A Photovoltaic (PV) System typically comprises multiple solar panels and other devices, such as storage batteries, electronic controllers, and boards or assemblies containing components, capable of directly powering equipment like electric motors or electrolyzers. To assist companies in ensuring accurate declarations and enhancing Customs clearance efficiency, key considerations regarding the Customs classification of PV systems and their components are outlined below.
I. Classification of PV Systems & Components
Photovoltaic (PV) systems should be classified under heading 8501 based on their output current type, specifically subheadings 85017 for DC systems and 85018 for AC systems.To be specific, the classification of components declared separately for import or export shall be determined by the principle of giving precedence to specifically named headings, based on their actual state at the time of Customs inspection.For instance, iron-basedsolar panel mounting brackets typically fall under heading 7308, photovoltaic inverters under 8504, storage batteries under 8507, control equipment under 8537, solar photovoltaic panels under 8541, and parts for PV systems not specifically named elsewhere are generally classified under heading 8503.
II. Common Classification Pitfalls
(I) Pitfalls in ClassifyingSolar Panel Mounting Brackets
The classification of a solar panel mounting bracket must be determined by its actual state at the time of Customs inspection.Completely Knocked Down (CKD) kits, typically comprising components such as columns, beams, rails, and connectors, based on its material composition,are considered structural elements once installed, as they are positioned permanently and not intended for relocation.For example, a CKD made of iron is generally classified under heading 7308. The rails included in such kits, which are often pre-drilled profiles requiring no further processing and are explicitly dedicated to assembling the solar panel mounting bracket, are considered integral components of the CKD kit and are classified together under heading 7308.
However, if a specific profile from these components is declared for export separately without its complementary parts, its classification, based on its actual condition,shall be under heading 7216, provided that it has only been drilled (without further operations like welding) and its processing level does not exceed the scope of heading 7216, pursuant to the principle of giving precedence to specifically named headings.
Important Note: A significant difference of 13 percent exists in the export tax rebate rates between CKD kits under heading 7308 and individual profiles under heading 7216.
(II) Classification Boundaries of Solar Photovoltaic Panels
A solar photovoltaic panel, also known as a solar cell, is a silicon photovoltaic cell (a barrier-layer device) with relatively high output power. It is particularly suitable for applications such as control equipment&Regulators, detection of light pulses, and fiber-optic communication systems, as it directly converts sunlight into electricity.Solar cells, are typically used in groups as power sources and are generally classified under heading 8541, including those that are mounted within assemblies or assembled into modules.However, if the product is already fitted with components (even ones as simple as a current-directing diode) that enable it to directly supply power to devices such as electric motors or electrolyzers, it shall be classified as a power supply unit under heading 8501.
Customs Advisory:The Customs classification of Photovoltaic (PV) systems and their components primarily depends on factors such as function, intended use, composition, and operating principle. Enterprises should verify these elements in detail according to the actual condition of the goods at the time of import or export. Particular attention must be paid to the extent of processing and the composition of the such items prone to misclassification before declaring them. Relevant supporting documents, such as product manuals and installation drawings, should be submitted with the declaration to avoid Customs clearance delays due to such pitfalls.(By Chen Tianwen)
Disclaimer：The above content is translated from Chinese version of China Inspection and Quarantine Times. The China Inspection and Quarantine Times version shall prevail.
