How to classify a product for U.S. customs

The step-by-step process

Step 1. Gather the facts that decide classification

Write down what the product is made of (by weight and by value for each material), what it does and how, its intended use, its condition (complete, incomplete, unassembled), and how it is packed or sold (individually, as a set, with accessories). Classification is decided on these attributes, so gaps here become errors later.

Step 2. Find candidate sections, chapters and headings

Locate the headings whose terms could describe the product. Read the section and chapter notes before the heading text: they define terms and exclude whole categories. Section XVI's notes, for example, govern whether a component is classified as a part or as a machine in its own right.

Step 3. Apply GRI 1

Classify by the terms of the headings and any relative section or chapter notes. Most products are resolved here. Only if GRI 1 does not settle the heading do you move on.

Step 4. Apply GRI 2 if the product is incomplete, unassembled, or a mixture

GRI 2(a) brings incomplete or unfinished articles that have the essential character of the finished article, and unassembled articles, into the heading for the complete article. GRI 2(b) extends a heading for a material to mixtures and combinations of it, which then go to GRI 3 if they could fall in more than one heading.

Step 5. Apply GRI 3 when two or more headings could apply

In order: 3(a) prefer the heading with the most specific description; 3(b) classify mixtures, composite goods and retail sets by the component that gives them their essential character; 3(c) if neither works, use the heading that occurs last in numerical order.

Step 6. Use GRI 4 and GRI 5 only where they fit

GRI 4 sends goods that fit no heading to the heading for the goods they are most akin to; it is rarely reached. GRI 5 covers cases and containers specially shaped for an article, and packing materials, which are generally classified with the goods they hold.

Step 7. Apply GRI 6 at the subheading level

Repeat the same logic one level at a time: compare only subheadings at the same level within the chosen heading, using the subheading notes. Then select the 8-digit U.S. rate line and the 2-digit statistical suffix.

Step 8. Check CBP rulings and add Chapter 99 overlays

Search CBP's CROSS database for rulings on the same or similar goods; they show how CBP reads the provisions. Then evaluate Chapter 99 additional duties for the country of origin and entry date, such as Section 301, Section 232 and IEEPA measures.

Step 9. Document the reasoning, or request a binding ruling

Record which headings you considered and why each was accepted or rejected. That record is your evidence of reasonable care. For high-value or uncertain products, a binding ruling from CBP under 19 CFR Part 177 fixes the classification before you import.

Worked example: a stainless steel ball valve

Facts: a hand-operated ball valve, body and ball of stainless steel, threaded ends, used to control the flow of industrial fluids. The candidate is heading 8481 (taps, cocks, valves and similar appliances for pipes), and Section XVI and Chapter 84 notes confirm a complete valve classifies there rather than as an article of steel in Chapter 73. GRI 1 settles the heading. Under GRI 6, it is not a pressure-reducing, check or safety valve, so it falls in subheading 8481.80 (other appliances), and the final rate line turns on its operation and material. Each of those decisions is a fact about the product that should be on the record.

Frequently asked questions