Our friends at the U.S. International Trade Commission are soliciting comments on possible revisions to the International Harmonized Commodity and Coding System. Everyone involved in international trade knows that the HS is the structure on which national tariff nomenclatures are based, including the Harmonized Tariff Schedule of the United States.
Keeping the HS Current
The HS, overseen by the World Customs Organization, undergoes periodic review and revision by WCO member governments. The goal is to simplify the nomenclature, take account of recently developed products and remove unnecessary tariff lines. Any changes adopted are at the international four-digit (heading) and six-digit (subheading) levels and do not affect tariff rates.
With the seventh such review nigh upon us, the Commission seeks public submissions on the following points:
- The deletion of HS headings or subheadings with low trade volume;
- The creation of separate 4-digit headings or 6-digit subheadings to identify types of products that are important in international trade but are not adequately classified;
- The simplification of the HS, whether by the modification of provisions for greater clarity or the elimination of provisions that are difficult to administer; and/or
- The suggestion of other changes that would improve the classification of products, especially those being exported from the United States, or assist in the administration of the HS and the more uniform classification of goods internationally.
The comments will be taken into account by the United States in formulating any proposed HS changes.
No Time Like Now
There’s a long lead time for submitting comments. The Commission recommends that they be docketed by March 31, 2020, though that’s not a hard deadline. After receiving input from member governments, the WCO will issue recommendations.
Changes at the eight-digit (national) and ten-digit (statistical) levels are outside this review, as are requests to revise the HS Explanatory Notes. Within those constraints, nevertheless, the review process offers an opportunity to clarify the classification of new technologies and eliminate redundant provisions.