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Detailed Description of Commission Implementing Regulation (EU) 2024/2621
The European Commission has adopted Implementing Regulation (EU) 2024/2621 of 1 October 2024 concerning the classification of certain goods in the Combined Nomenclature (CN). This regulation ensures the uniform application of the CN by classifying specific goods under appropriate CN codes, based on the general rules for interpretation.
Classification of a Tactical Response Robot
The regulation specifies the classification of a machine referred to as a tactical response robot. The detailed description of this machine is as follows:
- Track-Mounted Chassis: The robot features a track-mounted chassis with approximate dimensions of 1,500 mm × 1,200 mm × 1,300 mm. It is equipped with two electric drive motors of 7.5 kW each for propulsion, providing a tractive force of up to 4 tonnes. The electrical power is supplied by a lithium-ion battery.
- Camera System: It includes a camera system with four static directional cameras capable of transmitting live image feeds to the user.
- LED Spotlights: The robot is fitted with six LED spotlights aligned in the direction of movement, along with LED ambient lighting.
- Dispersing Device: There is a device for dispersing water or foam for firefighting purposes, with a capacity of up to 2,000 liters per minute at 10 bars. This device is fully compatible for connection with the hose of a firefighting truck.
- Cable Winch: The machine includes a cable winch with an extendable claw support to provide stability when handling large loads.
The robot is controlled remotely via a remote control with a range of up to 150 meters and/or from a system carrier vehicle via intranet with a range of up to 2,500 meters (WLAN-based). The product may be presented in different configurations depending on the extra equipment mounted on the chassis upon request. Optional equipment may include:
- Movable cameras for normal and thermal image transmission
- Additional LED spotlights
- A Raman spectrometer for the detection of hazardous substances
- A remotely controlled manipulator arm to perform precise tasks (e.g., sampling)
- A trailer coupler, etc.
The product is designed for use in firefighting and recovery operations, allowing firefighting personnel to remain outside the danger zone (such as areas with hazardous material exposure, collapse danger, or intense heat development) while still being involved in and remotely controlling operations at a safe distance.
Classification Under the Combined Nomenclature
According to the regulation, the tactical response robot is classified under CN code 8424 89 70. This classification is determined by:
- General Rules 1 and 6 for the interpretation of the Combined Nomenclature
- Note 3 to Section XVI
- The wording of CN codes 8424, 8424 89, and 8424 89 70
Reasons for the Classification
The regulation provides detailed reasoning for the classification:
- Exclusion of Heading 8701: Classification under heading 8701 is excluded because the product is not a vehicle constructed essentially for hauling or pushing another vehicle, appliance, or load. (Refer to Note 2 to Chapter 87)
- Exclusion of Heading 8705: Classification under heading 8705 is also excluded, as the product does not have the characteristics of a vehicle of heading 8705. Specifically, it does not form an essentially complete motor vehicle chassis or truck and lacks features such as a propelling engine, gearbox, controls for gear-changing, and steering and braking facilities. (Refer to the Harmonized System Explanatory Notes to heading 8705)
- Composite Machine: The product is considered a composite machine within the meaning of Note 3 to Section XVI. It is to be classified as if consisting only of that component or as being that machine which performs the principal function.
- Principal Function – Dispersing Device: The dispersing device for water or foam is determined to be the principal function of the machine due to its objective characteristics, mainly the volume, pressure, and projecting distance of the water or foam.
- Auxiliary Functions: The camera system and LED spotlights serve to remotely control and guide the machine. The winch operation for transferring loads is performed by human intervention via the cable winch and, optionally, via the trailer coupler.
- Optional Equipment: Functions such as identifying dangerous fields, detecting hazardous substances, and performing precise tasks are considered complementary and subsidiary to the function of dispersing water or foam, as they are performed by optional equipment.
Based on these considerations, the product is classified under CN code 8424 89 70 as “Other appliances for the projection or spraying of liquids or powders.”
Binding Tariff Information
The regulation states that binding tariff information (BTI) which does not conform to this classification may continue to be invoked for a period of three months from the date of entry into force of this regulation, in accordance with Article 34(9) of Regulation (EU) No 952/2013.
Entry into Force
This regulation enters into force on the twentieth day following its publication in the Official Journal of the European Union. It is binding in its entirety and directly applicable in all Member States.
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