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HS Codes as the Foundation of Origin Qualification

1. The dependency

Most free trade agreements test origin primarily through a change in tariff classification.

That test is expressed in HS codes. Without an accurate code, the origin test has no input.

2. Change in tariff classification

The non-originating materials used must fall under a different heading or subheading from the finished good, as the agreement specifies.

The levels

Chapter change: first two digits.

Heading change: first four digits.

Subheading change: first six digits.

Which level applies

The product-specific rule for that product decides.

3. Product-specific rules

Each agreement carries a schedule of rules organised by tariff code.

The structure

Product code, then the applicable rule.

The rule may be a change in tariff classification, a regional value content threshold, a specific process, or a combination.

4. How the codes interact with the rules

The finished good’s code selects the rule

The same product under heading A and heading B is tested against different rules, which may give different answers.

The material’s code determines whether the change occurred

Change a material’s classification and the answer may flip.

5. The common errors

Looking only at the finished good’s code and not the materials’ codes.

Building the whole assessment on a wrong classification.

Ignoring exclusions in the notes.

Applying the destination tariff’s rules using the Chinese code.

6. A working sequence

Establish the finished good’s code in the destination tariff.

Read the product-specific rule for that code.

List every non-originating material and its code.

Test whether the required change occurred.

If not, test whether a value-content rule applies instead.

If neither is met, the good does not qualify.

7. Closing view

The code is the foundation. The origin assessment is the building.

If the foundation is wrong, nothing above it stands.

*This article is based on the origin rules of China’s free trade agreements. Exporters should confirm requirements with China Customs and the agreement text.*

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