The three codes at a glance
| System | Length | Legal owner | Where it appears |
|---|---|---|---|
| HS (WCO) | 6 digits | World Customs Organization | Universal — first 6 digits of every national code |
| GTIP (Türkiye) | 12 digits | Ticaret Bakanlığı — Türk Gümrük Tarife Cetveli | Turkish export declaration, ATR, EUR.1 |
| TN VED EAEU | 10 digits | Eurasian Economic Commission | Kazakh, Russian, Belarusian, Kyrgyz, Armenian DT-1 |
| HS China | 13 digits | General Administration of Customs (GACC) | Chinese export declaration, CIQ inspection |
The six General Rules of Interpretation
Every classification dispute we resolve at customs comes back to the six GRIs (Общие правила интерпретации ТН ВЭД) — they are identical in every jurisdiction because they are inherited from the WCO. In practice we apply them in this order:
- GRI 1 — Classify by the terms of the headings and any relative Section or Chapter notes.
- GRI 2(a) — Incomplete or unassembled articles are classified as the finished article if they present its essential character.
- GRI 2(b) — Mixtures and composite goods: classify as if consisting of the material or component that gives essential character.
- GRI 3 — When two or more headings apply: (a) most specific description wins; (b) essential character; (c) last heading in numerical order.
- GRI 4 — If nothing else works, classify by the goods to which they are most akin.
- GRI 5 — Packing materials and containers follow the classification of the goods, unless they are suitable for repetitive use.
Five misclassifications we see every month
- Textile sets (bathrobe + towel + slippers) declared as three separate lines instead of a GRI 3(b) 'set for retail sale' — triples the customs value handling fee.
- Powder coated steel furniture declared under 9403 (furniture, ~15% duty) instead of 7326 (articles of steel, ~5%) when the powder coating is decorative only.
- LED luminaires declared under 8539 (lamps) instead of 9405 (light fittings). EAEU duty differs by ~10 points and the applicable TR CU changes.
- Machinery imported with the tooling in a separate box, breaking GRI 2(a) essential character — the tooling is then hit with full duty as a spare part.
- Cosmetics classified under 3304 (make-up) when they are actually 3306 (oral hygiene) or 3401 (soap). The mandatory State Registration route changes.
Duty, VAT and the FEACN modifier
For Kazakhstan, the applicable import duty rate is set by the Common Customs Tariff of the EAEU (ЕТТ ЕАЭС) against the 10-digit TN VED. On top of the duty, standard 12% VAT (НДС) is applied to the customs value plus duty plus excise. A one-digit classification error at position 9–10 can move a shipment from a 5% duty bracket to a 15% bracket, and the difference is compounded by VAT.
Binding Tariff Information — the pre-shipment shield
Both Kazakhstan (State Revenue Committee KGD) and Türkiye (Bağlayıcı Tarife Bilgisi, BTB) issue advance rulings on classification. The Kazakh ruling — Предварительное решение о классификации — is valid for three years and binds every customs post in the country. For high-value repetitive shipments (>100k USD per container) we always secure one before contract signature. The cost is negligible against a single mis-classified container.