CN subheading 691010 covers sanitary ware made of porcelain: kitchen and bathroom sinks, washbasins, baths, bidets, WC pans, urinals and cisterns made of sanitary porcelain. The decisive classification criterion for subheading 691010 as opposed to 691090 is the material: articles must be made of porcelain, which is a vitrified, essentially non-porous ceramic with a water absorption rate below 0.5%, typically white or off-white, fired at high temperatures. Sanitary porcelain differs from ordinary stoneware and earthenware by its superior mechanical strength, negligible water absorption and smooth glazed surface. Sanitary ware made of stoneware or earthenware is classified in subheading 691090. Heading 6910 covers all ceramic sanitary ware designed for permanent installation in bathrooms, toilets and kitchens as sanitary fixtures. Classification is performed in accordance with GRI rules 1 and 6, with reference to the Chapter 69 notes. The importer should specify in the customs declaration the material (porcelain vs. other ceramic), the type of article and the intended use. In case of doubt, a Binding Tariff Information (BTI) ruling is advisable.

Imports of ceramic sanitary ware under subheading 691010 into the EU are subject to the Construction Products Regulation (CPR), Regulation (EU) No 305/2011. WC pans, washbasins, baths and bidets intended for permanent installation in buildings are construction products and require CE marking and a Declaration of Performance (DoP) when covered by a harmonised standard. Key harmonised standards for ceramic sanitary ware are EN 997 (WC pans and WC suites), EN 14688 (washbasins), EN 14516 (baths) and EN 14296 (urinals). Articles covered by these standards placed on the EU market must bear CE marking and be accompanied by a DoP. Ceramic sanitary ware comes into contact with drinking water and is therefore subject to Regulation (EU) 2020/1783 on requirements for substances and materials in contact with drinking water — the producer or importer must demonstrate that glazing and ceramic body materials do not release harmful substances into water above permitted thresholds. REACH Regulation (EC) No 1907/2006 applies to SVHC substances in the product materials, particularly lead and cadmium compounds in pigments and glazes. The General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, applicable from 13 December 2024, requires importers to carry out a risk assessment, maintain technical documentation and designate a responsible person in the EU. MFN duty rates and any anti-dumping measures must be verified in the EU TARIC database.

Ceramic sanitary ware under subheading 691010 is imported into the EU primarily from China, Turkey, Vietnam, Morocco and Ukraine. MFN duty rates for subheading 691010 must be verified in the current EU TARIC database. Preferential duty rates may be available under EU free trade agreements — including the EU-Turkey customs union, the EU-Vietnam EVFTA, the EU-Ukraine DCFTA and others — for goods meeting the applicable rules of origin with a valid proof of origin. Note: the EU applies anti-dumping duties on ceramic tableware and kitchenware from China (heading 6912); ceramic sanitary ware under heading 6910 has a separate tariff classification and a different trade measure status, which must be verified in TARIC for the specific code and country of origin before each import. Imports of ceramic sanitary ware subject to CPR requirements may be subject to documentary checks at customs, where authorities may request the DoP and supporting technical documentation. Common classification pitfalls include: washbasins made of stoneware or earthenware should be classified in subheading 691090, not 691010; ceramic bathroom accessories (soap dispensers, towel hooks) are classified outside heading 6910. All applicable duty rates and trade measures must be verified in the EU TARIC database.