HS Codes (Harmonized System): Definition, Structure, and Key Role in EUDR Compliance
HS codes (Harmonized System) are often perceived as a strictly “customs-related” topic. However, they now play a central role in compliance, traceability, and determining regulatory scope—particularly within the framework of the EUDR (EU Deforestation Regulation).
In this article, we explain what HS codes are, how they are structured within the European Union (CN, TARIC), and why identifying them correctly is a fundamental step for EUDR obligations and associated declarations.
HS codes (Harmonized System) are an international nomenclature administered by the World Customs Organization (WCO). Their purpose is to classify goods uniformly on a global scale to facilitate international trade, statistical collection, and the application of customs measures.
1) What is an HS Code?
The Harmonized System is based on a six-digit coding system. This foundation is used by more than 200 countries to identify imported or exported products in a standardized way, regardless of language or country.
One can think of an HS code as a universal identifier: for example, the code 0901 corresponds to coffee.
2) HS, CN, TARIC: What are the differences in the European Union?
The six-digit HS code forms the international base. In the European Union, this base is supplemented by variations that add further levels of precision.
The CN Code (8 digits): The Combined Nomenclature (CN) is the European Union’s nomenclature. It adds two digits to the HS code to further specify product classification.
The TARIC Code (up to 10 digits): The TARIC can go up to ten digits. It is used to integrate specific regulatory requirements and EU measures (duties, restrictions, suspensions, controls, etc.) when a finer level of detail is required.
In summary:
– HS: 6 digits (International base)
– CN: 8 digits (European precision)
– TARIC: Up to 10 digits (European precision for regulatory purposes)
3) A Vital Point: Companies do not “choose” their code freely
It is important to avoid a common but inaccurate phrasing: a company does not “choose” its HS code in the sense that it can set it freely.
The code is determined by the nomenclature and the applicable classification rules (nature of the product, composition, function, degree of processing, etc.). The company’s role is to identify the code applicable to its product and then use it consistently in its master data, documents, and declarations.
In case of uncertainty or complex situations, it is possible to secure the classification via a dedicated administrative decision (Binding Tariff Information – BTI), in order to reduce the risk of error and misinterpretation.
4) Why are these codes decisive for the EUDR?
With the EUDR, the question is no longer just “how to declare a product,” but first and foremost: “Is my product subject to the regulation?”
The answer largely depends on customs classification: HS/CN codes are used to determine if a commodity falls within the scope of the regulation, in accordance with the list of relevant products in Annex I (wood, cocoa, coffee, soy, etc.).
In other words, EUDR compliance often begins with a structural step: correctly identifying the applicable code, as it dictates the scope, obligations, and the consistency of all downstream processes.
5) HS/CN Codes and Declarations via TRACES
Within EUDR processes, operators must enter product information into European systems, notably via TRACES, depending on the use case and the level of precision required.
The HS/CN code is one of the elements that allows for standardized identification of the goods, ensures a consistent interpretation of declarations, and aligns the product with applicable requirements.
6) Common Errors and Compliance Impacts
Imprecise or inconsistent classification is not merely an administrative detail; it can lead to compliance gaps, delays, or documentary inconsistencies.
Common errors include:
– Using a code that is too generic when a CN level is required.
– Confusing raw materials with processed products (different classifications and potentially different obligations).
– Reusing an unverified historical classification.
– Treating the subject as purely “customs-related” without measuring the impact on EUDR compliance and traceability.
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