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“Soap Dispenser” is difficult to classify under the HS code.

2021-03-24 By Taichi Kawazoe

How do you classify “Soap Dispenser” under the HS code?
It sounds easy but it is actually quite a lot of work to think deeply because
Five Customs classifies different HS for “Soap Dispenser”.

German and Switzerland case HS:8479.89
US case HS:8424.89
Japan case HS:3924.90 (GRI3(b))
Taiwan case HS:8413.20
India case HS:3924.90 (GRI1)

“Soap Dispenser”, an empty bottle, made of plastic and no electrical function.
Soap is pop out when you push the top of the dispenser by hand.

It’s just an ordinary item, but I guess it’s a kind of unclassifiable item without consult importing country’s customs.

Let’s see each country’s Customs ruling recode of “Soap Dispenser”

German case HS:8479.89

In most cases, Customs in the EU classify  Soap dispensers in 8479.89.
“Machine, apparatus and apparatus having individual functions”
this is from the case of a German custom.
Other EU country’s customs classify the same way.

Ref: DEBTI21927/19-1
Issue date: 2019-07-22
HS code: 84798997900
English description:
Soap dispenser, Art.-No. 18791, – of a cuboid housing made of plastic with a removable, mounted on a container opening, manually operated piston pump with spring-loaded suction pipe and soap dispensing spout (Figure see Appendix), – for the metered dispensing of liquids by pressing the piston pump. “Machine, apparatus and apparatus having individual functions, not specified or included elsewhere in Chapter 84, other than code number 8479 1000 00 0 to 8479 8997 85 0 – So-called soap dispensers”

Original description:

 

US case HS:8424.89

Previously US customs classify Soap Dispenser in 8424.20: Spray guns and similar appliances,
but revoked to 8424.89.“Mechanical appliances (whether or not hand-operated) for projecting, dispersing or spraying liquids . . . : Other appliances: Other.”

Ref: HQ H305296
Issue date: July 6, 2004
HS code: 8424.89.7090
English description: The article in question is a hand-operated soap and lotion dispenser, identified as a hand-painted liquid glass pump. The unit consists of a glass bottle reservoir, plastic pump assembly and dispenser head. By pressing the pump assembly up and down, soap or lotion is moved from the reservoir through the pump, and ejected out through the dispenser head.
The applicable subheading for the soap and lotion dispenser will be 8424.89.7090, Harmonized Tariff Schedule of the United States (HTS), which provides for other mechanical appliances for projecting, dispersing or spraying liquids.

The reason why US customs changed their mind to classify 8424.20 to 8424.89 is here
The compact Oxford English Dictionary defines spray gun as “a device resembling a gun which is used to spray a liquid such as paint under pressure.” As described in the ENs, spray guns are usually designed for attaching to compressed air or steam lines, are connected with a reservoir with the material to be projected, and are fitted with a trigger or valve to control the flow through the nozzle. x, and do not fall within the description of subheading 8424.20, HTSUS.
Subheading 8424.89.90, HTSUS, provides for other mechanical appliances for projecting or dispersing liquids. We have previously determined that hand-operated pump dispensers that operate in a manner similar to the instant items are classified in subheading 8424.89, HTSUS. See HQ H070635 (July 13, 2010); HQ H012731 (March 27, 2008); HQ 956522 (August 29, 1994); HQ 956530 (August 29, 1994). Accordingly, we conclude that the subject pump dispensers hand pump are classified in subheading 8424.89, HTSUS.

furthermore, according to “Harmonized Commodity Description and Coding System Compendium of Classification Opinions” Pump is classified in 8424.89

8424.89  «Pump»
comprising a press-button, a nozzle; a piston-spring, a sealing-piston, a stem,
a container-gasket, a screw cap, housing, a spring, a sealing-ball and a diptube.
The article is designed to be mounted on the neck of a container for projecting
liquids, powders or foams through the nozzle by means of a piston-pump

 

Japan case HS:3924.90

Japan case is a bit complicated, “Soap Dispenser” has a “Double-layered soap tank”.
Soap is stored inside of the tank, and paraffin oil, leaves, and ABS balls are stored outside of the tank to decorate its looks.
Japanese customs adopted GRI3(b) to classify and impart essential character on the decorated plastic container itself. They take the pump function as a secondary.

Personally, I don’t agree with that idea, even though the container has unique features, and looks good, this item is nothing other than a pump.

*Example Image1(it’s not confirmed that the below item image is ruling item.)

*Example Image2(it’s not confirmed that the below item image is ruling item.)

Source: Yahoo Shopping

Ref: 115003375
Issue date: 2015-07-17
HS code: 392490010
English description: Lotion dispenser, Pump with container shape: manual material paraffin oil, etc. are entered for the decoration to the pump is marked with the container body side (two-sided) of ( body) methacrylic resin (pump) ABS, PP, PE, chrome-plated, spring (SUS304) (decoration) paraffin oil, naturally dried washing (leaves), Ball (ABS), branch (PP, TPR) Applications: cosmetics purse (dispenser) Size: 75mm × 75mm × height 200mm

This product is a container for cosmetics made from a plastic container and a manual pump, as an article consisting of different components, to apply the general rule 3 (b) on the interpretation of the tariff. Manual pumps are those that are supplementary mounted so easy access cosmetics, construction elements that gives an important feature for this product, because it is recognized as a plastic container store cosmetics, the goods as plastic cosmetic supplies, pursuant to the provisions of Article 39.24 Section tariff and the same table commentary Section 39.24 (D), are classified as described above.

Original description:

Source: Japan customs

Taiwan case HS:8413.20

Ref: 104AA0113
Issue date: 2015-03-05
HS code: 841320
English description: Soap Pump According to the information attached to the case, the product is a soap dispenser which is a combination of a hand pump and a container made of concrete. Its function is a single or repeated operation of the hand pump, which will quantify the liquid soap. Upgrade, which belongs to the category of hand pump goods, should be listed in catalog number 8413.20.00.00-1.

Original description:

Below is TARIFF from the WCO web page, you can see subheading 8413.20 “Hand pumps”.

India case HS:3926.90

Ref: GUJ/GAAR/R/34/2020
Issue date: 03/07/2020
HS code: 3926.90
English description: The applicant has submitted that they are engaged in importing “Plastic Mechanical Liquid Dispensers” from China and sell them in local market since 2011. These dispensers are used as the caps of bottles. They are used for dispensing liquid either through direct discharge or spray type discharge or foam type of discharge.

The items in question are neither a mechanical appliance, Fire extinguisher, Spray guns and similar appliances, Steam or sand blasting machines and similar jet projecting machines nor it can be classified under CTH 8424.89 because CTH 8424.89 refers to other than agricultural or horticultural appliances, industrial bellows and similar other products having same type of functioning are covered.

Indian customs did not take Soap dispensers as a mechanical appliances.

France case HS:8479.89

Ref: FR-PRO-2011-006450
Issue date: Nov. 25, 2011
HS code: 8479.89
English description:DISPENSER MADE OF A HEAD PUMP POLYSTYRENE APPEARANCE AND BRUSH STEEL BODY WITH RUBBER COATING OF OIL. DIAMETER: 7.3 CM Height: 17 CM COLOR: PURPLE

Switzerland case HS:8479.89

Ref: Customs ruling in Switzerland
Issue date: 01/04/2020
HS code: 8479.89
English description: Soap dispenser
essentially consisting of a container and a manually operated
piston pump for dosing and dispensing (not distributing, spraying or
spraying) of liquid soap or similar products, made of plastic, in the
Unit weight of not more than 5000 kg.

Original description:

Source: Customs ruling in Switzerland

 

Conclusion

As stated above Five countries Customs have different opinions to classify.

EU case HS:8479.89
US case HS:8424.89
Japan case HS:3924.90
Taiwan case HS:8413.20
India case HS:3924.90

Japan and India choose the same HS code, but the classification reason is different.

Personally, I like the Taiwan customs decision HS:8413.20. But in EN, there is no clear definition of “Hand pumps”. On the other hand, US opinion and “Harmonized Commodity Description and Coding System Compendium of Classification Opinions” decisions are considerable.  (HS:8424.89), because Heading 8424 state that “Mechanical appliances for projecting, dispersing” .

So I think about how the word “Dispense” connects with “projecting” and “dispersing” could be a key point
From “Merriam-webster” each words are defined below.

Dispense: to divide and share out according to a plan: to deal out in portions
Projecting: to cause to jut out
Dispersing: to cause to become spread widely

What do you think?

Filed Under: Case Study, Classification Example, complex, HS Classification

Principle of being classified as automobile parts under HScode

2020-10-27 By Taichi Kawazoe

In order to determine whether automobile parts are classified as HS:8708, we need to consider this principle of being classified as automobile parts.

Section XVII GENERAL(III)

(a) They must not be excluded by the terms of Note 2 to this Section
(b) They must be suitable for use solely or principally with the articles of Chapters 86 to 88
(c) They must not be more specifically included elsewhere in the Nomenclature

In order to be classified as automobile parts, it is necessary to fulfill above all three of the conditions, therefore a part using solely or principally with the automobile is not enough to be classified as HS:8708(automobile part), it is just one condition.

Here is Supreme Court of India case
G.S. Auto International Ltd vs Collector Of Central Excise … on 15 January, 2003

it states that
whether the goods are suitable for use solely or primarily with articles of Chapter Heading Nos. 87.01 to 87.05; if the answer is in the affirmative, the goods will be classifiable under Chapter Heading 87.08,

But this factor is not enough to fulfill Section XVII GENERAL(III) to be classified as HS:8708(automobile part).

Section XVII GENERAL(III)(c) is the most important condition.
(c) They must not be more specifically included elsewhere in the Nomenclature
Since a part can be classified as other Chapter(ex.3926), it could be excluded from Section XVII (excluded from 8708) even if the part is solely or principally with the automobile

 

Below is the list of the items classified as “Fittings for Coachwork”(HS:3926.30)
They are nothing other than the automobile part but classified as “Plastic Fittings for Coachwork”(HS:3926.30).
They are excluded from Section XVII (HS: 8708) because of Section XVII GENERAL(III)(c).

“Fittings for Coachwork”(HS:3926.30)


door handle
Czech Customs:CZBTI37/086941/2018-580000-04/01


cable guide
German customs:DE239/17-1

 


cable guide
German customs:DE686/17-1

 


cover  mounted behind the interior trim of motor vehicle door
German customs:DE966/17-1


panel for window frames
German customs:DE4899/16-1

 

 


belt deflector
German customs:DE4949/17-1

 


cover assembly hole are directly and permanently mounted on motor vehicles behind the inner panel on the body of the left door
German customs:DE8666/17-1

 

 


entry bar made of molded plastic
German customs:DE14779/16-1

 


mounting bracket used to hold control units
German customs:DEBTI1836/18-1

 


The approximately 32.4 x 24.4 x 10.4 cm shaped product is essentially eleven Recesses for relay socket and plug couplings and a large main compartment for a control unit provided
German customs:DEBTI3532/18-1

 


door handle
German customs:DEBTI13185/18-1

 


universal mount for example, Mobile phones or iPods with two self-locking clamping devices
German customs:DEHH/15/09-1

 


door handle
German customs:DEHH/1118/05-1

 


Plates and emblems for tourist cars
spain customs:ESBTI2017SOL0000000000749

 


automotive plastic wheel attachment
French customs:FR-E4-2006-002796

 


Chrome-plated plastic edging for the power window block mounted on the car door next to the driver
Latvia customs:LVBTI2019-91

 


Interior door handle
Slovakia customs:SK13409/09/5219/28

Filed Under: Case Study, Classification Example

Classify Plastic Autoparts HS:3926.30 or HS:8708.99

2020-10-02 By Taichi Kawazoe

When it comes to classifying Autoparts made of Plastic, there are many HS options.

Especially those two HS definitions are vague
HS:3926.30 “Fittings for coachwork or the like:” and
HS:8708.99 “Parts and accessories of the motor vehicles ”

When you need to classify plastic auto parts you would be confusing which HS code the item belongs to.

In order to make a clear line between them, you need to understand two methods.

1.What is excluded from heading 8708
2.Definitions of “general use parts”

What is excluded from heading 8708

According to CBP “Vehicles, Parts and Accessories Under the HTSUS”.
In order for motor vehicle parts or accessories to be classifiable under heading 8708, they must satisfy all three of the following conditions:
otherwise, they are excluded from heading 8708.

1.They must be identifiable as being suitable for use solely or principally with
motor vehicles of headings 8701-8705.

2.They must not be excluded by Section XVII, Note 2.

3.They must not be more specifically provided for elsewhere in the HTSUS.

Above definitions 1 and 3 are understandable but 2, we need to refer Section XVII note2

Section XVII note2

The expressions “parts” and “parts and accessories” do not apply to the following articles、whether or not they are identifiable as for the goods of this Section:

(a) Joints、washers or the like of any material(classified according to their constituent material or in heading 84.84)or other articles of vulcanised rubber other than hard rubber(heading 40.16);

(b) Parts of general use、as defined in Note 2 to Section XV、of base metal(Section XV)、or similar goods of plastics(Chapter 39);

In this note, parts of general use are excluded from HS:8708 so what’s the definition of parts of general use?

Definitions of “parts of general use”

Note 2 to Section XV state.

2.Throughout the Nomenclature, the expression “parts of general use” means:

(a) Articles of heading 73.07,73.12,73.15,73.17 or 73.18 and similar articles of other base metals;

(b) Springs and leaves for springs、of base metal、other than clock or watch springs(heading 91.14); and

(c) Articles of headings 83.01、83.02、83.08、83.10 and frames and mirrors、of base metal、of heading 83.06。

similar goods of (a),(b),(c) made of plastics are also considered as “parts of general use”

With the above definitions we may make a clear line between HS:3926.30 or HS:8708.99.

The Case of 3926.30

Even if the item is auto parts, fitting parts could be excluded from 8708.
below are examples of classified as 3926.30 by Europian Customs.


Fittings(panel for window frames)
DE4899-16-1


Fittings(panel for window frames)
DEBTI3658/19-1


Fittings
DEBTI27153/18-1


Logo
ESBTIESBTI2017SOL836

Logo
ESBTI2017SOL0000000000749-1

 

Some items are kind of Joints, and some are “parts of general use”

The Case of 8708.99

Even though the items below are made of plastic, they are essential parts for automobiles and not excluded from HS:8708.


The plastic blower for cars
SK12536/16/02


Parts of a steering column
DE892/17-1

 


CONSOLE
GB501958157

Glove box
DE4894-16-1

cable guide
DEBTI5248-18-1

Retrieved from:European Union Website

Filed Under: Case Study

Classifing HS, based on Material or Function?

2020-09-03 By Taichi Kawazoe

US customs(CBP) is reclassifying various Rain gauges as other meteorological instruments under HScode 9015.80 rather than as other articles of glass under HScode 7020.00 or other articles of plastic under HScode 3924.90

At first, they considered that the essential character of this item is represented by its material glass or plastic.therefore they classified them as HS code of 7020.00 or 3924.90.

To the contrary, Europian Union classified Rain gauges as “Surveying, hydrographic, oceanographic, hydrological, meteorological or geophysical instruments and appliances”

Here are examples of Rain gauges classified by Germany customs.

Item image
Issued Country Germany
Reference DE1351/12-1
Issuing date 2012-05-11
Item name Rain gauge
Classified HS code 9015.80
Details & Customs Opinion Rain gauge, so-called rain gauge butterfly (Art. 23295), mainly consisting of an elongated rod with a total length of 110 cm of base metal with a stylized butterfly at the upper end, and a circular cup with a cylindrical glass vessel in “cm” and “Inch” is scaled (external form: see Figure in Appendix). It is used to determine the rainfall in private applications. Not pos 8306, there are goods of Section XVIII, except in Note 1 h) to Section XV of this. The product is considered “not electronic equipment for meteorology, not by UPOS. (HS) recorded 9015 10-9015 40, not on particular aircraft” classified.

 

Item image
Issued Country Germany
Reference DE26898/16-1
Issuing date 2017-01-16
Item name Rain gauge
Classified HS code 9015.80
Details & Customs Opinion Undertow. Rain gauge, essentially consisting of a wooden stick with a total length of approx. 37 cm, which is provided with a plastic fastening ring at the upper end. The ring serves to hold a cylindrical plastic container of approx. 24 cm in length and a diameter in the area of the opening of approx. 8 cm, which is provided with a graduation. The goods are packed in a plastic bag. The goods are used to determine the amount of rainfall in private areas of application. For the outer shape, see illustration in the appendix. The goods are classified as “equipment for meteorology other than those specified in subheading (TARIC) 9015 1010 10 to 9015 4090 00”.

Retrieved from:European Union Website

There was HS classification dichotomy between the US and EU, but now CBP is revocating its opinion.

If there is a classification conflict between Function and Material we need to consider GRI 3(a)

Then we can see “Surveying, hydrographic, oceanographic, hydrological, meteorological or geophysical instruments and appliances” is more specific than “articles of glass” or “articles of plastic”.

Therefore Rain gauge should have been classified as HS code 9015.80.

Filed Under: Case Study

Case study of “CTC” & “VA” method combined(Doors of copper plate)

2020-02-05 By Taichi Kawazoe

Here is a case study of “CTC” & “VA” method combined pattern.

Company A manufactures Doors of copper plate (HS code:74.19)

Case study of "CTC" & "VA" method combined(Doors of copper plate)

Doors of copper plate of heading (HS code:74.19) are manufactured from
the following non-originating materials:

 Final product non-originating
materials
HS code Value
(Total 115 €)
 

Doors of copper plate
HS:74.19
EXW € 200.

 

 

Copper plate: 74.09 € 60.-
  Lock etc.: 83.01 € 37-
  Pressed parts: 74.19 € 18.-

Example PSR for goods of heading Doors of copper plate(HS code:74.19) is:

Case study of "CTC" & "VA" method combined(Doors of copper plate)

It states :
“Manufacture
• from materials of any heading, except that of the product, and
• in which the value of all the materials used does not exceed 50 % of the exworks
price of the product”.

*This rule (PSR) varies depending on the each FTA agreement

The rule contains two conditions. Both of them must be fulfilled. If not, the
product does not acquire originating status.

 

The first condition

“Manufacture from materials of any heading, except that of the product, and”.

As the doors are classified in heading 74.19, the change of tariff heading
requirement is only fulfilled for the copper plate and the locks but not for the
pressed parts.

The second condition

“Manufacture in which the value of all the materials used does not exceed 50 %
of the exworks price of the product”
”.

As the total value of the non-originating materials used for one door (115 €)
exceeds 50 % of the ex-works price of one door (200 €), the second requirements
is not fulfilled.

Conclusion

The doors are regarded as non-originating products.

The “general tolerance rule” cannot help to confer originating status as this rule
contains a limitation stipulating that any of the percentages given in the list for the
maximum value of non-originating materials must not be exceeding the threshold
given in the rule.

Although the value of the pressed parts of 18 € is less than 10 % of the ex-works
price, the total value of all non-originating materials would exceed 50 % of the
limits required in the rule and the second part would not be fulfilled.

Text of the general tolerance rule:
Non-originating materials may be used in the manufacture of a given product,
provided that their total value does not exceed 10 % of the ex-works price of the
product. Where, in the list, one or several percentages are given for the maximum
value of the non-originating materials, such percentages must not be exceeded
through the application of the first subparagraph.

Filed Under: Case Study

Case study of “CTC” & “VA” method combined pattern(Industrial fans)

2019-12-26 By Taichi Kawazoe

Here is a case study of “CTC” & “VA” method combined pattern.

Company A manufactures Industrial fans (HS Heading 84.14)

Industrial fans of heading 84.14 are manufactured from the
following non-originating materials:

 Final product non-originating
materials
HS code Value
 

Industrial fans
HS:84.14
EXW € 200.

 

 

Fan hub 84.14 € 14.-
  Motor 85.01 € 40.-
  Bolts 73.18 € 20.-

Example PSR for goods of heading 84.14 (Industrial fans ) is:

*This rule (PSR) varies depending on the agreement

There are two alternative rules:
Either of them need to be fulfilled in order to be considered as originating goods.

 

The first condition (Column 4)

“Manufacture in which the value of all the materials used does not
exceed 25 % of the ex-works price of the product”.

This condition is not satisfied since the total value of the non-originating
material used is 74 € which means 37 % of the ex-works price of one fan (200 €).

The second condition (Column 3)

“Manufacture:
• from materials of any heading, except that of the product, and
• in which the value of all the materials used does not exceed 40 % of the ex-works
price of the product”.

This rule contains 2 conditions which must be satisfied.

(i) The change of tariff requirement of the first part of the rule is not satisfied for
the fan hub(84.14).
The general tolerance rule allowing the use of non-originating material, provided
that their value does not exceed 10 % of the ex-works price (fun hub 14 € versus
value of the final (200 €) can help to fulfill the requirement.
The limitation in the general tolerance rule saying that any of the percentages
given in the list for the maximum value of non-originating materials must not be
exceeded through the application of the general tolerance rule is also fulfilled.

(ii) The second condition in column 3 is that the total value of the non-originating
materials used must not exceed 40 % of the ex-works price of the product. This
condition is also fulfilled as the total value of the non-originating materials used is
only 37 % of the ex-works price of the fan.

The fans are considered as originating products.

Filed Under: Case Study

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