Importing Korean Aluminum Windows into the EU: Why Zero Tariff Is Not the Gate

If you are sourcing Korean aluminum windows for the EU, the tariff is not the obstacle: under the Korea-EU Free Trade Agreement (FTA) most consignments are already duty-free. The real gate is proof that each window has met Europe's safety and performance standards, CE marking. And that proof needs to exist before production ships, not after the deal is signed, or clearance stalls.

Start with the tariff: mostly 0% under the Korea-EU FTA

Aluminum windows classify under HS 7610.10 (doors, windows and their frames and thresholds for doors, of aluminium). Europe's base tariff runs at roughly 6%, but Korean-origin goods pay none of it under the Korea-EU FTA, in force since 2011. The question is not the rate but how Korean origin gets proven.

The origin test itself is simple. A window (7610) qualifies if it is made from materials of a different 4-digit heading than the finished product; there is no value-ratio calculation to run. That is a different outcome from auto parts (HS 8708), which can qualify either by change of heading or by keeping non-originating materials at 50% or less, so do not carry that rule over here.

The origin declaration mechanism itself matches auto parts exports. The Korea-EU FTA uses an origin declaration the exporter writes onto a commercial document like the invoice, rather than a certificate issued by an authority, and above EUR 6,000 per consignment only an exporter holding an approved-exporter number from customs may declare. A single container of windows usually exceeds that threshold, so securing approved-exporter status in advance is effectively mandatory. The mechanics of origin declarations and approved-exporter status are set out in certificates of origin and using an FTA. The principle for deciding exactly which code a window falls under is in what an HS code is.

The real gate: CE marking under the Construction Products Regulation

A low tariff means the contest is decided elsewhere. Europe governs the performance of construction products through the Construction Products Regulation ((EU) No 305/2011, the CPR). For a product covered by a harmonised standard, the CPR requires two things. One is a Declaration of Performance (DoP), a document stating which harmonised standard and which performance level the product meets. The other is CE marking, which may only be affixed once a DoP exists. The harmonised standard for windows is EN 14351-1, covering windows and external pedestrian doorsets.

CE marking must carry the year first affixed, the manufacturer's name, a product-type identification code, the DoP reference number, the declared performance level, the harmonised-standard reference, and, where applicable, a notified body number. The DoP itself follows a fixed annex format, ending in the statement that it "is issued under the sole responsibility of the manufacturer." That is, drawing up this document is the manufacturer's job, meaning the Korean window maker's own job.

Every window needs notified-body testing

Windows under EN 14351-1 are generally classified under Assessment and Verification of Constancy of Performance (AVCP) System 3. Under this system, Initial Type Testing is carried out not by the manufacturer but by a notified body, a test house designated by an EU member state, while the manufacturer only handles factory production control once production is running. A common assumption holds that a notified body is needed only when fire-related performance is declared; it is safer to assume CE marking for windows does not start at all without a notified body's test report. Routine characteristics such as air permeability, watertightness, wind load resistance and thermal transmittance are also subject to this Initial Type Test.

Here is a point Korean manufacturers often miss. KS F 3117 ("Window Set"), the domestic Korean standard familiar at home, sets grades for air-tightness, water-tightness, wind-pressure resistance, sound insulation and thermal insulation, but it is a separate standard from EN 14351-1. The test methods and grading systems differ, so a KS certificate or a domestic test report cannot substitute for the basis of an EU-bound DoP. A window certified under KS still needs its own EN 14351-1 Initial Type Test through a notified body before it can carry CE marking for the EU.

Windows and curtain walling are different standards

A manufacturer producing both windows and curtain walling often assumes one certification covers both; in fact the harmonised standards differ. EN 14351-1 covers only windows and external pedestrian doorsets; curtain walling falls under a separate harmonised standard, EN 13830. Both sit within the same CPR framework, but the test characteristics and performance metrics differ, so certifying a window line does not certify a curtain-wall line. Ship both, and you need a separate DoP for each, matched to its own harmonised standard.

Without an EU entity, who is actually liable?

This is where most confusion sits. The CPR does not require a manufacturer to appoint a representative inside the EU. Appointing one is a permissive provision, "the manufacturer may appoint" one, not a mandate, so a Korean manufacturer with no EU entity or representative still carries the DoP and CE-marking responsibility itself, by default.

So what does the EU importer actually do? The importer's duty is not to draw up the paperwork in the manufacturer's place, but to verify it. Before placing the product on the market, the importer must check that the manufacturer has already carried out the assessment procedure, holds the technical documentation and DoP, and has affixed CE marking correctly, and must withhold the product if there is reason to doubt it. Skip that check and distribute anyway, and liability for what follows lands on the importer. The one exception: if an importer or distributor puts the window on the market under its own name or trademark, or modifies it in a way that could affect the declared performance, it is treated as the manufacturer from that point and inherits the DoP and CE-marking obligations outright. What a Korean manufacturer needs to prepare, then, is not an EU representative, but a DoP and test report complete enough that an EU buyer's verification check has nothing to catch.

The 2026 CPR overhaul changes nothing immediately

The CPR is being repealed from 8 January 2026 by a new regulation adopted at the end of 2024 ((EU) 2024/3110). Under its savings clause, though, the articles governing the DoP, CE marking, and manufacturer and importer obligations, along with their annexes, remain in force until 8 January 2040 for products covered by harmonised standards already referenced in the Official Journal. EN 14351-1 falls within that savings clause, so the procedure and liability structure described above does not change simply because the regulation has been recast. A separate implementing measure could still migrate the window product family to the new regime sooner, so check the current listing again close to your actual shipping date.

What to watch in shipping and packing

Aluminum windows often ship with glazing already fitted into the frame, which raises breakage risk. Glass units are stood and secured in dedicated crates or A-frame stands, with cushioning between frames so they never touch directly. Aluminum surfaces can suffer galvanic corrosion on contact with a dissimilar metal, so packing should keep them apart. Because windows are light for their volume, ocean freight on this cargo is often priced by volume rather than weight, worth factoring into the load plan early.

Four things to check before sourcing Korean aluminum windows

1. CE marking and the DoP: confirm whether EN 14351-1 (windows/doors) or EN 13830 (curtain walling) applies, and require an Initial Type Test through a notified body and a DoP issued in the manufacturer's name.
2. KS certification is not EU certification: domestic Korean certifications like KS F 3117 cannot substitute for the EU-bound DoP; plan for separate testing.
3. Korea-EU FTA origin: confirm the exporter holds an approved-exporter number (mandatory above EUR 6,000) and meets the change-of-heading origin criterion.
4. Division of responsibility: know that the DoP and CE marking stay the manufacturer's responsibility, and request the documents (DoP, test report, technical file) your own verification duty requires before the goods ship.

Sourcing Korean aluminum windows is not a contest over tariffs. Under the Korea-EU FTA the duty is already near zero, and the contest is decided in CE marking under the harmonised standard, specifically the notified body's test report and the Declaration of Performance the manufacturer issues. Know that liability does not shift to you simply because the manufacturer has no EU entity, prepare your verification accordingly, and in a duty-free market you hold the real leverage: the certification.

This guide is general information as of August 2026. The status of harmonised standards, EU base tariff rates, Korea-EU FTA origin rules, and the scope of the CPR's savings clause change with the rules, so confirm with a notified body, a customs specialist and your forwarder before you actually ship.