The General Rules for the Interpretation (GRI) of the Harmonized System consistently regulate the international customs classification of goods and serve as "rules of the game" for uniform application. They comprise six systematically structured rules, ranging from the wording of the headings to the so-called "last-resort rule," enabling a legally sound and comprehensible classification.

Starting May 3, 2025, the USA will impose comprehensive special tariffs under Section 232 on numerous vehicle parts, machinery components, and electronic parts with an additional duty rate of 25%. Affected companies should carefully review their HTS codes, utilize potential USMCA exemptions, and adjust their customs strategy accordingly to avoid additional costs.

In the USA, new tariff exemptions for certain products under heading 8517 will apply from April 11, 2025, particularly for smartphones (8517.13.00) and networking devices (8517.62.00). The key criterion for the exemption is that the product must independently perform communication functions; however, many accessories and devices with a different primary function remain subject to the US reciprocal tariffs.

Annex II of the US 'Reciprocal Tariffs' indeed lists customs tariff numbers as exceptions, but it does not guarantee a general exemption, as many headings are restricted by HS Notes and explanatory notes. Therefore, a precise customs tariff examination of each product is essential to avoid misclassifications and unexpected duties.

Starting April 2025, the USA will impose additional tariffs of at least 10% on nearly all imports, with higher rates applicable for countries with a high trade surplus. Exceptions, such as for certain product groups or when the US-origin content is at least 20%, are thoroughly regulated and require precise customs classification and origin documentation.

The customs classification of delivered machines is determined according to GRI 2a and is carried out as with complete goods when the parts belong together and are intended for assembly. This not only impacts customs clearance but also affects the determination of origin, as only a uniform customs classification allows for accurate determination of preferential origin.

The Volvo case shows that final assembly alone does not change the non-preferential origin if pre-assembled main components have already gained a new identity in another country. For companies, this means that, in addition to the correct customs classification, the declaration of origin must also be carefully documented and maintained in the ERP system to avoid additional claims and penalties.

Since March 2025, the USA has imposed a uniform additional tariff of 25% on nearly all steel imports, as all general exemptions have been removed. This affects numerous steel products from chapters 72 and 73 as well as various derivative products; companies need to adjust their procurement and customs strategies accordingly to avoid additional costs.

The Ford case demonstrates how critical accurate customs classification is for imports: Due to an incorrect customs classification of Transit Connect vehicles as passenger cars instead of trucks, Ford had to pay 365 million USD in customs back payments and penalties. The decisive factors for the classification are not registration or equipment at importation, but objective features such as use, construction, and vehicle equipment according to customs tariff regulations.

The precise customs classification of steel and aluminum products is essential for internationally operating companies, as errors can lead to high punitive tariffs, delays, and legal consequences. With the tightening of US Section 232 measures to up to 25% additional tariffs, the material composition, processing condition, and processing depth of the products gain critical importance for correct classification.