the data in the computer are classified under subheading 8471 80 00 00.

Encryption security devices

These are access code generators that allow users to log on to a network remotely. They can't be connected directly to a computer. Encryption security devices are classified under subheading 8543 70 90 99.

Internal upgrades and parts

Many computer parts and accessories are classified under heading 8473. However some items are treated as complete units, not parts, and classified under other headings.

Parts

The following items are classified as parts rather than as complete units under heading 8473.

Central processing units (CPUs) are made up of two or more electronic integrated circuits. They may come packaged with certain other components, usually a heatsink and sometimes a cooling fan. Some examples include processors. They're classified under subheading 8473 30 20 00.

CPU heatsinks on their own are classified under subheading 8473 30 80 00.

Motherboards that aren't fully populated with CPU and random access memory (RAM) are treated as electronic parts and classified under subheading 8473 30 20 00.

Computer casings - with or without a power supply - are classified under subheading 8473 30 80 00.

Barebone units usually consist of a computer case, a motherboard and a power supply. They're classified under subheading 8473 30 80 00.

Memory modules designed for use only, or mainly, with computers and computer units that are classified under heading 8471 are classified under heading 8473. Memory modules for use only, or mainly, with apparatus that are classified under a different heading are classified as part of the apparatus. Memory modules designed for use with a range of apparatus are classified under heading 8548.

Standard dynamic random access memory (DRAM) and modules of metal oxide semiconductor (MOS) technology, like single in-line memory module (SIMM) and dual in-line memory module (DIMM), are classified under subheading 8473 30 20 00.

Other standard memory modules, including non-volatile types like static random access memory (SRAM) modules, are classified under subheading 8473 30 20 00.

Complete units

The following items are classified as complete units rather than as parts under various different heading codes.

Power supply units (PSUs) that are specially made and suitable for use with computer units like base systems or printers are classified under subheading 8504 40 30 90.

Combined CPU fan and heatsink units for personal computers are classified under subheading 8414 59 20 90.

Motherboards that are complete with a CPU and RAM are treated as a complete computer base unit and classified under subheading 8471 50 00 90.

Internal drives are classified according to the drive type, as follows

  • optical drives, like CD, DVD and MO, are classified under subheading 8471 70 30 00 whether they're read-only or read and write
  • hard disk drives, including removable disk drives, are classified under subheading 8471 70 50 00
  • card readers for semiconductor media are classified under subheading 8471 70 98 00
  • floppy drives, including super floppy, are classified under subheading 8471 70 70 00
  • tape drives are classified under subheading 8471 70 80 00

Other expansion cards are also classified as complete units rather than as parts. The following expansion cards are all classified under subheading 8471 80 00 00

  • input/output (I/O) cards
  • serial and parallel port cards
  • USB cards and adapters
  • SCSI (Small computer system interface) and IDE (Integrated Drive Electronics) controller cards

Various other types of computer expansion card are also classified under this subheading.

Memory modules designed to be used with apparatus other than computers and computer units classified under heading 8471 are classified under subheading 8548 90.

Machines with a specific function that aren't computers

A 'computer part' is an integral component of a computer. Various computer parts are classified as separate units if they don't make up part of a complete computer system.

A 'computer accessory' gives a computer an additional function, but isn't an integral component. It's an interchangeable part or device that's designed to adapt a machine to

  • do a particular operation
  • perform a particular service
  • increase its range of operations

Computer parts

Note 2 to Section XVI sets out the legal basis for classifying (computer) parts.

Many integral computer parts are classified under heading 8473.

A part that's an integral part of a computer, but is specifically covered by a heading in Chapter 84 or Chapter 85, is classified under that heading. For example, because coaxial cable is specifically covered by heading 8544, it's classified under this heading and not as a computer part under heading 8473. However, there are certain headings to which this rule doesn't apply because they're designated parts headings. They're listed in Note 2a to Section XVI and are

  • 8409
  • 8431
  • 8448
  • 8466
  • 8473
  • 8487
  • 8503
  • 8522
  • 8529
  • 8538
  • 8548

Some parts are suitable for use solely or principally with a particular kind of machine - or with a number of machines classified under the same heading- but aren't specifically covered by a heading in Chapter 84 or Chapter 85. These are classified either under one of the headings listed above or under the same heading as the machine or machines that they're suitable for.

Parts that are equally suitable for use solely or principally with goods classified under heading 8517, and under heading 8525 to 8528, are always classified under heading 8517. This rule is set out in Note 2b to Section XVI.

Any other parts that are suitable for use with a number of machines classified under different headings are classified, as appropriate, under one of the following headings

  • 8409
  • 8431
  • 8448
  • 8466
  • 8473
  • 8503
  • 8522
  • 8529
  • 8538

If none of the above heading codes is suitable, they're classified under heading 8487 or 8548. This rule is set out in Note 2c to Section XVI.

Computer accessories

Many computer accessories are classified under heading 8473, which deals specifically with parts and accessories for machines that include computers. Only a few headings in Chapter 84 and Chapter 85 cover computer accessories. If the item, or items, for which the accessories are intended is classified under a heading that doesn't cover accessories, then the accessories themselves are classified elsewhere in the Tariff according to their function or constituent material.

Software

Software classification depends on the media on which it's been recorded and the nature of the software. Media include

  • CD, DVD, Laserdisc, Minidisc and other laser-read disks. Even though there are differences in the manufacturing and recording - or writing - processes, these are all designed to be read by some kind of laser system once recorded.
  • floppy disks
  • magnetic tapes
  • magnetic stripe cards
  • memory cards
  • cartridges for video games consoles

For the purposes of Tariff classification, software categories include

  • programs and data
  • sound recordings
  • computer games
  • films, pictures and image files
  • games for video games consoles

Programs and data

These include word processing programs, spreadsheets, desktop publishing programs, painting or drawing programs, route planners, encyclopaedia, business or phone directories, catalogues, device drivers, system boot-disks and backup disks. Programs and data are classified according to the media they're recorded on. If they're recorded on

  • CD, Laserdisc, Minidisc or other laser-read disks then they're classified under subheadings 8523 49 20 00
  • DVD, then they’re classified under subheading 8523 49 10 00
  • magnetic tape and floppy disc, then they're classified under subheading 8523 29 19 00

Sound recordings

These include music disks, language courses, wildlife recordings, train enthusiasts' sound bites, talking books and so on. Sound recordings are classified according to the media they're recorded on. If they're recorded on

  • Minidisc then they're classified under subheading 8523 29 19 00
  • any other laser-read disk - for example CD, SACD or DVD - then they're classified under subheading 8523 49 10 or 8523 49 20 00

Computer games

These include flight simulators, 'shoot 'em ups', sports games, car racing games, strategy games and so on for use only on an automatic data processing machine (computer). Computer games are classified according to the media they're recorded on. If they're recorded on

  • CD, Laserdisc, Minidisc or other laser-read disk then they're classified under subheading 8523 49 20 00
  • floppy disk then they're classified under subheading 8523 29 19 00

Films, pictures and image files

These include movies, videos, photo CDs, clip art collections, photo collections and karaoke disks. Films, pictures and image files are classified according to the media they're recorded on. If they're recorded on

  • DVD then they're classified under subheading 8523 49 10 00
  • any other laser-read disk then they're classified under subheading 8523 49 20 00
  • floppy disk then they're classified under subheading 8523 29 19 00

Games for video games consoles

These are classified according to the media on which they're recorded. If they're recorded on

  • DVD, then they're classified under subheading 8523 49 10 00
  • any other laser-read disk, then they're classified under subheading 8523 49 20 00
  • cartridges, then they're classified along with games consoles in Chapter 95 under subheading 9504 50 00

Software on memory cards and magnetic stripe cards

Software that's recorded onto a memory card - for example Compact Flash, Smart Media, Secure Digital (SD), Multimedia Card (MMC), Memory Stick, XD Picture Card, PC Card or PCMCIA Card - is classified under subheading 8523 51 90 00.

Software that's recorded onto a magnetic stripe card is classified under subheading 8523 21 00 00.

Blank media

Blank media include

  • CD, DVD, Minidisc and other laser-read disks
  • flash memory cards
  • magnetic tapes and disks
  • removable hard disks
  • micro drives
  • floppy disks, floppy disk cookie only and super floppy disks

CD, DVD, Minidisc and other laser-read disks

Blank (unrecorded disks) are classified under subheading 8523 41. Depending on the capacity of the disks they are classified under subheadings 8523 41 10, 8543 41 30 or 8523 41 90.Blank Minidiscs. These use magnetic optical technology for recording and erasing. They've got a magnetic layer and are rigid magnetic disks. Blank Minidiscs are classified under subheading 8523 29 15 00.

  • other blank magneto-optical disks - these are classified under subheading 8523 29 15 00.
  • DVD-R disks -the technology of these disks is assumed to be similar to the CD-R disk in that they use laser technology for both reading and writing - DVD-R disks are classified under subheading 8523 41.

DVD+RW discs. These use the Phase-change technology for recording and erasing and are classified under subheading 8523 41.

Flash memory cards

These cards contain two or more flash memory integrated electronic circuits mounted on a base. There are different types of flash memory card, including Compact Flash, Smart Media, Secure Digital (SD), Multimedia Card (MMC), Memory Stick, XD Picture Card, PC Card and PCMCIA Card. Flash memory cards are classified under subheading code 8523 51 10 00 if unrecorded. Recorded they are classified under subheading 8523 51 90.

Magnetic tapes and disks

These include compact cassettes, VHS and mini-DV and are classified under subheading 8523 29 15 00.

Removable hard disks - disk only, not the complete drive

This type of disk is usually supplied with some software utilities pre-loaded, so it's classified as recorded software under subheading 8523 80 10 00.

Micro drives

These are miniature hard disk drives for use in a PC card or similar slot. They're classified under subheading 8471 70 50 00.

Floppy disks

These include standard floppy disks, floppy disk cookie only and super floppy disks - for example the LS120 type. They're all classified under subheading 8523 29 15 00.

Share this page:

Quick links