I. Macroeconomic Environment and Trade Risk Analysis

Displays (e.g., HS 8528) and optical devices (e.g., HS 9013) are increasingly subject to non-tariff and technical regulations rather than traditional tariffs . Issues regarding tariff application based on EU environmental regulations (RoHS/REACH) and product classification and interpretation have recurred (e.g., past LCD monitor classification and tariff disputes), and the interpretation of the scope of application of the Information Technology Agreement (ITA) directly impacts competitiveness. ( World Trade Organization)

Risk factors2025-26 OutlookInfluence (1~5)Implications
ITA scope and classification issuesClassification debate persists due to changes in product specifications.4Preventing dispute risks by clarifying HS codes, origin, and function. World Trade Organization
EU environmental regulations (RoHS/REACH)Continuous application and renewal4Continuous improvement of hazardous substances, SCIP, and documentation systems is necessary. European Commission+1
CBAMCurrent direct hits are limited (focused on basic materials)2Monitoring indirect expansion potential and preparing electricity/process carbon data. Taxation and Customs Union
Exchange rate/logisticsgentle fluctuations2Optimization of FOB/CIF adjustment and insurance package
Ⅱ. FTA Utilization Rate and Corporate Practice Statistics

Display finished products (8528) and optical components/devices (9013) often secure tariff benefits (usually 0% or low rates) through ITA or FTA routes in major markets (the US and EU). However, proving product classification and function (e.g., output device for ADP vs. standalone monitor) , managing certificates of origin (PSR) , and submitting environmental certification data (RoHS/REACH) are frequently cited as practical bottlenecks. Given the past classification dispute in the EU, where a 14% tariff was applied to some LCD monitors, consistency of documentation and specifications is crucial. World Trade Organization

divisionExpected FTA/ITA applicabilityOn-site difficulties (major)Management Points
8528 Monitor/ProjectorIn the US and EU, generally low rates and no tariffs through ITA/FTA routesVerification of functional classification, such as ADP/TV reception functionFunctional and interface specifications and test reports are available. World Trade Organization
9013 Liquid crystal devices and other optical devicesIncreased demand for detailed regulations and documentationDetermination of 'components vs. finished products' and whether electronic devices are includedHS 9013 Detailed Tariff Schedule and Manual Consistency Management. Chungbuk Global Marketing System
Country of Origin/PSRPotential for utilizing regional accumulation (Korea-EU, etc.)Uncertainty over PSR due to component diversificationRVC/CTH Parallel Scenario·Supply Chain BOM Tracking
environmental regulationsRoHS/REACH compliance at all timesMaintaining the up-to-dateness of data and test reportsPreparation of the SCIP Reporting and Substitutes Roadmap. European Commission
III. Matrix of Comparison of Tariffs and Non-Tariffs by Country

The US and EU often have 0% effective tariffs on many display and optical device products due to the application of ITA and FTAs. However, this can vary on a case-by-case basis depending on product classification and functional connectivity (a 14% tariff was previously imposed on EU LCD monitors). China and other emerging markets may still have significant tariffs on products subject to MFNs . Due to frequent policy and interpretation changes, actual HTS/TARIC data is required. World Trade Organization

marketRepresentative HS (example)MFN tariff (scope)When FTA/ITA is appliedNon-tariff barriers (example)Comments
USA8528, 9013Varies by item (previous low rates/no tariffs)0% frequency through ITA/FTA routeProduct Safety/Labeling/Export ControlWe recommend checking the Harmonized Tariff Schedule for each household at all times.
EU8528, 9013Some past cases of 14% applicationCurrently, there are 0% cases for many items.RoHS/REACH·Labeling·Eco-designMust check the latest TARIC data. World Trade Organization+1
china8528, 9013Report of the presence of items in the 5-8% rangeVaries according to concession/agreementCCC·Standard·Domestic Substitution KeynoteSimultaneous management of price, delivery, and certification is required.
ASEAN (Vietnam)8528, 9013~5% reportedReduced through RCEP/bilateral FTACertification, quarantine, and administrative proceduresIntra-regional cumulative logic is valid.

Note: The table above is significantly affected by policy and classification changes, so we recommend checking the HTS/TARIC real-time data before importing or exporting . EU documents and WTO dispute data show the volatility of past classification and tariff application. World Trade Organization

Ⅳ. ESG·CBAM Impact

CBAM currently focuses on basic materials such as steel and aluminum, with limited direct coverage for displays and optical devices . However, the CBAM linkage to power, indirect process emissions, packaging, and accessory materials can be gradually expanded, ensuring safe management of power mix and emissions data . RoHS/REACH regulations are continually being updated, making data and alternative material strategies essential. Taxation and Customs Union

V. Investment and Supply Chain Transition Scenario

Localization in the EU and US : Meeting energy and environmental requirements + ensuring proximity to customers.

ASEAN Processing and Packaging : Cost and Lead Time Optimization + Regional Comprehensive Economic Partnership (RCEP).

Korea R&D Hub : Focusing on design capabilities for high-value-added optical components and modules (facilitating FTA country of origin management).

Ⅵ. AI-based 3-month export and import forecasts

AutoLoop combines publicly available statistics with news and policy sentiment (α), global sentiment (β), and sector sentiment (λ) to produce a short-term 3-month forecast (Forecast_3M). Display and optical devices are highly sensitive to regulatory and classification news, so their ΔSignal volatility tends to be greater than that of other electronic products.

variable

Δ(%) or exponent

analysis

ΔExport_now+1.6Retail demand in the EU and Americas is slowly recovering.
ΔImport_now+1.1Increase in imports of parts and modules (new product cycle)
ΔPrice_now+0.2Slight increase in average unit price (high resolution conversion)
ΔSignal_now+0.024Positive signal (policy, demand, and exchange rate neutrality+)
ΔFTAEffect+0.27ITA/FTA cumulative effect (offsetting classification risk)
Forecast_3M+0.40A gradual improvement is expected over the next three months.

Formula (summary): Forecast_3M = 0.5·ΔSignal + 0.3·ΔFTAEffect + 0.2·ΔPrice

VII. Policy Recommendations and System Improvement Roadmap

field

Suggestion

Executor

Expected effect

Product Classification Guide8528/9013 Detailed Judgment Guide and Expansion of Preliminary ExaminationKorea Customs Service and Ministry of Trade, Industry and EnergyReduce the risk of disputes and collections
Simplified country of originMultinational Sourcing BOM Standard + Expanded Autonomous IssuanceKorea Customs ServiceIncreasing PSR compliance and utilization rates
Responding to environmental regulationsRoHS/REACH Data Lake + SCIP AutomationCompanies and AssociationsReduced certification costs and stable delivery times
international cooperationDiscussion on the expansion of ITA product categories and consistency of interpretationTrade authoritiesAlleviating uncertainty and attracting investment
Ⅷ. Summary of Conclusions

Competitiveness hinges on classification and environmental regulations, rather than tariffs themselves . Maximizing ITA/FTA benefits hinges on documentation, functional verification, and environmental data . World Trade Organization

3-Month Outlook (+0.40) : Signals of gradual improvement. News sentiment on classification and environmental issues is a factor in short-term volatility.

Recommended Strategies: ① Zero classification risk, ② Optimize origin and accumulation, ③ Constantly update RoHS/REACH data, ④ Real-time HTS/TARIC monitoring , and Harmonized Tariff Schedule .