Mixtures and Combinations — GRI 2(b)
/ˈmɪkstʃərz ənd ˌkɑːmbəˈneɪʃənz/
GRI 2(b) extends a heading's reference to a material or substance to mixtures or combinations of that material or substance with others, and extends a reference to goods of a given material to goods consisting wholly or partly of that material. When this extension makes goods consisting of more than one material or substance prima facie classifiable under multiple headings, those goods are classified according to GRI 3.
In Detail
GRI 2(b) consists of two sentences that broaden the scope of headings in the Harmonized Tariff Schedule of the United States (HTSUS):
1. Any reference in a heading to a material or substance shall be taken to include a reference to mixtures or combinations of that material or substance with other materials or substances.
2. Any reference to goods of a given material or substance shall be taken to include a reference to goods consisting wholly or partly of such material or substance.
These provisions mean that a heading describing a single material or type of goods can also cover products that contain that material mixed or combined with others, or goods made partly of that material. For instance, a heading for 'cotton fabric' (referencing goods of a given material) would extend to cover a fabric made of 60% cotton and 40% polyester. Similarly, a heading for 'rubber' (referring to a material or substance) would extend to cover a good made of a rubber-plastic mixture.
The critical implication of GRI 2(b) arises when its application makes a single good prima facie classifiable under two or more headings. For example, if a plastic-coated paper product could be described by a heading for 'paper products' (extended by the plastic component) and also by a heading for 'plastic products' (extended by the paper component), then classification cannot be resolved by GRI 2(b) alone. In such cases, the conflict between headings must be resolved by applying GRI 3. It is important to note that GRI 2(b) applies to goods that are themselves mixtures or combinations of materials or substances, or goods partly made of a described material. It does not apply to separate articles that are merely packaged together in a set for retail sale, which are addressed under GRI 3(b).
Classification Significance
Failure to correctly apply GRI 2(b) is a common classification error. Importers may overlook that a heading's coverage is extended by GRI 2(b) to encompass goods containing other materials, and therefore incorrectly classify a multi-material good under a single heading without considering potential competing headings. This can lead to misclassification because the proper analytical sequence—identifying all prima facie applicable headings via GRI 2(b), then resolving conflicts using GRI 3—is skipped. This error frequently appears in classifications of chemical products, textiles, and composite materials, and is a common focus of CBP audits and focused assessments.
How Kanon Handles This
Kanon detects goods consisting of mixtures, combinations, or multiple materials through its product attribute model and applies GRI 2(b) as part of its heading analysis. When GRI 2(b) extends coverage such that a good becomes prima facie classifiable under multiple headings, the GRI 3 analysis is automatically triggered. The full GRI 2(b) → GRI 3 reasoning sequence is documented in the Classification Support Package, ensuring transparency and accuracy.