3319

Authorization procedure and Trade Register aspects for CAEN 3319

For registering the activity 'Repair and maintenance of other equipment' (CAEN code 3319) with the National Trade Register Office (ONRC), it is mandatory to expressly specify this code in the secondary object of activity, if not primary, and to submit a sworn statement according to Law 359/2004. This attests to the fulfillment of operating conditions, without the need for prior authorizations issued by ONRC. When completing the application, CAEN code 3319 will be indicated without requiring a sectoral opinion from the Trade Register, but it is recommended to consult specific legislation regarding the regime of products and equipment subject to repair (e.g., medical devices, scales, measuring equipment). The activity covers the repair and maintenance of mechanical, electrical, optical, radar, navigation, industrial control equipment, pumps, compressors, turbines, and others not classified under other CAEN codes. It does not include repair of ships (3315), aircraft (3316), motor vehicles (4520), or motorcycles (4540).

Regulatory framework, specific approvals, and control institutions

Economic operators carrying out repair activities under CAEN 3319 must comply with the rules on occupational safety and health (Law 319/2006), environmental protection (G.O. 195/2005), and waste management, including WEEE (Gov. Decision 1037/2010). If intervening on pressure equipment or measuring apparatus, metrological regulations (Law 152/2009) apply, and accreditation as an authorized person for metrological verifications is required. For equipment with major risks (e.g., electrical installations, lifting apparatus), authorizations from ISCIR or ANRE are required. Activities involving the repair of medical devices fall under the scope of Ministry of Health Order 1010/2008, requiring registration with the National Medicines Agency (ANM) and authorization as a service unit. Control institutions include: ITM (labor conditions control), Environmental Guard (waste), ANPC (consumer protection), and the authorities issuing specific approvals. It is recommended to consult an industrial compliance expert to identify all applicable regulatory obligations.

Tax management, risk of ANAF audit, and specific accounting

From a fiscal perspective, revenues from repairs are generally classified as service provisions (standard VAT rate 19%), and VAT registration is made according to the Fiscal Code (Law 227/2015). Repair operations on movable goods may be qualified as intra-Community service provisions or exports, depending on the place of performance, according to art. 278 of the Fiscal Code. Issuance of fiscal invoices and reporting in the RO e-Factura system is mandatory for B2B relations. In accounting, expenses for spare parts and materials are recorded in inventory accounts (301, 302), while revenues are recorded in service provision revenue accounts (704). For long-term repair works, IAS 11 regarding construction contracts applies (recognition based on the stage of completion). ANAF may initiate tax audits concerning the deductibility of spare parts expenses, documentation of inventories, and compliance with transfer pricing for transactions with related parties. The audit risk is high in case of non-declaration of revenues from services performed outside the premises or incorrect application of VAT rate (e.g., applying reduced rate for bicycle repairs, if applicable, but not for CAEN 3319). It is recommended to prepare a framework service contract and a work acceptance report as supporting documents for ANAF. Also, the implications regarding the tax on micro-enterprise income or profit tax are established depending on the form of organization and legal thresholds.