UK Commodity Codes, EU Combined Nomenclature and Canada Tariff: Regional HS Code Guide
- John Hall
- Customs Specialist at iCustoms.ai
The Harmonized System gives every traded product a universal six-digit identity. What countries do with those six digits after that is where national tariff systems diverge. The UK, the EU, the United States, Canada, and Australia each extend the international HS subheading with their own national digits, their own duty rates, and their own trade measures. For traders operating across multiple markets, understanding how these systems differ is not optional. Using the wrong digit count, the wrong tariff schedule, or the wrong national extension on a customs declaration is a classification error.
This guide covers the UK commodity code system post-Brexit, the HMRC guidance tools available to UK traders, the EU Combined Nomenclature and TARIC system, and the Canadian tariff schedule. A full regional comparison table covers the UK, EU, US, Canada, and Australia in one reference.
Post-Brexit Commodity Codes Explained
Before 1 January 2021, the United Kingdom used the European Union’s Combined Nomenclature as the basis for all customs declarations. UK traders importing goods declared a 10-digit TARIC code. UK traders exporting declared an 8-digit CN code. Both were drawn from the EU’s single tariff schedule.
Brexit changed this. From 1 January 2021, the UK published its own tariff schedule: the UK Global Trade Tariff (UKGT). The UKGT uses the same six-digit international HS subheading as its foundation but applies UK-specific duty rates, UK trade preference schemes, and UK trade measures in the digits beyond six. The EU and UK now maintain separate tariff schedules that have diverged increasingly since 2021.
How UK and EU Commodity Codes Differ Post-Brexit
The divergence between the UK and EU tariff schedules operates at several levels. At the six-digit HS subheading level, the codes remain identical because both are based on the WCO Harmonized System. At the national extension level (digits 7 to 10), the two systems have followed different paths.
| Area of Divergence | UK Position (Post-Brexit) | EU Position |
|---|---|---|
| Tariff Schedule Name | UK Global Trade Tariff (UKGT) | EU Common Customs Tariff based on the Combined Nomenclature (CN) |
| Import Digit Count | 10 digits (full commodity code) | 10 digits (full TARIC code) |
| Export Digit Count | 8 digits | 8 digits (CN code) |
| Duty Rates | The UK has reduced or eliminated tariffs on many goods under the UKGT. Rates differ from EU MFN rates across hundreds of product lines. | EU Common Customs Tariff rates remain in force. UK goods imported into the EU are generally subject to EU MFN duty unless a preferential arrangement applies. |
| Trade Preference Schemes | UK Developing Countries Trading Scheme (DCTS) replaced the EU GSP for UK imports. The UK also maintains separate bilateral FTAs with countries such as Japan, Australia, New Zealand, and GCC partners. | EU Generalised Scheme of Preferences (GSP) and the EU’s network of bilateral Free Trade Agreements. |
| UK–EU Trade | UK goods exported to the EU may face EU MFN duty unless the Trade and Cooperation Agreement (TCA) rules of origin are satisfied for preferential zero-tariff treatment. | EU goods exported to the UK may face UK MFN duty unless the TCA rules of origin are satisfied for preferential zero-tariff treatment. |
| Anti-Dumping and Safeguard Measures | The UK maintains its own anti-dumping and safeguard measures. Some align with former EU measures, while others differ. | The EU maintains separate anti-dumping and safeguard measures that no longer automatically apply to the UK. |
| Tariff Classification Tool | UK Trade Tariff at trade.gov.uk | EU TARIC database at ec.europa.eu/taxation_customs/dds2/taric |
TRADER ALERT A commodity code that was correct before 1 January 2021 under the EU tariff schedule may not produce the same UK duty rate under the UKGT. The six-digit HS subheading will be the same, but the UK national extension and duty rate may differ. Verify all commodity codes against the current UK Trade Tariff, not against historical EU declarations. |
What Changed for Northern Ireland
Northern Ireland operates under a distinct customs arrangement under the Windsor Framework. For goods moving between Northern Ireland and the EU, the EU’s tariff schedule and TARIC codes continue to apply rather than the UK Global Trade Tariff. Northern Ireland traders moving goods to and from the EU must use EU commodity codes for those movements, while UK commodity codes apply to goods moving between Northern Ireland and Great Britain in certain circumstances. The Windsor Framework arrangements are complex and subject to ongoing development.
HMRC Commodity Code Guidance: Official UK Resources
HMRC publishes commodity code guidance through several channels. For most traders, the UK Trade Tariff is the primary resource. For complex classification questions, HMRC’s Tariff Classification Service and Advance Tariff Ruling system provide more formal support.
| Resource | What It Provides | Where to Access |
|---|---|---|
| UK Trade Tariff | The complete UK commodity code schedule for imports (10-digit) and exports (8-digit). Includes duty rates, trade measures, import and export controls, preference schemes, and suspension information. Updated in real time. | trade.gov.uk — select “Import goods into the UK” or “Export goods from the UK”. |
| HMRC Tariff Classification Service | Free written classification advice from HMRC for traders unsure of the correct commodity code. Responses are advisory rather than legally binding, but can demonstrate reasonable care if the code is later questioned. | Contact via HMRC’s online service; search “Get help classifying your goods” on GOV.UK. |
| Advance Tariff Ruling (ATR) | A legally binding commodity code decision from HMRC for a specific product. Valid for three years and provides certainty if the classification is later challenged. | Apply via GOV.UK; search “Apply for an Advance Tariff Ruling”. |
| HMRC Tariff Stop Press Notices | Urgent updates to the UK Trade Tariff issued between scheduled updates. Covers legislative changes, duty rate amendments, and new trade measures that take effect immediately. | GOV.UK; search “UK Trade Tariff: stop press notices”. |
| HMRC Notice 143 (Importing Goods) | Guidance on completing import entries, including commodity code requirements for CDS declarations. | GOV.UK; search “HMRC Notice 143”. |
| HMRC Customs Tariff Vol 2 and Vol 3 | Detailed classification guidance for goods subject to specific regimes, including excise goods, agricultural products, and preference goods. | Incorporated into the UK Trade Tariff online schedule. |
HMRC TIP
When using the UK Trade Tariff search function, always check the ‘Import’ or ‘Export’ tab before searching. The two tabs return different commodity codes (10-digit vs 8-digit) and different duty rates. Starting a search in the wrong tab is a common source of incorrect code selection. |
EU Combined Nomenclature Explained
The EU Combined Nomenclature is the EU’s product classification system for customs purposes. It extends the six-digit international HS subheading with two further EU-specific digits to create an eight-digit code. The CN is the foundation of both EU export classification and the first eight digits of the EU import classification system (TARIC).
The CN is updated annually, typically taking effect on 1 January each year. The European Commission publishes the updated CN in the Official Journal of the European Union. EU member states are legally required to use the current CN for all customs declarations.
CN vs HS vs TARIC: Understanding the Three Layers
The relationship between the HS code, the CN code, and the TARIC code is a source of consistent confusion for traders. All three share the same six-digit HS foundation. What differs is what is built on top of it and for what purpose.
To understand how to read an HS code and its digit structure, see our dedicated guide.
| System | Digits | Who Manages It | What the Extra Digits Do | Used For |
|---|---|---|---|---|
| HS Code (International) | 6 digits | World Customs Organization (WCO) | N/A — this is the international standard used in every country. | International trade statistics and the foundation for all national tariff classification systems. |
| CN Code (EU) | 8 digits (6 HS + 2 CN) | European Commission (DG TAXUD) | Digits 7 and 8 align product classification with EU trade policy and subdivide HS subheadings where different duty rates or measures apply to goods within the same HS subheading. | EU export declarations, the first 8 digits of TARIC import codes, and EU trade statistics. |
| TARIC Code (EU Imports) | 10 digits (6 HS + 2 CN + 2 TARIC) | European Commission (DG TAXUD) | Digits 9 and 10 identify EU-specific trade measures, including anti-dumping duties, countervailing duties, tariff suspensions, tariff quotas, preference schemes, and import licensing requirements. | EU import declarations, determination of duty rates, anti-dumping measures, and quota eligibility for goods imported into the EU. |
A practical example: The HS subheading 6109.10 covers cotton T-shirts at the international level. At the CN level, this becomes 6109.10.00 (the two CN digits 00 indicate no further EU subdivision at this point). At the TARIC level, the code becomes 6109100010 for cotton T-shirts of a specific type, with the final two digits triggering the applicable EU duty rate and any active anti-dumping measures on cotton garments from specific countries of origin.
How the EU Combined Nomenclature is Updated
The CN is revised annually to reflect the WCO’s five-yearly HS updates and to align with EU trade policy changes. When the WCO updates the HS (as it did in 2022 and will do again in 2027), the CN is updated accordingly, and TARIC codes for affected products are revised.
Between annual revisions, the European Commission also publishes TARIC updates to add, modify, or remove trade measures mid-year. Anti-dumping duties, for example, are added to TARIC as they are imposed by EU regulation and may come into effect at any point in the year. Traders importing goods subject to frequent EU trade measures should monitor TARIC regularly.
EU RESOURCE
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Canada Tariff Schedule Explained
Canada’s tariff classification system extends the six-digit HS subheading to a 10-digit tariff classification number. The first six digits are identical to the international HS subheading. Digits seven and eight are Canadian statistical sub-codes used for national trade statistics. Digits nine and ten identify the specific tariff treatment, duty rate, and any applicable trade measure for that product within Canada’s customs framework.
Canada’s national tariff is published in the Schedule of Customs Tariff, managed by the Canada Border Services Agency (CBSA). The CBSA also provides a Canadian Customs Tariff online database and a Tariff Finder tool that allows traders to search for the correct tariff classification number by product description or HS code.
| Feature | Detail |
|---|---|
| Total Digits | 10 digits for imports; 8 digits for exports (Statistical Code). |
| Digit Breakdown | Digits 1–6: International HS subheading. Digits 7–8: Canadian statistical sub-codes. Digits 9–10: Tariff treatment identifier. |
| Primary Tariff Schedule | Schedule of Customs Tariff (Customs Tariff Act, R.S.C. 1997, c.36). |
| Administered By | Canada Border Services Agency (CBSA). |
| MFN Duty Rates | Canada’s Most Favoured Nation (MFN) rates apply to imports from all WTO members, including the UK where no preferential rate is available. |
| UK–Canada Trade Agreement | The UK–Canada Trade Continuity Agreement (TCA) maintained preferential rates from the original EU–Canada CETA after Brexit. A new UK–Canada Free Trade Agreement is currently under negotiation. |
| Tariff Classification Tool | Canada Tariff Finder at tariffinder.cbsa-asfc.gc.ca and the Customs Tariff database at cbsa-asfc.gc.ca. |
| Advance Ruling System | CBSA issues National Customs Rulings (NCRs), the Canadian equivalent of a UK Advance Tariff Ruling, providing binding tariff classification decisions for specific products. |
UK traders exporting to Canada: Under the UK-Canada Trade Continuity Agreement, many UK goods benefit from preferential tariff rates in Canada, provided they meet the applicable rules of origin. The preference claim must be declared on the export documentation and supported by a statement on origin or origin declaration. Using the correct HS subheading is essential to identifying whether a product qualifies for preference and at what rate.
Regional HS Code Systems: Full Comparison Table
The table below provides a reference comparison of how the six major customs jurisdictions relevant to UK traders extend the international HS subheading.
| Country / Region | Code Name | Import Digits | Export Digits | Digits 7-8 | Digits 9-10 | Primary Tool | Administered By |
|---|---|---|---|---|---|---|---|
| United Kingdom | Commodity Code | 10 | 8 | Combined Nomenclature (shared with EU) | UK-specific tariff rate and trade measures | UK Trade Tariff (trade.gov.uk) | HMRC |
| European Union | TARIC / CN Code | 10 | 8 | Combined Nomenclature (EU trade policy alignment) | EU trade measures, including anti-dumping duties, quotas, and suspensions | EU TARIC (ec.europa.eu/taxation_customs) | European Commission (DG TAXUD) |
| United States | HTS Code | 10 | 10 (Schedule B) | US national sub-codes for statistical purposes | Trade measure identifiers, including anti-dumping and safeguard measures | USITC HTS (hts.usitc.gov) | US International Trade Commission (USITC) / U.S. Customs and Border Protection (CBP) |
| Canada | Customs Tariff Number | 10 | 8 (Statistical Code) | Canadian statistical sub-codes | Tariff treatment identifier | CBSA Tariff Finder (cbsa-asfc.gc.ca) | Canada Border Services Agency (CBSA) |
| Australia | Working Tariff (WCO Schedule 3) | 10 | 8 (Statistical Code) | Australian statistical codes | Specific duty rate or statistical suffix | Australian Border Force Tariff (abf.gov.au) | Australian Border Force / Australian Taxation Office (ATO) |
| China | HS / CCC Code | 10 | 10 | Chinese national sub-codes | Statistical and regulatory identifiers | GACC / China Customs Tariff Database | General Administration of Customs of China (GACC) |
KEY PRINCIPLE
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Frequently Asked Questions
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