Customs classification of goods ensembles for retail sale: Introduction

In this article, we explain the term "goods assembled for retail sale" in the customs tariff and present examples.

Within the framework of all relevant EU preference regulations, the term "assembly of goods" is understood as a combination of goods that complies with General Interpretative Rule 3 (GRI 3b) of the Harmonized System (HS).

These assemblies are prepared for retail sale and are characterized by the following features:

1. Consist of at least two different goods that could fall under different tariff headings.

2. They are assembled to meet specific needs or to support certain activities.

3. They are packaged in such a way that they can be delivered directly to consumers without further repackaging, for example, in boxes, cases, clear packaging, or on substrates.

All three of the above criteria must be met, and assemblies of this type are generally classified under the heading of the component that imparts their essential character.

Exceptions to the above rules apply when it comes to assemblies that must be classified according to GRI 1 and 6, and where the term "assembly" is explicitly stated in the CN code. Here are some examples:

• 6308 00 00: Assemblies of textile and yarn, [...] packaged for retail sale

• 8206 00 00: Assemblies of tools from two or more of the headings [...] packaged for retail sale;

• 9503 00 70: other toys, assembled in assemblies or packaged

Examples that are considered customs tariff assemblies

• Bath and pamper sets that include shower gel, bubble bath, soap, body lotion, as well as complementary items such as sponges or washcloths. These goods can be used simultaneously, in sequence, or in any order and complement each other in their application.

• Hospital patient or travel hygiene kits consisting of low-value items such as disinfectant wipes, disposable pens, toothbrushes, toothpaste, shampoo, moist face and body cleansing wipes, hand sanitizers, fabric sprays, lip balm, soap, nail brushes, and hygiene information leaflets.

• Drill and plug assemblies, comprising twist drills made of steel, wood twist drills, carbide stone drills, screwdriver bits with magnetic holder, and plugs. All elements are housed in a divided plastic case.
  
  

Examples that are not considered customs tariff assemblies

• "Holiday baskets" or gift baskets that contain various items such as cheese, wine, champagne, liqueur, tea, jam, olive oil, honey, pâté, and spices must be classified separately.

• A "coffee set" in plastic packaging, consisting of flavored instant coffee powder, cinnamon sticks, a small stainless steel grater, a metal container with a lid (containing coffee powder), and a ceramic mug. Each element is classified separately.

• Bath and pamper sets containing body cleansing products (such as shower gel, soap) and separately usable items such as slippers, hand mirrors, hairbrushes, and ornamental candles are used differently and serve different needs. Therefore, they must be classified separately.

Because the assessment of customs tariff assemblies often requires individual and careful examination, the European Commission has published a guideline for the interpretation of GRI 3b. This guideline can be found at the following link: Guideline.

traide Support

The correct customs classification of assemblies can be challenging – especially when products are mixed-packaged and versatile. Deciding whether an assembly is treated as a unit under customs law or must be classified individually has immediate impacts on duty rates, preferential rights, and import documentation.

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