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Commodity codes and origin for liquid containers

The code sets the duty, decides whether CBAM applies and pulls in trade measures. Origin is a legal test, not where the box was loaded.

An opened export carton of plain steel cans in a port examination bay
The heading decides the duty and which measures apply.

The commodity code on your entry decides three things at once: the duty you pay, whether the carbon border mechanism applies, and which trade measures attach. Suppliers routinely hand over a code copied from an old invoice. That is a guess with your money behind it, and the liability for getting it wrong is the importer’s.

Where liquid containers classify

HeadingCoversTypical products here
7310Tanks, casks, drums, cans, boxes and similar containers of iron or steel, capacity not exceeding 300 litres, lined or notSteel and stainless jerry cans, upright and horizontal steel tanks
3923Articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and other closures of plasticsHDPE jerrycans, plastic closures and caps
7612Aluminium casks, drums, cans and similar containers, capacity not exceeding 300 litresAluminium fuel cans

Indicative headings for orientation, not a classification ruling. Accessories often classify away from the container they serve: a steel mounting bracket, a brass tap and a rubber gasket can each land in a different chapter.

How a commodity code is builtThe first six digits are the international Harmonised System and are identical everywhere. The EU extends to eight digits as the Combined Nomenclature and ten as TARIC. The UK runs its own tariff on the same six-digit base. HS 6
International. Same everywhere
CN 8
EU Combined Nomenclature
TARIC 10
EU trade policy measures
UK tariff
Own extension, same HS base
A code is not portable between markets past six digits. A supplier quoting one number for both the UK and the EU has checked neither.

How the code is built

The first six digits are the international Harmonised System and are the same everywhere. After that the systems diverge: the EU extends to eight digits as the Combined Nomenclature and to ten as TARIC, which is where trade policy measures are expressed. The UK runs its own tariff on the same six-digit base. So a code is not portable between markets past six digits, and a supplier quoting one number for both is telling you they have not checked either.

There is a method behind arriving at the code, and it is worth knowing because it settles the arguments. Classification follows the General Interpretative Rules in order. Rule 1 says the headings and the section and chapter notes govern, so a marketing description never decides anything. Where a good is composite or made up of different materials, Rule 3 applies in sequence: the most specific description wins, failing that the material or component giving the good its essential character, and only failing that the last heading in numerical order. Rule 6 then repeats the exercise at subheading level.

The essential-character rule is the one that decides a real question in this category. A can supplied with its cap and a pouring spout as one retail package is classified by whatever gives it its essential character, which is the container rather than the accessory, so the set follows the can. Buy the same spouts as a separate line and they classify on their own, in their own material's heading, at their own duty rate. The same physical parts therefore land in different places depending on how they are packed and invoiced, which is a commercial decision with a customs consequence.

Where the parts classifyA steel can falls in heading 7310, a plastic can in 3923 and an aluminium can in 7612. CBAM lists goods by heading, so only the steel heading brings a carbon border obligation. 7310 steel 3923 plastic 7612 alum. Steel jerry can Steel jerry can: suitable for 7310 steel✓ Steel jerry can: not suitable for 3923 plastic✕ Steel jerry can: not suitable for 7612 alum.✕ HDPE jerry can HDPE jerry can: not suitable for 7310 steel✕ HDPE jerry can: suitable for 3923 plastic✓ HDPE jerry can: not suitable for 7612 alum.✕ Aluminium can Aluminium can: not suitable for 7310 steel✕ Aluminium can: not suitable for 3923 plastic✕ Aluminium can: suitable for 7612 alum.✓ Plastic closures alone Plastic closures alone: not suitable for 7310 steel✕ Plastic closures alone: suitable for 3923 plastic✓ Plastic closures alone: not suitable for 7612 alum.✕ CBAM applies CBAM applies: suitable for 7310 steel✓ CBAM applies: not suitable for 3923 plastic✕ CBAM applies: not suitable for 7612 alum.✕
A can supplied with its cap and spout as one retail package follows the container, because Rule 3 classifies a set by essential character. Buy the same spouts as a separate line and they classify on their own, in their own heading, at their own rate. The same parts land in different places depending on how they are packed and invoiced.

Why the code matters beyond duty

  • CBAM. The carbon border mechanism lists goods by heading, and 7310 is on the list. Classify a steel can into 7310 and the EU importer picks up CBAM obligations; classify a plastic one into 3923 and they do not.
  • Trade measures. Anti-dumping duties, safeguards and quotas attach to codes and origins, not to product descriptions. Steel is a heavily measured sector.
  • Preference. Whether a trade agreement rate applies at all turns on the code plus the origin rule for that code.
How far a code travelsThe first six digits are the international Harmonised System. The EU extends to eight as the Combined Nomenclature and ten as TARIC. The UK runs its own tariff on the same six-digit base. EU UK Elsewhere HS 6 digits HS 6 digits: suitable for EU✓ HS 6 digits: suitable for UK✓ HS 6 digits: suitable for Elsewhere✓ CN 8 digits CN 8 digits: suitable for EU✓ CN 8 digits: not suitable for UK✕ CN 8 digits: not suitable for Elsewhere✕ TARIC 10 digits TARIC 10 digits: suitable for EU✓ TARIC 10 digits: not suitable for UK✕ TARIC 10 digits: not suitable for Elsewhere✕ UK commodity code UK commodity code: not suitable for EU✕ UK commodity code: suitable for UK✓ UK commodity code: not suitable for Elsewhere✕ Binding ruling Binding ruling: suitable for EU✓ Binding ruling: suitable for UK✓ Binding ruling: conditional for Elsewhere~
A code is not portable between markets past six digits, so a supplier quoting one number for both is telling you they have not checked either. Both EU BTI and UK ATaR run three years and bind the authority as well as the holder, and a BTI binds every member state rather than only the one that issued it.

Origin is a legal test, not a shipping address

The country a shipment leaves is not necessarily its origin. Origin is determined by rules attached to the product and, where a trade agreement is claimed, by that agreement’s own rules of origin, which usually turn on where substantial transformation happened rather than where the goods were consolidated.

For a dual-sourced supplier this is the practical consequence: production moving between plants can change origin, which can change duty in either direction and can change which measures apply.

What decides origin is where the last substantial transformation happened, and for a pressed steel can that is where the coil was formed and finished rather than where it was packed or consolidated. Shipping through a third country changes nothing. Neither does invoicing from a fourth. Origin follows the manufacturing, which is why a Singapore contract desk does not make goods Singaporean.

Where a trade agreement is claimed, that agreement’s own rules of origin apply and they are stricter than the general ones. They typically set a threshold as a change of tariff heading or a percentage of value added, and claiming preference without meeting it is a declaration error rather than a difference of interpretation.

Get an origin declaration for each production base before you need one, not after a customs query.

Keep the two kinds of origin apart in your own records, because they answer to different rules and are needed at different moments. Non-preferential origin is what determines whether an anti-dumping duty, a safeguard measure or a quota applies, and it exists whether or not any trade agreement is in play. Preferential origin is a claim under a specific agreement, made to obtain a reduced rate, and it carries its own stricter tests and its own documentary form. A supplier declaration that supports one will not necessarily support the other.

For a dual-sourced programme that is a filing discipline rather than a theoretical point. The same design, made to the same drawing, at two plants in two countries, has two origins and potentially two duty outcomes, two sets of applicable measures and two preference positions. Which plant made a given consignment is therefore a customs fact that has to be traceable from the entry back to the production record, and the time to build that link is at the order rather than at the query.

Stop guessing: get a binding ruling

Both markets issue rulings that bind the authority to a classification. In the EU it is Binding Tariff Information; in the UK, an Advance Tariff Ruling. Both are valid for three years from the date of the decision, both bind the authority as well as the holder, and an EU BTI binds every member state's customs administration rather than only the one that issued it. Either can be cut short if the classification legislation, the explanatory notes or the case law move underneath it.

They take time to obtain and they remove the argument entirely for the period they cover. For a programme of any size, on a product family with a real classification question behind it, that is a cheap piece of certainty, and three years is long enough to cover a tooling cycle. Apply before the first entry rather than after the first query, because a ruling obtained during a dispute does not settle the entries already made.

Getting to a code you can rely onA commodity code is arrived at by applying the classification rules to the goods, and it is made binding by a ruling from the customs authority rather than by a supplier opinion. Describe it
Material, capacity, closure, use
Apply the rules
Heading, then subheading, in order
Check precedents
Existing rulings on similar goods
Get it binding
A ruling the authority must honour
Only the last box is protection. Everything before it is a well-informed opinion, and an opinion is what an importer is left holding when the classification is challenged.

What to ask a supplier for

  • The heading they believe applies, with the reasoning, rather than a number alone
  • Material composition by weight, since classification often turns on the constituent material
  • Country of production for the specific run, and an origin declaration
  • Net and gross weights, which you need for both duty and the CBAM threshold
What the code decides beyond the duty rateClassification is often treated as a duty question, but the heading is also the trigger for several regimes that have nothing to do with the rate. Follows the code Duty rate Duty rate: suitable for Follows the code✓ CBAM scope CBAM scope: suitable for Follows the code✓ Preference eligibility Preference eligibility: suitable for Follows the code✓ Quotas and safeguards Quotas and safeguards: suitable for Follows the code✓ Import licensing Import licensing: suitable for Follows the code✓ Statistical reporting Statistical reporting: suitable for Follows the code✓
This is why a code chosen to minimise duty can cost more than it saves. The same digits that set the rate decide whether a carbon mechanism and a safeguard measure reach you.

Where we stand on this

We confirm the heading we believe applies for any product before you order, with the reasoning behind it, and we state the country of production for the run. What we do not do is give you a classification you can rely on as a ruling, because no supplier can: classification is determined by the customs authority in your market, and a binding ruling is the only thing that settles it. Treat our view as the starting point for your own check.

Origin against shipping addressOrigin is a legal test about where the goods were substantially transformed. Where they were despatched from, invoiced from or stored has no bearing on it. Sets origin Does not Where it was manufactured Where it was manufactured: suitable for Sets origin✓ Where it was manufactured: not suitable for Does not✕ Where it changed materially Where it changed materially: suitable for Sets origin✓ Where it changed materially: not suitable for Does not✕ Where it was warehoused Where it was warehoused: not suitable for Sets origin✕ Where it was warehoused: suitable for Does not✓ Where it was invoiced from Where it was invoiced from: not suitable for Sets origin✕ Where it was invoiced from: suitable for Does not✓ The packing list address The packing list address: not suitable for Sets origin✕ The packing list address: suitable for Does not✓ Where it was consolidated Where it was consolidated: not suitable for Sets origin✕ Where it was consolidated: suitable for Does not✓
Four of these six change nothing and all four appear on the paperwork, which is why origin is the field most often filled in from the wrong document.

Where to start

Your use caseRecommended canWhy this one
Steel, heading 7310 20L NATO Steel Fuel Can20L NATO Steel Fuel Can Also the heading that triggers CBAM.
Plastic, heading 3923 Economy HDPE Jerrycan — non-UNEconomy HDPE Jerrycan — non-UN Outside CBAM; inside packaging rules.
Aluminium, heading 7612 20L Aluminium NATO Can20L Aluminium NATO Can Different chapter, different measures.
Accessories classify separately Caps, Closures & GasketsCaps, Closures & Gaskets Closures rarely follow the container.

Common questions

What is the commodity code for a steel jerry can?

Steel containers up to 300 litres classify in heading 7310, which covers tanks, casks, drums, cans and boxes of iron or steel whether or not lined. Plastic containers and closures fall in 3923 and aluminium ones in 7612. These are orientation, not a ruling: classification is determined by the customs authority in your market.

Is the commodity code the same in the UK and the EU?

Only to six digits. The first six are the international Harmonised System and are identical everywhere. The EU extends to eight digits as the Combined Nomenclature and to ten as TARIC, where trade policy measures are expressed; the UK runs its own tariff on the same six-digit base. A code is not portable between markets past six digits.

Why does the commodity code matter beyond the duty rate?

Because CBAM lists goods by heading, so classifying a steel can into 7310 gives the EU importer CBAM obligations while a plastic one in 3923 carries none. Anti-dumping duties, safeguards and quotas also attach to codes and origins rather than to product descriptions, and steel is a heavily measured sector.

Is country of origin the same as where the goods shipped from?

No. Origin is a legal test based on where substantial transformation happened, and where a trade agreement is claimed it follows that agreement own rules of origin. For a dual-sourced supplier this matters: moving production between plants can change origin, which changes duty and which measures apply.

How do I get certainty on a classification?

Apply for a binding ruling. The EU issues Binding Tariff Information and the UK issues Advance Tariff Rulings, both of which bind the authority for the period they cover. No supplier can give you a classification you can rely on, because classification is determined by the customs authority in your market.

References

The standards and regulations this page relies on, at their issuing body. Where a market rule is named here, check the current revision before you specify against it.

Last reviewed .

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