Classification and tariff conclusion
An LPWAN base station is examined in CN 8517 61 00; a gateway that receives, converts and transmits sensor data is commonly examined in 8517 62 00. Other transmit/receive apparatus may fall in 8517 69, while a measuring or alarm sensor can be classified by its principal measuring/signalling function. The six Vietnamese eight-digit codes cannot be copied into an EU declaration. The complete architecture and the current Combined Nomenclature determine the CN eight-digit and TARIC ten-digit code.
Technical facts controlling classification
Record the protocol, frequency plan, output power, bandwidth, duty cycle, antenna, processor, routing/protocol conversion, Ethernet or cellular backhaul and sensor function. Apply GIR 1 and 6 to the condition at import. LoRaWAN/Sigfox equipment in short-range bands and NB-IoT/LTE-M equipment using a licensed mobile network are not regulatory substitutes. Separately imported radio modules, gateways, antennas and sensors require their own classification.
Customs duty, VAT and origin
The common customs duty for the principal 8517.61/62 communications provisions is generally 0%, subject to the current TARIC and any origin-specific measure. Import VAT is charged at the Member State rate and on the customs value plus duty and statutory additions. Preferential origin requires the exact product-specific rule and valid proof; routing or repacking does not create origin. Check sanctions, dual-use controls and trade remedies separately where the product, encryption or parties create a risk.
RED conformity and CE marking
Directive 2014/53/EU (RED) applies before the radio equipment is placed on the Union market. The manufacturer must assess Article 3 requirements for health/safety, EMC and efficient spectrum use, prepare technical documentation and an EU declaration of conformity, affix CE marking and provide instructions and safety information. The EU importer must verify conformity, identify itself, preserve documents and cooperate with market surveillance; a radio-module report alone may not establish conformity of the final host and antenna configuration.
Spectrum and cybersecurity
A device must use the EU frequency plan and comply with harmonised spectrum conditions and applicable ETSI standards; a 920–923 MHz configuration intended for Vietnam or Asia must not simply be enabled in the EU. Internet-connected LPWAN equipment is also within the RED cybersecurity requirements activated by Delegated Regulation (EU) 2022/30 from 1 August 2025; the 2026 repeal only becomes effective with the CRA regime on 11 December 2027. Data protection and sector-specific metering, medical or machinery law may apply to the sensor use case.
Import file and declaration
Keep the invoice, customs value and origin evidence, datasheet, block diagram, frequency/power/bandwidth/duty-cycle and antenna tables, risk assessment, RED test reports, technical file, EU declaration of conformity, CE artwork, labels and instructions. Suggested description: “LPWAN radio gateway, EU frequency plan, protocol ..., receives/converts/transmits sensor data, backhaul ..., output ... dBm, antenna ..., model ..., new; CN reference 8517 62 00.” Confirm the TARIC code and national VAT on the declaration date.
Official sources
Sources checked September 22, 2026: EU TARIC consultation; Directive 2014/53/EU; European Commission RED guidance; harmonised standards for radio equipment; Delegated Regulation (EU) 2022/30.
