EU classification and import answer
There is no universal AGV tariff code. An electric self-propelled works truck for short-distance goods transport in a factory or warehouse, with a fixed deck and no lifting or handling equipment, starts in CN 8709 11. An AGV with forks, a lift table, clamp or active transfer equipment starts in CN 8427 10; a coordinated conveying or AS/RS installation may require heading 8428. The final eight-digit CN and ten-digit TARIC code depend on the imported configuration, origin and declaration date.
Technical facts that decide the code
Document propulsion, battery, payload, speed, operating area, road capability, fixed deck, hitch, forks, lift stroke, rollers, conveyor, clamp, sensors, navigation and software. State whether the entry is a complete vehicle, unassembled vehicle, parts or an interconnected system. Apply CN General Rules 1 and 6 and the Section notes. Magnetic tape, QR, lidar or SLAM merely describe guidance; commercial terms AGV, AMR and robot do not displace objective characteristics.
No lifting or handling equipment: CN 8709 11
Heading 8709 expressly covers self-propelled works trucks not fitted with lifting or handling equipment and used in factories, warehouses, docks or airports for short-distance goods transport. A driverless electric flat-deck carrier can meet CN 8709 11 when the deck does not lift, push or transfer the load and the design is not for public roads. Preserve dimensions, turning circle, speed, payload and operating layout. The statistical subdivision and TARIC measures must be confirmed in the live database.
Lift or handling equipment: CN 8427 10
Heading 8427 covers fork-lift trucks and other works trucks fitted with lifting or handling equipment. An integral fork, elevating platform, clamp, telescopic fork or powered roller that receives or discharges a load requires CN 8427 10 analysis. The General Court in T-321/25, 10 June 2026, confirmed the legal distinction between 8709 vehicles without lifting equipment and 8427 works trucks fitted with it. A short lift stroke is not automatically immaterial.
AMRs and integrated systems
An AMR mainly used for inspection, cleaning or a special service may belong to 8479.89 or another functional heading rather than 8709. Machines imported together and interconnected to perform a clearly defined storage, retrieval or conveying function may qualify as a Section XVI Note 4 functional unit under 8428. A single contract or common controller does not automatically absorb static racks, structures or independently functioning machinery.
Parts, batteries and controls
Parts solely or principally for 8709 vehicles are compared with 8709 90; qualifying 8427 parts with 8431 20 under Section XVI Note 2. Batteries, chargers, motors, computers, radio modules, sensors and control cabinets described in their own headings remain separately classified. Lithium batteries require transport evidence. Engineering, software licences, assists and royalties also require a Union Customs Code valuation review.
Customs duty, origin and import VAT
Query TARIC with the final code, origin and declaration date for third-country duty, suspension, quota, sanctions and trade-defence measures. Preference requires the applicable agreement, product-specific origin rule and valid proof; country of dispatch is not origin. Import VAT is charged at the rate of the Member State of importation and on the legally defined taxable base. Do not infer a national VAT or customs rate from the six-digit HS alone.
Import controls and market access
A new industrial AGV is not automatically prohibited merely because of headings 8709 or 8427. Screen TARIC restrictions, dual-use/end use, sanctions, radio equipment, batteries, chemicals and used machinery by specification. Market access is a separate gate from customs release. The importer and economic operator must identify applicable harmonisation legislation, retain technical documentation and satisfy language, traceability and surveillance obligations.
Machinery safety and CE conformity
Machinery Directive 2006/42/EC applies until 19 January 2027; Regulation (EU) 2023/1230 applies from 20 January 2027. Depending on configuration, EMC, Radio Equipment, Low Voltage and battery rules may also apply. Validate risk assessment, protective fields, stopping distance, crossings, emergency stop, restart prevention, load retention, charging and fire response. ISO 3691-4 is useful but does not replace the binding conformity assessment.
Customs file and proposed description
Keep contract, invoice, packing list, transport document, photos, video, drawings, crate-level BOM, payload, speed, lift stroke, deck and transfer design, battery, radio module, software function, origin and valuation evidence, EU declaration and technical file. Suggested 8709 wording: “Electric self-propelled automated guided works truck for short-distance warehouse goods transport, fixed load deck, not fitted with lifting or handling equipment, payload ..., model ..., new.” Describe lift hardware when present.
Official sources, limits and BTI
Sources checked 12 September 2026: TARIC, General Court T-321/25, Regulation (EU) 2023/1230, EU BTI and Access2Markets. This is conditional guidance, not a BTI. Obtain BTI for recurring or high-value entries.