Classification is a legal decision · The order of legal analysis

General Interpretative Rules (GRI)

The six rules that tell you which heading applies when product descriptions, sets or mixtures create ambiguity.

Key facts

GRI 1Classification is determined by the heading text and the section or chapter notes
GRI 2Covers incomplete or unassembled goods and mixtures presented as a set
GRI 3Covers goods that appear to fit more than one heading; essential character and then last in numerical order
GRI 4Covers goods that cannot be classified by the earlier rules; use the most analogous heading
GRI 5Covers cases, containers and packing materials
GRI 6Applies the rules at subheading level, comparing subheadings at the same level
Official sourceWCO HS General Interpretative Rules

Do not jump to essential character

GRI 3(b) is often quoted, but it only applies when the goods cannot be classified by GRI 1 or by the more specific heading rules. If a heading or a chapter note already names the product, the essential-character test is not the starting point.

Write the analysis in order. That order is what a customs auditor or a binding-ruling officer will check.

Sets and kits are a common trap

A set can be classified by the component that gives it its essential character, but the components must meet the set conditions and be put up for retail sale together. A collection of unrelated products in one box is not automatically a set.

If the set changes, re-run the test. Adding a low-value item can change the essential character or the set rule.

Frequently asked questions

Which GRI applies first?

GRI 1. Start with the heading text and the section or chapter notes before using the later rules.

Can I use essential character for any multi-part product?

No. It applies when classification cannot be settled by the earlier rules and the goods qualify as a set or mixture under the relevant rule.

Tell me when the rules change

De minimis thresholds, import tax rates and marketplace fee schedules move more often than most price lists. Leave an address and we will send a short note when one of the tracked markets changes.

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