2612
Manufacture of electronic subassemblies (modules)
This code covers the manufacture of electronic subassemblies, such as printed circuit boards (PCBs) assembled with electronic components, hybrid modules and other custom electronic assemblies. Activities include component soldering, functional testing and integration into finished products. It is ideal for companies producing electronic components for the automotive industry, medical equipment or consumer electronics.
Entrepreneur Profile
Acest cod este potrivit pentru SRL-uri sau PFA-uri care produc subansambluri electronice la comandă pentru OEM-uri, firme de service electronic, sau pentru producători de echipamente industriale. De asemenea, este util pentru ateliere de asamblare electronică care oferă servicii de lipire SMT sau THT.
Who should avoid:
Avoid the exclusive use of code 2612 if the main activity of your company shifts towards other commercial or related branches not specified in the official description. See the excluded activities section below.
Authorization procedure and Trade Register aspects for NACE 2612
Companies opting to carry out the activity of manufacturing electronic subassemblies (modules) (NACE 2612) must go through the registration stage with the Trade Register (ONRC), submitting the standard application and constituent documents. When establishing the main activity object, NACE code 2612 must be clearly specified, and for secondary objects, related codes will be chosen (e.g. 2611, 2620, 2790). According to the provisions of Law 359/2004, it is not necessary to submit a declaration on own responsibility regarding prior authorizations for NACE 2612, as the activity is not subject to special authorization at establishment. However, it is mandatory to correctly classify the activity objects in the NACE Rev. 4 classification and explicitly specify the technological processes involved in the manufacture of electronic modules (e.g., card assembly, PCB manufacturing with components).
Regulatory framework, specific endorsements and control institutions
The activity NACE 2612 involves compliance with technical rules on electrical and electronic equipment (RoHS Directive, WEEE Directive), implemented by Government Decisions HG 448/2005 and HG 992/2011. Electronic subassembly manufacturing units must obtain an endorsement from the National Authority for Consumer Protection (ANPC) for product conformity with standards SR EN 50581 and SR EN 62368-1. Also, an environmental authorization from the Environmental Protection Agency (APM) is mandatory under Law 128/2022 on industrial emissions and electronic waste management. Control institutions include the National Environmental Guard (GNM) for checking hazardous waste management (solder, solvents, lead) and the Territorial Labour Inspectorate (ITM) for safety of production processes (SMT equipment, furnaces).
Tax management, ANAF audit risk and specific accounting
From a tax perspective, the manufacture of electronic subassemblies (NACE 2612) is taxed according to the Fiscal Code (Law 227/2015) and involves VAT obligations (standard rate 19% for domestic sales, except for exempt intra-Community supplies). It is essential to correctly record operations in the RO e-Factura system and declare purchases of electronic components (chips, resistors) through form D390. A major risk of ANAF audit arises in justifying production costs and profit margins, especially if transfer pricing is used for transactions with related parties (e.g., import of raw materials from China). It is recommended to keep separate records of material inventories (cables, semiconductors) and work-in-progress using account 331. Corporate income tax is calculated monthly or quarterly, and for taxpayers opting for micro-enterprise income tax, the rate of 1% applies (if legal thresholds are not exceeded). As the activity generates electronic waste, it is mandatory to keep records and annually declare waste quantities through ANAF form 100 and pay the environmental tax under Government Emergency Ordinance OUG 5/2014.
Included Activities
- ✅ Manufacture of printed circuit boards (PCBs) assembled with electronic components
- ✅ Manufacture of hybrid electronic modules
- ✅ Assembly of electronic components on substrates
- ✅ Testing and functional verification of electronic subassemblies
- ✅ Manufacture of custom electronic assemblies for customers
Excluded Activities
- ❌ Manufacture of discrete electronic components (transistors, diodes, etc.) - code 2611
- ❌ Manufacture of unassembled printed circuit boards - code 2611
- ❌ Manufacture of finished electronic equipment (computers, telephones) - codes 2620, 2630, 2640
- ❌ Software design activities - code 6201
Similar or Related CAEN Codes:
From the same category of economic activities:
Întrebări Frecvente
What authorizations are needed for manufacturing electronic subassemblies?
No special environmental or operating authorizations are required, but fire safety and electronic waste (WEEE) management rules must be observed. If hazardous substances (e.g., soldering fluxes) are used, an environmental authorization under OUG 195/2005 may be necessary.
Can I export electronic subassemblies manufactured under this NACE code?
Yes, but you must comply with customs regulations and, for certain products (e.g., those with encryption), an export license may be required. Also ensure that products comply with EU standards (CE marking) and the RoHS and WEEE directives.