The World Customs Organization recently reported the acceptance of hundreds of changes to the global Harmonized System, the international classification of goods that gives every traded product a standardized code. Individual WCO members are slated to implement these changes in their national tariff schedules as of Jan. 1, 2028.
What’s Changing
According to a WCO press release, the amendments comprise 299 sets of changes, resulting in an HS nomenclature of 1,229 headings and 5,852 subheadings. Compared to the 2022 edition, the 2028 HS adds six new headings and 428 new subheadings while also removing five headings and 172 subheadings to reflect evolving trade patterns, technological progress, and growing regulatory needs. Specific highlights include the following.
- new subheadings to enhance the visibility of essential supplies used in health emergencies, including ambulances, personal protective equipment, medical ventilators, and diagnostic devices
- reclassifying vaccines previously covered by heading 3002 into two new headings: 3007 for vaccines for human medicine, with disease-based subheadings, and heading 3008 for other vaccines, including veterinary vaccines
- new heading 2107 for dietary supplements, with subheadings 2107.10 for those put up in measured doses and 2107.90 for those in packings for retail sale, accompanied by new legal notes, to resolve longstanding classification challenges at the interface between food and pharmaceutical products
- restructuring the classification of plastic waste, including new subheadings that distinguish hazardous plastic waste, plastic waste subject to prior informed consent procedures, and other plastic waste
- new subheadings and legal clarifications that support (1) more consistent classification of plastic products, including single-use items, (2) support better trade data and policies to reduce plastic pollution, and (3) promote circular economy approaches
- improvements for goods controlled under international conventions, enhanced visibility for certain environmentally-relevant products, and targeted clarifications to HS provisions to ensure more uniform interpretation and application
What It Means
Companies should expect updates to product classifications, especially in sectors such as medical devices, pharmaceuticals, dietary supplements, plastics, and environmental goods. In addition, the creation of new headings and subheadings could alter partner government agency requirements and reporting obligations, while discontinued codes may require the revalidation of long-used classifications. Internal databases, automation tools, and documentation may need to be updated accordingly.
In the U.S., the International Trade Commission is expected to publish in February its preliminary draft modifications to the Harmonized Tariff Schedule of the U.S. to implement the HS 2028 changes. Following a public comment period the ITC will finalize the necessary modifications to the HTSUS, with plans to submit a report to the president in September.
Any such modifications must ensure substantial duty rate neutrality, so once they’re issued importers should identify where their goods are being reclassified and confirm that the new HTSUS provision has the same duty rate as the old one. If it appears there is no provision under the new heading/subheading with the same duty rate, comments can be submitted to advocate for additional rate lines under the new heading or subheading. ST&R can support your company in this and advocate before the ITC and U.S. Customs and Border Protection, if needed, to redress any missing provisions.
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