2652

Authorization procedure and Trade Register aspects for CAEN 2652

Companies opting for CAEN code 2652 – Watch production – must go through the standard registration stages at the Trade Register (ONRC), with special attention to secondary activity objects and technical documentation. It is recommended to include the activity as a main or secondary object, without requiring prior approval from the Ministry of Economy, except when producing materials subject to special regimes (precious metals). For the production of wristwatches or wall clocks, no additional licenses are required upon incorporation, but a sworn declaration under Law 359/2004 on compliance with applicable technical regulations must be submitted. When drafting the articles of incorporation, the full 4-digit CAEN codes must be mentioned. If electronic components are also assembled, CAEN 2611 (manufacture of electronic components) may be added, noting that it does not overlap with the ANCOM authorization regime unless communication devices are produced.

Regulatory framework, specific approvals, and control institutions

Watch production does not require a special operating authorization, but compliance with ISO 9001 or ISO 14001 standards may be imposed by business partners. If precious metals (gold, silver for cases) are used, the provisions of Law 54/1994 on precious metals and precious stones become applicable, and the company must obtain approval from the National Bank of Romania or the National Commission for Precious Metals. Also, watches with time-measuring functions for medical use (chronometers) fall under the regulations of the National Agency for Medicines and Medical Devices (ANMCS). Control institutions include: the Tax Authority (ANAF) (for VAT and corporate income tax), the Ministry of Economy (for possible dual-use technology exports), and the State Inspectorate for Boilers, Pressure Vessels and Lifting Installations (ISCIR) (if watches with pressure components are produced, a rare case).

Fiscal management, ANAF audit risk, and specific accounting

From a fiscal perspective, companies with CAEN 2652 are subject to the general rules of the Fiscal Code. Upon incorporation, the fiscal vector is completed at the Tax Authority (ANAF), noting that corporate income tax is due quarterly or annually, depending on turnover. Excise duty is applicable only if watches containing alcohol are produced (pocket watches with thermometers and alcohol reservoirs – an atypical situation). VAT applies at the standard rate (19%). The ANAF audit risk is medium, particularly regarding the import of movement mechanisms from Switzerland or China – ANAF may verify the correctness of the customs value and the application of the VAT regime on imports. Accounting must reflect production costs separately (materials, labor, depreciation), and the FIFO method is recommended for inventories. Companies delivering to EU clients must register in the RO e-Factura system and submit recapitulative declarations (D390).