Customs classification can be challenging. Try your luck with our guided classification challenge and compare your results with the official solution
Every once in a while, the EU issues customs classification decisions. Just like on this product. We have based our analysis on the analysis of the EU. So, when we present you with the solution, you know that we are totally aligned with the EU decision-makers and EU Customs authorities.
This is why they are helpful for the trade community in creating a best practice classification argumentation and checking if you had reached the same commodity code.
This is why we run these classification quizzes and talk our members through difficult cases.
Together we can crack customs classification.
OK, so you are ready to try your skills as a customs classifier of this shower-bath in the form of a flat tray?
Great, before we start, let's remind ourselves of some top tips.
Solid customs classification advice. Thank you! – Jane Williams, Customs Manager Ltd, Logistics company
Customs classification is a journey of discovery. Start with answering these fundamental questions:
What is the product that I am looking at?
What are the necessary characteristics that I need to know about?
What is the product used for?
What is the commercial description vs. what it actually is?
What about some technical features, length, thickness etc?
We, as customs consultants EU and UK, have found in our years of classification experience that starting with the right description of the product has really helped with the classification of the product.
Step 1: Nail the Description
So we know that the EU has classified a shower-bath. What are the characteristics?
It has the form of a flat tray, made out of a mixture of minerals and plastics and a white outer plastic coating.
The product is by weight composed of the following:
65 % calcium carbonate;
28 % polyester resin;
5 % silicon dioxide;
2 % polyester ‘gel-coat’ (outer surface).
The mineral components (calcium carbonate and silicon dioxide) are made out of marble chips, quartz or finely crushed granite.
The production process involves first mixing the mineral component with plastic material (polyester resin).
That mixture is then poured into a mould, which is lined with the polyester ‘gel-coat’, and the polyester resin is finally cured.
Step 2: Build your argument, grounded in law
Time to make our case
Start with a section. Which one does this product fall into?
Look at the GIR/GRIs and think about which ones could apply in this case? 1 & 6 is a given, but what about 3?
Get your support tools ready. Have you got the Section & Chapter notes handy? Have you got access to the national explanatory notes of your country? What about the WCO classification explanatory notes? What about BTI? Case Law?
Next, consider GIR 1 and find possible competing headings and try to unravel them with careful consideration of the section and heading notes. Use all the tools, including exclusions and exceptions, to support your case.
Consider any other GIR rule you think is appropriate here
Look at specific rules of your national tariff, like additional notes and subheading rules for numberings past 6 digits.
Draft and fine-tune your justification and conclude by determining the article.
How should a justification look, sound and feel
There is no fixed rule, but it should clearly answer the question: Why is this code correct and give reasons backed up by the rules of classification. The geekier the better.
Here is an example:
Classification is determined by general rules X and X for the interpretation of the Harmonised System of Classification as published by the WCO, version of year 20XX, and (insert name of national tariff).
We considered the following Notes and wordings of HS/commodity codes:
note XX and xx to Section XX
Wording of HS codes XXXX, XXXX
National Tariff commodity codes: XXXX XXXX
The articles are produced in/by .... (see note XX to Section XX).
Taking into account their xxx character the articles are to be considered as xxx. In addition, note xxx to Section xxx classifies Product A like Product B in that section.
Classification under heading XXXX is excluded, because (see also the Harmonized System Explanatory Note to heading XXXX (X) and the Explanatory note to the National Tariff XXXX ).
Consequently, the articles are to be classified under National Code XXXX XX XXas a xxx
Now it is up to you :-)
Can you try to find the 6-digit code for the WCO and the eight-digit code for the EU (or your country?)
YOUR ANSWER IS __ __ __ __ __ __ __ __
Our answer is published in a subsequent post, with detailed explanations. Access it here
Help is here
If you get stuck, please reach out to us in the chat. We are always happy to assist you. Good luck!
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