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Classification challenge: Can you customs classify these hairbands?

Updated: May 23, 2022

Customs classification can be challenging. Try your luck with our guided classification challenge and compare your results with the official solution

OK, so you are ready to try your skills as a customs classifier of these hairbands. Great, before we start, let's remind us 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:

  1. What is the product that I am looking at?

  2. What are the necessary characteristics that I need to know about?

  3. What is the product used for?

  4. What is the commercial description vs. what it actually is?

  5. 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

Here is what we know about this product when looking at the picture and measuring it.

  • It is a articles consisting of a tubular knitted, elasticated fabric

  • It has synthetic fibres combined with a rubber thread

  • It has the of loops with a diameter of approximately 4,5 cm and a width of approximately 2 cm (when unrolled).

  • The articles are knitted in a tubular form and cut at a defined (pre-programmed) width (2 cm).

  • Due to the rubber thread contained in the elasticated fabric, the edges of the articles roll-up, which gives the articles the form of hairbands, ready for use.

See images.

Step 2: Build your argument, grounded in law

Time to make our case

  1. Start with a section. Which one does this product fall into?

  2. Look at the GIR/GRIs and think about which ones could apply in this case? 1 & 6 is a given, but what about 3?

  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?

  4. 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.

  5. Consider any other GIR rule you think is appropriate here

  6. Look at specific rules of your national tariff, like additional notes and subheading rules for numberings past 6 digits.

  7. 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 more geeky 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 your country? The answer will be published in a subsequent post with detailed explanations, so please look out for this.

Help is here

If you get stuck, please reach out to us in the chat. We are always happy to assist you. Good luck!


While you are here, check out these resources:

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