UK CDS Classification Checklist

🔒 IMPLEMENTATION PLAYBOOK: Apply GIRs, verify UK commodity codes, check tariff measures and align classification with CDS declaration data.

About the asset

The CDS Classification Checklist gives you a structured, five-stage process for classifying imported goods and ensuring the resulting commodity code is correctly reflected in your UK Customs Declaration Service (CDS) import declarations. It takes you from gathering the right product information and applying the General Rules for the Interpretation of the UK Tariff through to verifying commodity codes, tariff measures, binding tariff decisions and CDS data elements.

You'll also find practical guidance on documenting classification decisions, maintaining supporting evidence and keeping classification separate from customs origin, valuation and other regulatory controls. Designed for customs compliance managers, classification specialists, import operations teams and declarants, this Checklist helps you apply a consistent approach, identify potential errors and strengthen your classification controls. Includes a Checklist PDF download for immediate use.

CDS Classification Checklist: A step-by-step guide to ensure accurate UK import declarations by gathering product information, applying GIRs, checking commodity codes, reviewing tariff decisions, and aligning with CDS for compliance.

Before you start

Use this Checklist when:

• Setting up a new product for import.

• Reviewing an existing commodity classification.

• Preparing a CDS import declaration.

• Reviewing classification decisions made by a customs representative.

• Investigating a potential classification error.

• Conducting a periodic customs compliance review.

Complete one classification record for each product or product group where the goods have the same relevant technical characteristics and classification treatment.

Do not assume that products with similar commercial descriptions necessarily have the same classification.

Information required

Before starting, obtain the following information where relevant:

Information	What to obtain
Product description	Full and precise technical description, not just the commercial or invoice description
Composition	Materials, ingredients, constituent parts and percentages by weight or other relevant measurement
Function	Principal function, intended use and how the product operates
Technical characteristics	Dimensions, construction, performance, specifications and relevant technical data
Manufacturing	Production method, processing and degree of completion
Presentation	Condition as imported, including whether unassembled, disassembled, incomplete, mixed or presented as a set
Packaging	Packaging type and whether it is specially designed for the product
Product evidence	Technical datasheets, manuals, drawings, photographs, samples and manufacturer information
Import details	Import date, country of import and intended customs procedure
Existing decisions	Previous classification records, tariff advice, rulings and relevant correspondence

If information necessary to distinguish between competing tariff headings is missing, do not finalise the classification. Request the missing technical evidence.

Stage 1. Product identification and technical assessment

The classification must be based on the goods as presented for customs purposes. A product's marketing name, invoice description or supplier's suggested commodity code is not sufficient on its own.

1.1 Product characteristics

• Obtain a complete and accurate product description.

• Confirm the materials and substances the product is made from.

• Record the composition of mixtures and composite products.

• Identify the product's objective characteristics and principal function.

• Establish the intended use where it is relevant to the tariff description.

• Obtain technical specifications, drawings, manuals or product photographs where necessary.

• Confirm the manufacturing process where it affects the product's characteristics.

• Establish whether the product is complete, incomplete, unfinished, unassembled or disassembled when imported.

• Identify whether the goods are presented individually, in a set or with other components.

• Record the packaging and presentation of the goods.

  
  

1.2 Product identity and evidence

• Check that the technical information relates to the exact product being imported.

• Confirm that the product model, SKU, specification and version match the goods.

• Identify any differences between products grouped under the same commercial description.

• Obtain further information from the manufacturer or supplier where the available description is insufficient.

• Record any assumptions made during the assessment.

• Escalate unresolved technical questions before making a final classification decision.

  
  

1.3 Separate regulatory controls

Commodity classification can identify tariff measures and point towards certain import controls. It does not replace the separate assessment of other regulatory requirements.

• Check whether the goods may be subject to import prohibitions or restrictions.

• Check applicable licensing and permit requirements.

• Identify relevant sanitary and phytosanitary (SPS) requirements where applicable.

• Assess any applicable product safety, environmental or other regulatory requirements separately.

• Assess export controls and sanctions separately where relevant to the wider transaction.

  
  

Control point

Do not treat a commodity code as proof that you have met all regulatory requirements. Classification, licensing, product compliance, origin and valuation are separate assessments.

Stage 2. Apply the General Rules for the Interpretation of the UK Tariff

The classification of goods is governed by the General Rules for the Interpretation of the Tariff of the United Kingdom, together with the relevant Section and Chapter Notes.

Apply the rules in their legal sequence. Do not select a heading simply because its description appears commercially familiar.

2.1 GIR 1: Terms of headings and legal notes

• Identify the potentially relevant Section and Chapter.

• Read the wording of the relevant tariff headings.

• Review all relevant Section Notes and Chapter Notes.

• Check whether a legal note includes or excludes the product.

• Consider whether the heading and relevant notes determine the classification.

• Record the legal wording and reasoning supporting the selected heading.

  
  

Application

GIR 1 is the starting point. The titles of Sections and Chapters are provided for reference. Classification is determined by the terms of the headings and the relevant Section and Chapter Notes.

If classification is determined at this stage, there is no need to follow the later rules as a formality.

2.2 GIR 2(a): Incomplete, unfinished, unassembled or disassembled goods

• Establish whether the goods are incomplete or unfinished when imported.

• Assess whether the goods, as presented, have the essential character of the complete or finished article.

• Check whether the goods are imported unassembled or disassembled.

• Consider whether the rule treats the goods as the complete or finished article.

• Retain the technical evidence supporting the conclusion.

  
  

Application

GIR 2(a) can extend a heading for an article to an incomplete or unfinished article where, as presented, it has the essential character of the complete or finished article.

It also covers a complete or finished article presented unassembled or disassembled, including an article treated as complete or finished under the rule.

Do not assume that every incomplete product or collection of components qualifies. Assess the essential-character test against the actual goods.

Find out more about GIR 2 (a).

2.3 GIR 2(b): Mixtures and combinations of materials

• Identify whether the product consists of a single material or substance.

• Identify whether it consists of a mixture or combination of different materials or substances.

• Consider whether a heading referring to a material or substance also covers the product under GIR 2(b).

• Where the goods are prima facie classifiable under two or more headings, proceed to GIR 3.

• Record the competing headings and the reasoning for the final decision.

  
  

Application

GIR 2(b) extends references to a material or substance to mixtures or combinations of that material or substance with other materials or substances. Goods consisting wholly or partly of a particular material may therefore fall within a heading referring to that material.

Where the goods are prima facie classifiable under two or more headings, apply the principles of GIR 3.

Do not treat the presence of several materials as automatically determining the classification. Assess the relevant headings and the GIR 3 hierarchy.

2.4 GIR 3: Goods potentially classifiable under two or more headings

Apply GIR 3 where goods are prima facie classifiable under two or more headings, including where this results from GIR 2(b).

GIR 3(a): Most specific description

• Identify all headings that are prima facie applicable.

• Compare the wording of the competing headings.

• Determine whether one heading provides a more specific description.

• Check whether each heading refers only to part of the materials, substances, or items in a set.

• Record why the selected heading is more specific, or why GIR 3(a) does not resolve the classification.

  
  

Application

The heading that provides the most specific description is generally preferred to a heading that provides a more general description.

There is an important qualification. Where two or more headings each refer to part only of the materials or substances in mixed or composite goods, or part only of the items in a retail set, those headings are regarded as equally specific for this purpose.

GIR 3(b): Essential character

• Establish whether the goods are a mixture, composite good or retail set.

• Identify the components or materials contributing to the product's character.

• Consider the role, nature, quantity, value, weight and function of the relevant components where appropriate.

• Assess which component or material gives the goods their essential character.

• Record the evidence and reasoning supporting the conclusion.

  
  

Application

Where GIR 3(a) does not resolve the classification, classify mixtures, composite goods, and certain retail sets as if they consisted of the material or component that gives them their essential character, where that can be determined.

Essential character is a question of fact and must be assessed in the context of the goods. Do not use one factor, such as value or weight, as an automatic test.

GIR 3(c): Last heading in numerical order

• Confirm that GIR 3(a) and GIR 3(b) do not resolve the classification.

• Identify the remaining competing headings.

• Select the heading that occurs last in numerical order.

• Record why the earlier rules did not determine the classification.

  
  

Application

GIR 3(c) is the final step in the GIR 3 hierarchy. It is not an alternative to the specific-description or essential-character tests.

2.5 GIR 4: Most akin goods

• Confirm that classification cannot be determined under GIRs 1 to 3.

• Identify the goods most closely akin to the product.

• Compare the relevant characteristics and nature of the goods.

• Record the reasoning supporting the chosen heading.

  
  

Application

GIR 4 applies only where the preceding rules do not determine the classification. The goods are classified under the heading appropriate to the goods to which they are most akin.

2.6 GIR 5: Containers, cases and packing materials

GIR 5(a): Specially shaped containers and cases

• Establish whether a container or case is presented with the article.

• Check whether it is specially shaped or fitted to contain a specific article or set of articles.

• Consider whether it is suitable for long-term use.

• Check whether it is presented with the intended article.

• Assess whether the container or case is normally sold with the article.

• Check whether the container or case gives the whole its essential character.

• Record the conclusion.

  
  

Application

GIR 5(a) concerns certain specially shaped or fitted containers and cases presented with the articles for which they are intended. The rule is subject to its stated conditions and exceptions, including where the container or case gives the whole its essential character.

GIR 5(b): Packing materials and packing containers

• Identify the packing materials and containers presented with the goods.

• Establish whether they are of a kind normally used for packing the goods.

• Consider whether they are clearly suitable for repetitive use.

• Apply the rule only where its conditions are met.

• Record any exceptional packaging arrangements.

  
  

Application

Packing materials and packing containers normally used for packing the goods are classified with the goods where the rule applies. This does not apply where the packing materials or packing containers are clearly suitable for repetitive use.

2.7 GIR 6: Classification at subheading level

• Confirm the correct heading before selecting a subheading.

• Review the wording of the relevant subheadings.

• Read the applicable Subheading Notes.

• Compare only subheadings at the same level.

• Apply GIRs 1 to 5, with the necessary changes, when determining the appropriate subheading.

• Record the reasoning supporting the selected subheading.

  
  

Application

GIR 6 governs classification at subheading level. It does not permit comparison of subheadings at different levels. The wording of the subheadings and relevant Subheading Notes must be considered.

Classification decision record

Complete this record before approving the classification.

Decision field	Record
Product name and SKU
Technical description
Composition and materials
Function and intended use
Condition as imported
Relevant Section and Chapter
Candidate headings considered
Relevant Section and Chapter Notes
GIR applied
Subheading analysis
Selected commodity code
Classification rationale
Supporting technical evidence
Outstanding questions
Decision date
Reviewer or approver

Stage 3. Verify the UK tariff and commodity code

Once the classification analysis has identified the appropriate heading and subheading, verify the applicable commodity code using the official tariff for the territory and import date.

Use the UK Trade Tariff for imports into Great Britain. Do not rely solely on a supplier's code, a search engine result, an old declaration or an unverified classification database.

3.1 Commodity code verification

• Open the current UK Trade Tariff.

• Search using the product description and relevant technical characteristics.

• Navigate to the selected Section, Chapter, heading and subheading.

• Check the full legal description of the selected code.

• Review the relevant Section, Chapter and Subheading Notes.

• Confirm that the code is valid for the intended import date.

• Check whether the code has been amended, replaced or discontinued.

• Record the tariff version or search date.

• Save the tariff result or other evidence supporting the selection.

Official tariff service: https://www.gov.uk/trade-tariff

3.2 Check tariff measures

The classification decision and applying tariff measures are related but distinct tasks. A correct commodity code does not, by itself, establish that you have applied every measure correctly.

• Check the applicable customs duty rate.

• Check whether a tariff suspension or reduction applies.

• Check whether an autonomous tariff quota is available and whether its conditions are met.

• Check applicable trade remedy measures, including anti-dumping or countervailing duties.

• Check whether additional codes are required.

• Check whether import restrictions or prohibitions apply.

• Check whether a licence, certificate or other supporting document is required.

• Check whether you must declare supplementary units or quantities.

• Check whether the commodity code is compatible with the intended customs procedure.

• Record the relevant country of origin and country of dispatch separately where they affect the measure.

Do not assume that a tariff preference applies simply because the goods originate in a particular country. Assess the applicable preferential origin rules and supporting evidence separately.

3.3 Keep classification, origin and valuation separate

Subject	What it determines	What to verify
Commodity classification	The tariff heading, subheading and applicable commodity code	Product characteristics, tariff wording and legal notes
Customs origin	The country of origin under the applicable non-preferential or preferential rules	Production, processing and relevant origin criteria
Customs valuation	The customs value used to calculate duty where relevant	Transaction value, adjustments and applicable valuation rules
Import controls	Whether goods require licences, certificates or other approvals	Applicable prohibitions, restrictions and agency requirements

• Do not use the country of origin to determine the commodity code.

• Do not use the commodity code as proof of origin.

• Do not assume that the customs value can be derived from the commodity code.

• Retain separate evidence for classification, origin and valuation decisions.

  
  

Stage 4. Check binding tariff decisions and classification evidence

A binding tariff decision can provide legal certainty for the goods described in that decision. Check that it is from the correct jurisdiction, holder, product identity, and is valid.

4.1 Great Britain: Advance Tariff Ruling

An Advance Tariff Ruling (ATaR) is the relevant HMRC route for a legally binding tariff classification decision for imports into or exports from Great Britain.

• Check whether the importer or relevant business holds an ATaR for the product.

• Confirm the legal holder's identity.

• Match the ruling's product description to the actual goods.

• Check the model, specification, composition and identifying details.

• Check the ruling's validity dates and any relevant conditions.

• Confirm that the goods and their characteristics have not changed.

• Check whether the ruling has been amended, withdrawn or otherwise affected.

• Retain the ruling and supporting product information.

• Ensure the person completing the declaration is informed of the ruling and the correct commodity code.

ATaR decisions are not transferable. A ruling held by another business is not automatically binding on the importer.

Official guidance: https://www.gov.uk/guidance/apply-for-an-advance-tariff-ruling

4.2 Northern Ireland: Binding Tariff Information

For imports into or exports from Northern Ireland or the EU, the relevant legal ruling route is Binding Tariff Information (BTI).

• Establish whether the transaction falls within the Northern Ireland or EU tariff framework.

• Check whether a BTI decision exists for the goods.

• Confirm the holder and the exact goods covered.

• Check the validity period and relevant conditions.

• Confirm that the product remains consistent with the ruling description.

• Retain the decision and supporting evidence.

Do not substitute a Great Britain ATaR for a Northern Ireland or EU BTI decision.

Official guidance: https://www.gov.uk/guidance/apply-for-a-binding-tariff-information-decision

4.3 Other classification evidence

• Review previous classification decisions for the same product.

• Check whether the technical characteristics have changed since the previous decision.

• Review relevant published ruling examples where they assist the analysis.

• Consider relevant classification regulations or official classification material.

• Do not treat another business's ruling as a binding decision for your business.

• Do not rely on a historical classification simply because it has previously been accepted in a declaration.

Where the classification remains uncertain, obtain further technical information or consider applying for the appropriate binding ruling.

Stage 5. Align the classification with the CDS import declaration

The commodity code must be reflected in the correct CDS data elements. The code structure and additional data required depend on the goods and the declaration type.

5.1 Verify the CDS commodity code data elements

HMRC identifies four data elements used for the commodity code and related additional codes.

CDS data element	Information	Check
6/14	Combined Nomenclature code, first 8 digits	Confirm the correct 8-digit code
6/15	TARIC code, digits 9 and 10	Check whether the additional two digits are required for the import declaration
6/16	TARIC additional code	Check whether a relevant additional code applies
6/17	National additional code	Check whether a national additional code is required

The full CDS commodity code structure can extend to 18 characters across these four data elements. It is not correct to describe every UK CDS import commodity code as simply a 10-digit numerical code.

The applicable data elements and their completion requirements depend on the goods and declaration type. Follow the current CDS completion instructions.

• Confirm the correct 8-digit code for DE 6/14.

• Check whether DE 6/15 is required for the particular import declaration.

• Check whether DE 6/16 requires an additional TARIC code.

• Check whether a national additional code is required in DE 6/17.

• Check the applicable declaration category and data set.

• Check the relevant tax type in DE 4/3.

• Check whether DE 6/2 requires supplementary units.

• Check whether a measurement unit code is required in DE 4/4.

• Check the documentary requirements in DE 2/3.

• Check any relevant additional information requirements.

• Confirm that the commodity code is compatible with the customs procedure code in DE 1/10 and additional procedure codes in DE 1/11.

  
  

5.2 Documentary requirements

• Review the measures and conditions displayed against the selected commodity code in the tariff.

• Identify any required licences, certificates, permits or supporting documents.

• Check the relevant document codes and document status requirements.

• Confirm that the required supporting documents are available before declaration.

• Check whether you must declare a ruling reference.

• Ensure the document reference corresponds to the correct product and transaction.

  
  

Do not insert a document code simply because it appeared on an earlier declaration. Check the current tariff measure and CDS completion instructions.

5.3 Final declaration review

Before submission:

• Compare the commodity code in the declaration with the approved classification record.

• Confirm that the declaration accurately describes the goods.

• Check the additional codes and document references.

• Check the applicable customs duty and other tax treatment.

• Confirm the selected procedure and additional procedure codes are compatible.

• Confirm that any required licences or certificates are available.

• Check that the declarant has received the relevant classification instructions.

• Retain the submitted declaration and its supporting evidence.

  
  

4. Practical Implementation

This section sets out how to operate the classification control as a repeatable business process.

4.1 Establish a product classification record

Create or maintain a classification record for each product or product group.

The record should contain:

• Product name, SKU and model.

• Technical description and specifications.

• Materials and composition.

• Function and intended use.

• Condition and presentation at import.

• Selected commodity code.

• Classification rationale and GIR analysis.

• Tariff source and date checked.

• Relevant tariff measures and additional codes.

• Any applicable ATaR or BTI decision.

• Reviewer, approval date and review history.

Recommended control: Do not release a new product classification for customs use until the supporting technical information and classification rationale have been reviewed.

4.2 Define responsibilities

The actual allocation of responsibilities will depend on the organisation. The following roles are suggested control functions, not statutory job titles.

Role	Suggested responsibility
Product or technical function	Supplies accurate product specifications and composition
Classification specialist	Conducts the legal and technical classification assessment
Customs compliance manager	Reviews material classification decisions and exceptions
Import operations	Ensures the approved code and related instructions are used
Customs representative or declarant	Uses the supplied classification and declaration instructions and raises discrepancies
Compliance reviewer	Conducts periodic checks and records corrective actions

Using a customs representative does not remove the importer's need to maintain adequate product information and oversee its customs declarations.

4.3 Control changes to products and tariff data

Reassess the classification when:

• Product composition changes.

• Materials or components are substituted.

• Product function or technical characteristics change.

• The manufacturing process changes in a way that affects classification.

• The product is imported in a different condition or presentation.

• Packaging or retail-set arrangements change in a classification-relevant way.

• The tariff is amended.

• A ruling is amended, withdrawn or reaches the end of its validity.

• A classification discrepancy is identified.

Recommended control: Maintain a review history showing what changed, who assessed the change and whether the commodity code or declaration instructions were amended.

4.4 Maintain the evidence file

Retain the information needed to explain and support the classification decision.

The file should include, where relevant:

• Product specifications and technical datasheets.

• Manufacturer descriptions, drawings and photographs.

• Composition and material breakdowns.

• Classification rationale and GIR analysis.

• Relevant Section, Chapter and Subheading Notes.

• Tariff extracts or dated tariff search records.

• Relevant classification decisions and rulings.

• Correspondence supporting the decision.

• CDS declarations using the classification.

• Records of reviews, changes and corrective action.

  
  

Record retention

Do not apply a blanket statement that every customs record must be retained for exactly four years from the date of declaration.

The HMRC Notice made under the Customs (Records) (EU Exit) Regulations 2019 sets out the relevant retention periods. For standard free-circulation cases, the period generally ends three years after the last day of the calendar year in which the declaration was accepted, or the procedure was discharged, as applicable.

Longer periods can apply. These include certain preferential trade agreement records; longer periods under other record-keeping rules or authorisations; cases involving declaration inaccuracies or repayments; and records relevant to appeals or proceedings.

Recommended control: Apply a retention schedule that identifies the relevant customs, VAT, authorisation and trade agreement requirements. Where more than one period applies, retain the records for the longest applicable period.

4.5 Exceptions and escalation

Stop the classification or declaration process and escalate where:

• Product information is incomplete or contradictory.

• Two or more headings remain plausible, and the legal analysis is unresolved.

• The classification depends on an unestablished technical characteristic.

• The tariff description or legal notes appear inconsistent with the proposed classification.

• An existing ruling does not clearly cover the goods.

• A tariff amendment may affect the existing code.

• A required licence, certificate or document is unavailable.

• The CDS declaration requirements do not match the approved classification record.

Record the issue, the affected product or declaration, the decision required and the evidence needed to resolve it.

4.6 Periodic review

A periodic review should test whether:

• Product information remains accurate.

• Classification decisions remain supported.

• Commodity codes remain valid.

• Tariff measures and additional codes have been checked.

• Rulings remain applicable.

• CDS declarations use the approved classification.

• Changes and discrepancies have been recorded.

• Supporting evidence can be retrieved.

The review frequency should reflect the business's product range, classification risk, tariff changes, and volume of import activity.

4.7 Classification control completion record

Control field	Record
Product / SKU
Commodity code
Classification rationale available	Yes / No
GIR analysis completed	Yes / No
Tariff checked	Yes / No
Tariff check date
Additional codes reviewed	Yes / No / Not applicable
CDS data elements checked	Yes / No
Binding ruling reviewed	Yes / No / Not applicable
Supporting evidence retained	Yes / No
Outstanding issue
Action required
Responsible role
Review date
Approval status	Approved / Pending / Rejected

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