HS 90.19

Massage & health devices

Massage and health devices are the category DG works deepest, because it does not only trade them: it specifies, commissions the testing, imports and retails Medics Care and Sana Vivo under its own name. That means carrying the parts of the trade most traders hand off — the safety file in our own name, the two-man delivery up a stairwell, and the technician who opens the back panel eighteen months later.

A Medics Care massage chair lit in a dark studio
§ What we trade

What we trade in this category

  • Full-body SL and L-track chairs over a cubic metre boxed and heavy enough to need two people, so the container fills on volume and the last hundred metres — lift, stairwell, door width — decides whether the sale sticks
  • Zero-gravity 3D and 4D recliners the frame, actuator and control board are the product; a mid-production change of actuator or board supplier puts the shipped unit outside the construction the test report describes, and the market file with it
  • Compact and sofa-style chairs sold on footprint, so packed dimensions and door clearance matter more than the feature list, and the spec sheet has to carry both boxed and open measurements
  • Foot, calf and neck units air-freightable and high repeat, but each model still needs its own IEC 60335-2-32 test work, which is a hard cost against a low unit value
  • Percussion guns and portable devices lithium cells bring UN 38.3 test summaries, a safety data sheet and dangerous-goods handling; a missing test summary strands the pallet at origin, not at destination
  • Air-compression leg and arm devices the moment the claim moves from comfort to circulation the product leaves consumer rules and enters a medical device regime with a different file and a different lead time
  • Massage beds and physio couches largely mechanical and argued between the furniture and medical-furniture headings rather than the massage-apparatus one, but load rating, stability and pinch-point guarding all need documented test evidence
§ How we select

How a supplier and a product get chosen.

01

Start at the mechanism

Two chairs with the same shell can be entirely different products. We ask who makes the linear actuators, the air pump, the solenoid manifold and the control board, and whether those are the parts fitted in production or only in the sample. The shell is styling; the mechanism is the warranty.

02

Read the safety file first

Before the price list we ask for the CB Test Report to IEC 60335-1 and 60335-2-32 from a CB Testing Laboratory in the IECEE scheme, and we check that the model designation on the report is the model being quoted, not a sister model. A CB certificate with the national differences already tested is worth more than a folder of unrelated national certificates.

03

Take the sample apart

The golden sample gets stripped: hose routing where it crosses the backrest pivot, strain relief on the loom at the hinge, foam density, seam construction, roller bearing quality, noise at full stroke. What fails in year two is visible in the teardown in week one.

04

Price the after-sale

A chair is not returned to base, so the service economics are part of the purchase. We agree the spare-parts kit as a share of the order, the parts availability window, the exploded diagram, the service manual and who holds the firmware before the FOB price is settled.

05

Test the packaging

Much of what arrives damaged in this category was damaged in transit or under a clamp truck, not on the line. We run drop and compression testing on the loaded carton, check the corner and edge protection, and fix the two-carton split so the heavy piece is the one that stays on the pallet.

§ Development

Development and design.

Design

Specification and mechanism

We write the bill of materials rather than picking from a catalogue: track geometry and stroke, roller count and profile, airbag map and pressure, actuator travel, heat zones, seat and backrest angles. It is locked with a signed golden sample and a photographed parts list, so a substituted board or pump is a breach and not a discussion.

Design

Upholstery for the destination climate

Synthetic leather is where these products age badly. We specify grade, backing and abrasion and colourfastness testing against the market: coastal Portugal, the Balkans in summer, the Gulf and southern China all punish a low-grade polyurethane skin, and delamination shows up as a warranty claim long after the container has been paid for.

Design

Interface, firmware and localisation

Menu text, voice prompts, hand-controller legends and the printed manual are set per market and per language, and programme names are written to stay inside comfort language rather than drifting into therapeutic claims. Where a device pairs to a phone, the radio module brings its own conformity work and the app brings data obligations.

Design

Packaging, artwork and the label set

Carton construction, internal foam, the two-carton split, the rating plate, the mark set, the responsible economic operator on the box, the recycling and battery symbols, the Arabic or Chinese label copy and the barcode all get built as one artwork pack per market. Getting the label set wrong is the cheapest way to hold a container.

§ Our part

What we do that a broker does not.

A

We hold the file, not a copy of it

As brand owner we commission the testing, hold the reports, and issue the declaration of conformity in our own name. When a customs officer or a marketplace asks for the technical documentation behind a model, it exists, it is current, and it names the model on the rating plate.

B

A named importer in each corridor

Sana Vivo Brands, Lda in Porto is an EU-established economic operator. DG Brands Europe doo in Belgrade and Novi Sad carries Serbian import, the Serbian-language declaration and the 3A conformity mark. DG Brands Limited handles Hong Kong and the Asian corridor. Buyers deal with an entity inside their own regime, not an offshore invoice.

C

Parts stock, not a parts promise

We hold control boards, hand controllers, actuators, pumps and airbag sets in the markets where we run the after-sales, because a faulty chair is repaired in a living room. Distributors get the exploded diagram, the service manual and a technician briefing rather than a returns address.

D

Inspection tied to the money

We book the pre-shipment inspection ourselves, to an agreed sampling plan, with function cycling, dielectric strength, earth continuity on Class I units, and a carton drop on the same visit. The balance payment sits behind the report, so the factory's incentive and ours point the same way.

E

We sell it ourselves

We run the retail and after-sales for these brands in our own markets, so returns reasons, complaint patterns and field failures come back into the next specification. Product change is driven by the service log rather than by a supplier's new catalogue.

§ Documents

What the paperwork actually is.

The document set below is what this category needs to clear. We raise it rather than forwarding a checklist.

  • EU electrical and consumer regime: Low Voltage Directive 2014/35/EU and EMC Directive 2014/30/EU, tested to EN 60335-1 with EN 60335-2-32 for massage appliances and EN 62233 for electromagnetic field exposure; RoHS 2011/65/EU, WEEE 2012/19/EU, and Regulation (EU) 2023/1542 with its end-user removability rule for any device that carries cells; Radio Equipment Directive 2014/53/EU where the unit pairs by Bluetooth, which then carries the safety and EMC requirements for that model instead of the two directives above, not alongside them; an EU declaration of conformity, a technical file, and a responsible economic operator established in the Union under Article 4 of Regulation (EU) 2019/1020, with the General Product Safety Regulation (EU) 2023/988 reaching the risks the harmonised directives do not.
  • Medical-purpose devices are a separate regime, not a stronger version of the same one: Regulation (EU) 2017/745 in the EU with classification, technical documentation, UDI and an authorised representative; registration with ALIMS in Serbia, the Health Sciences Authority and a dealer's licence in Singapore, NMPA in mainland China, the SFDA in Saudi Arabia, and the Department of Health's voluntary listing scheme in Hong Kong. We decide which side of that line a product sits on before tooling.
  • Serbia: rulebooks transposing the low-voltage and electromagnetic compatibility regimes, a declaration of conformity issued in Serbian, the Serbian 3A conformity mark, and an importer established in Serbia. CE test evidence is accepted as the technical basis, but a CE mark alone does not place goods on the Serbian market.
  • Hong Kong and Singapore: household electrical products in Hong Kong need a certificate of safety compliance under the Electrical Products (Safety) Regulation, a BS 1363 fused plug and bilingual Chinese and English warnings, with the Consumer Goods Safety Ordinance covering the non-electrical goods its schedule leaves in scope. In Singapore, where a model falls within the controlled goods list, it needs a Registered Supplier established locally, registration and the SAFETY Mark before it can be offered for sale.
  • Gulf: Saudi Arabia works through SABER, where a product certificate of conformity is issued per model and a shipment certificate of conformity is issued per consignment — the shipment certificate is what actually releases the container. The Gulf conformity mark under the GCC low-voltage technical regulation and UAE conformity registration apply alongside it, and Arabic labelling and an Arabic manual are part of the requirement, not a courtesy.
  • Trade and transport documents: classification under subheading 9019.10 of heading 90.19 as mechano-therapy and massage apparatus, or heading 94.01 as a seat, settled in advance by binding tariff information or a written ruling; commercial invoice, packing list with carton volumes, certificate of origin, and preferential origin evidence only where it is genuinely earned; UN 38.3 test summary, safety data sheet and a dangerous goods declaration for any lithium-cell device; transit test reports for the loaded carton.
§ Corridors

How it moves.

Chairs and mechanisms are built in Greater China and move by sea into Koper, Rijeka and Piraeus for Central Europe and the Balkans and into Leixões for Portugal and Iberia, with Serbia trucked inland and cleared outside the EU customs union — the same chair, two different document sets, prepared before the vessel sails. Eastbound and intra-Asian volumes run into Hong Kong and Singapore, with small devices moving by air when the lithium paperwork is clean, and Gulf shipments route to Jebel Ali and Jeddah, where the per-shipment certificate rather than the product certificate is what holds or releases the box.

See the lanes we run

§ Questions

What buyers ask first.

Is a massage chair a massage apparatus or a chair for customs purposes?

Both classifications are used in practice. Subheading 9019.10 covers mechano-therapy appliances and massage apparatus, while heading 94.01 covers seats, and customs authorities have classified massage chairs as seats where the article remains comfortable and usable as ordinary seating and the massage function reads as complementary. The choice moves duty, and in some markets it moves the tax and registration treatment as well, so we get it decided in writing in advance rather than argued at the border.

Can we private-label this and use your CE file?

No, and you should be suspicious of anyone who says yes. CE is a manufacturer's declaration, not a certificate someone lends you; the obligation follows the name on the rating plate and the packaging. If you sell our brand, we hold the file and the responsible economic operator is ours. If you want your own label, we can commission testing and build the technical file in your name — that is a project with a cost and a timeline, not a document transfer.

What actually fails on these products?

Solenoid valves and air pumps, hoses chafing where they cross the backrest pivot, hand-controller cables, control boards after mains disturbance, and upholstery delaminating in hot or humid markets. Almost none of it can be shipped back to the factory economically, which is why the spare-parts kit, the exploded diagram and the parts availability window are negotiated alongside the unit price rather than after the first claim.

Do you sell these with health claims?

We do not. Consumer massage chairs and personal devices are sold as consumer products, described in terms of what they do mechanically — track, stroke, airbags, heat, positions — not what they treat. A device that claims a medical purpose moves into a medical device regime with its own file, its own registration and a materially longer route to market, and that decision is taken at specification stage because it changes the design, the labelling and the price.

§ Other sectors

Moving massage & health devices?

Tell us the product, the origin and the destination. We come back with the classification, the document set and a realistic timeline.

Open a file with us
§ Two minutes

Not ready to write a brief?

Leave three lines and we will come back with the corridor, the customs position and a realistic timeline for whatever you are moving.

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