Chapter 91 covers clocks and watches and their parts, including personal clocks and watches, other clocks and watches, time recorders, and instruments for measuring, recording or otherwise indicating intervals of time, and parts thereof. The core feature of this chapter is "timekeeping function"; goods must have the ability to measure, indicate or record time. Although vehicle-mounted time recorders are used for vehicles, their core function is to record time and driving status, so they are classified in this chapter. Heading 9106 covers time recorders and instruments for measuring, recording or otherwise indicating intervals of time, including time registers, production recorders, parking meters, race timers, etc. Vehicle-mounted time recorders are used to record vehicle driving time, speed, mileage, etc., and fall within the scope of time recorders, so they are classified under 9106. Code 910610 consists of 6 digits: the first 2 digits "91" represent Chapter 91 (clocks and watches and their parts), covering all timekeeping and time-recording devices; digits 3-4 "06" represent heading 9106 (time recorders and instruments for measuring, recording or otherwise indicating intervals of time), including time registers, parking meters, race timers, etc.; digits 5-6 "10" represent subheading 9106.10, specifically time recorders, i.e., devices used to record points in time or intervals of time. Vehicle-mounted time recorders, because they record vehicle operating time, speed and other data, meet the definition of this subheading. The core function of a vehicle-mounted time recorder is to record time and vehicle driving status, rather than simply displaying time (classified under 9105) or measuring speed (classified under 9029). The recorded time data is used to analyze vehicle usage and belongs to time recorders, so it is classified under 9106.10, rather than 8708 (vehicle parts) or 9029 (speedometers).
Chapter
Chapter 91 covers clocks and watches and their parts, including personal clocks and watches, other clocks and watches, time recorders, and instruments for measuring, recording or otherwise indicating intervals of time, and parts thereof. The core feature of this chapter is "timekeeping function"; goods must have the ability to measure, indicate or record time. Although vehicle-mounted time recorders are used for vehicles, their core function is to record time and driving status, so they are classified in this chapter.
Heading
Heading 9106 covers time recorders and instruments for measuring, recording or otherwise indicating intervals of time, including time registers, production recorders, parking meters, race timers, etc. Vehicle-mounted time recorders are used to record vehicle driving time, speed, mileage, etc., and fall within the scope of time recorders, so they are classified under 9106.
Digit Breakdown
Code 910610 consists of 6 digits: the first 2 digits "91" represent Chapter 91 (clocks and watches and their parts), covering all timekeeping and time-recording devices; digits 3-4 "06" represent heading 9106 (time recorders and instruments for measuring, recording or otherwise indicating intervals of time), including time registers, parking meters, race timers, etc.; digits 5-6 "10" represent subheading 9106.10, specifically time recorders, i.e., devices used to record points in time or intervals of time. Vehicle-mounted time recorders, because they record vehicle operating time, speed and other data, meet the definition of this subheading.
Classification Basis
The core function of a vehicle-mounted time recorder is to record time and vehicle driving status, rather than simply displaying time (classified under 9105) or measuring speed (classified under 9029). The recorded time data is used to analyze vehicle usage and belongs to time recorders, so it is classified under 9106.10, rather than 8708 (vehicle parts) or 9029 (speedometers).
📝 Declaration Elements
Product Name: The standard name of the declared commodity, which should accurately reflect the function of the commodity, such as "vehicle-mounted time recorder" or "vehicle driving recorder." Brand Type: Fill in the brand name and type (such as no brand, domestic brand, foreign brand), which must be consistent with the actual product. Model Specification: Fill in the specific model and specifications, such as recording parameters, storage capacity, interface type, etc. Recording Function: Explain the recorded parameters such as time, speed, mileage, etc., as well as the recording method (electronic/mechanical). Working Principle: Briefly describe how the time signal is obtained (such as GPS, vehicle pulse) and the recording medium (such as chip, printing paper). Whether Integrated with Vehicle: Explain whether it is original equipment or aftermarket equipment for the vehicle, and whether it needs to be connected to the vehicle circuit. Purpose: Clearly state whether it is used for vehicle driving time recording, fleet management, insurance assessment, etc. Product Name: Vehicle-mounted time recorder; Brand: XX; Model: T-100; Recording Function: Records driving time, speed, mileage, stored on SD card; Working Principle: Obtains data through GPS and vehicle pulse signals; Whether Integrated with Vehicle: Yes, needs to be connected to OBD interface; Purpose: Fleet management. Misreporting a "vehicle-mounted time recorder" as a "vehicle driving recorder," which may be classified under 8708. Ignoring the recording function and only emphasizing time display, leading to misclassification under 9105. Failing to provide specific recording parameters, making it impossible for customs to determine whether it is a time recorder.
Product Name
The standard name of the declared commodity, which should accurately reflect the function of the commodity, such as "vehicle-mounted time recorder" or "vehicle driving recorder."
⚠️ Misreporting as "car black box" or "GPS recorder," leading to classification disputes.
Brand Type
Fill in the brand name and type (such as no brand, domestic brand, foreign brand), which must be consistent with the actual product.
⚠️ Omitting the brand or filling it in incorrectly, affecting intellectual property verification.
Model Specification
Fill in the specific model and specifications, such as recording parameters, storage capacity, interface type, etc.
⚠️ Filling in only "universal type" without specific parameters, causing difficulties in inspection.
Recording Function
Explain the recorded parameters such as time, speed, mileage, etc., as well as the recording method (electronic/mechanical).
⚠️ Failing to specify the recorded content, misreporting as only displaying time.
Working Principle
Briefly describe how the time signal is obtained (such as GPS, vehicle pulse) and the recording medium (such as chip, printing paper).
⚠️ Confusing it with a timer, ignoring the recording function.
Whether Integrated with Vehicle
Explain whether it is original equipment or aftermarket equipment for the vehicle, and whether it needs to be connected to the vehicle circuit.
⚠️ Misreporting as an independent portable device, affecting classification.
Purpose
Clearly state whether it is used for vehicle driving time recording, fleet management, insurance assessment, etc.
⚠️ Filling in "for automobile use" is too general and does not reflect the core of time recording.
Example： Product Name: Vehicle-mounted time recorder; Brand: XX; Model: T-100; Recording Function: Records driving time, speed, mileage, stored on SD card; Working Principle: Obtains data through GPS and vehicle pulse signals; Whether Integrated with Vehicle: Yes, needs to be connected to OBD interface; Purpose: Fleet management.
Common Mistakes：
Misreporting a "vehicle-mounted time recorder" as a "vehicle driving recorder," which may be classified under 8708.
Ignoring the recording function and only emphasizing time display, leading to misclassification under 9105.
Failing to provide specific recording parameters, making it impossible for customs to determine whether it is a time recorder.
🎯 Classification Logic
The core basis for classification is the function, working principle and purpose of the commodity. The main function of a vehicle-mounted time recorder is to record time and vehicle operating data, which meets the definition of heading 9106 "time recorders." If the commodity only displays time without a recording function, it should be classified under 9105; if its main function is to measure speed, it should be classified under 9029. In addition, if it is a vehicle part and does not have an independent timekeeping function, it may be classified under 8708. 9105 Other clocks and watches: 9105 covers clocks and watches that only display time and have no recording function; while 9106.10 has a time recording function. 9029 Speedometers and tachometers: 9029 mainly measures speed or rotational speed; although it may include time recording, its core function is to measure speed. 8708 Parts of motor vehicles: 8708 covers general vehicle parts. If the recorder is dedicated to vehicles and does not have an independent timekeeping function, it may be classified here. 8543 Other electrical equipment: 8543 is a residual code. If the commodity does not have a time recording function, it may be misclassified here. Is the primary function of the commodity to record time? Does it have independent time recording and storage capabilities? Is it confused with the vehicle speed measurement function? Is it imported as original vehicle parts? Can it be classified under another more specific heading?
Basis
The core basis for classification is the function, working principle and purpose of the commodity. The main function of a vehicle-mounted time recorder is to record time and vehicle operating data, which meets the definition of heading 9106 "time recorders." If the commodity only displays time without a recording function, it should be classified under 9105; if its main function is to measure speed, it should be classified under 9029. In addition, if it is a vehicle part and does not have an independent timekeeping function, it may be classified under 8708.
Confused Codes：
9105 - Other clocks and watches
9105 covers clocks and watches that only display time and have no recording function; while 9106.10 has a time recording function.
9029 - Speedometers and tachometers
9029 mainly measures speed or rotational speed; although it may include time recording, its core function is to measure speed.
8708 - Parts of motor vehicles
8708 covers general vehicle parts. If the recorder is dedicated to vehicles and does not have an independent timekeeping function, it may be classified here.
8543 - Other electrical equipment
8543 is a residual code. If the commodity does not have a time recording function, it may be misclassified here.
Self-Check：
✓ Is the primary function of the commodity to record time?
✓ Does it have independent time recording and storage capabilities?
✓ Is it confused with the vehicle speed measurement function?
✓ Is it imported as original vehicle parts?
✓ Can it be classified under another more specific heading?
❓ FAQ
What is the difference between a vehicle-mounted time recorder and a driving recorder? A vehicle-mounted time recorder mainly records vehicle driving time, speed and other data for fleet management; a driving recorder mainly records video images and is usually classified under 8525. The two have different functions and different classifications. If a vehicle-mounted time recorder has a GPS function, will it affect classification? The GPS function only serves as a means of obtaining time signals and does not change its core function of time recording, so it is still classified under 9106.10. However, if GPS navigation is the main function, it may be classified under 8527. How can I check the import tariff rate for 910610? You can visit the website of the General Administration of Customs of China or use a customs classification inquiry tool, enter HS code 910610, and check the latest tariff rate. Tariff rates change, so it is recommended to rely on official publications. Do I need to provide the technical parameters of the recorder when declaring? Yes, you need to provide recording parameters, working principle, storage method, etc., so that customs can confirm the classification. Lack of parameters may lead to inspection or classification disputes. What certifications are required for exporting a vehicle-mounted time recorder to the EU? CE certification, E-mark certification, etc. may be required, depending on EU regulations. It is recommended to consult a professional agency to ensure compliance with local requirements. If the recorder is part of an original vehicle import, how should it be declared? If it is imported separately as a vehicle part, it is still declared under 910610; if it is imported with the complete vehicle, it is classified according to the complete vehicle and does not need to be declared separately. What is the difference between 910610 and 910690? 910610 is for time recorders, and 910690 is for other time recording instruments. If the recorder only records time, it is classified under 910610; if it also has other functions (such as measurement), it may be classified under 910690. For cross-border e-commerce sales of vehicle-mounted time recorders, how can the HS code be determined? Determine it based on the function and purpose of the commodity. If the core is time recording, use 910610. It is recommended to refer to customs classification decisions or consult a professional customs broker to ensure accuracy.
Q: What is the difference between a vehicle-mounted time recorder and a driving recorder?
A: A vehicle-mounted time recorder mainly records vehicle driving time, speed and other data for fleet management; a driving recorder mainly records video images and is usually classified under 8525. The two have different functions and different classifications.
Q: If a vehicle-mounted time recorder has a GPS function, will it affect classification?
A: The GPS function only serves as a means of obtaining time signals and does not change its core function of time recording, so it is still classified under 9106.10. However, if GPS navigation is the main function, it may be classified under 8527.
Q: How can I check the import tariff rate for 910610?
A: You can visit the website of the General Administration of Customs of China or use a customs classification inquiry tool, enter HS code 910610, and check the latest tariff rate. Tariff rates change, so it is recommended to rely on official publications.
Q: Do I need to provide the technical parameters of the recorder when declaring?
A: Yes, you need to provide recording parameters, working principle, storage method, etc., so that customs can confirm the classification. Lack of parameters may lead to inspection or classification disputes.
Q: What certifications are required for exporting a vehicle-mounted time recorder to the EU?
A: CE certification, E-mark certification, etc. may be required, depending on EU regulations. It is recommended to consult a professional agency to ensure compliance with local requirements.
Q: If the recorder is part of an original vehicle import, how should it be declared?
A: If it is imported separately as a vehicle part, it is still declared under 910610; if it is imported with the complete vehicle, it is classified according to the complete vehicle and does not need to be declared separately.
Q: What is the difference between 910610 and 910690?
A: 910610 is for time recorders, and 910690 is for other time recording instruments. If the recorder only records time, it is classified under 910610; if it also has other functions (such as measurement), it may be classified under 910690.
Q: For cross-border e-commerce sales of vehicle-mounted time recorders, how can the HS code be determined?
A: Determine it based on the function and purpose of the commodity. If the core is time recording, use 910610. It is recommended to refer to customs classification decisions or consult a professional customs broker to ensure accuracy.
⚠️ Disclaimer: HS code classification, declaration elements, tariff rates and regulatory conditions on this page are for reference only and do not constitute legal advice on customs classification. Tariff rates and regulations are subject to change; the latest announcements from the General Administration of Customs and on-site determinations shall prevail. Please consult professional customs brokers or customs authorities before import/export.