Subheading 854190 of the Combined Nomenclature covers parts for semiconductor devices, mounted piezoelectric crystal assemblies, light-emitting diodes (LEDs) and photovoltaic cells, not classified under more specific subheadings of heading 8541. Typical goods include ceramic and metal packages for diodes and transistors, leadframes, heat sinks for power semiconductors, lens caps for LEDs, and ceramic substrates for semiconductor modules. Classification under 854190 requires the part to be identifiable as a component intended solely or principally for semiconductor devices of heading 8541. Leadframes manufactured from copper strip, stamped and gold-plated, represent one of the highest-volume products in this subheading. Parts for semiconductor devices must be distinguished from parts for integrated circuits (854290) and from unprocessed semiconductor materials such as silicon wafers (heading 3818). Classification is based on the GIR, rules 1 and 6, taking into account the notes to Section XVI and Chapter 85 of the CN. Where doubt arises regarding classification, it is advisable to apply for a Binding Tariff Information ruling from the competent customs authority.

Parts for semiconductor devices under subheading 854190, as electronic components, are subject to the RoHS 2 Directive (2011/65/EU as amended), which restricts the use of lead, mercury, cadmium, hexavalent chromium, PBB, PBDE and four phthalates (DEHP, DBP, BBP, DIBP). Importers should hold a RoHS compliance declaration from the manufacturer or supplier. Under the ITA (Information Technology Agreement), semiconductor products and their parts benefit from a zero percent MFN customs duty rate when imported into the EU from ITA signatory countries, including the USA, Japan, Taiwan, South Korea and China. The WEEE 2 Directive (2012/19/EU) applies to finished electrical equipment rather than industrial components, although the importer should be aware that the final product containing these parts will be subject to collection and recycling obligations. CBAM does not apply to semiconductor products from Chapter 85. Import requires an EORI number, a correct customs declaration filed in the AIS/IMPORT system, a commercial invoice and a technical specification identifying the intended use of the part for semiconductor devices.

Current MFN customs duty rates for goods under subheading 854190 should be verified in the European Commission's TARIC database before each customs clearance. As IT products covered by the ITA, parts for semiconductor devices benefit from a zero MFN rate when imported from ITA signatory countries. The ITA expansion of 2016 confirmed the coverage of semiconductor component parts under the zero-duty regime. Preferential duty rates under EU FTAs such as CETA with Canada, EU-Korea, EPA with Japan, EVFTA with Vietnam, and TCA with the United Kingdom may provide additional benefits where rules of origin are met and appropriate proof of origin (EUR.1, invoice declaration or REX registration) is presented. Imports from Russia and Belarus may be subject to sanctions restrictions under current EU Council regulations. Importers should verify the 10-digit TARIC code prior to clearance, as codes may change during annual CN updates. National VAT is charged on every import. Where classification uncertainty exists, a Binding Tariff Information ruling is recommended.