Category: Automotive

Deep Dive into HS2028 Transition Decisions for Automotive Sensor Groups

Automotive sensors are now at the heart of a vehicle’s added value. However, in trade practice, sensors are prime examples of products whose tariff classification tends to fluctuate. This is because they continuously straddle the boundary between vehicle parts, electrical machinery, measuring instruments, or semiconductor devices.

HS2028 will enter into force on January 1, 2028. When the first six digits of the HS change, there will be cascading impacts on import/export declarations, certificates of origin, internal master data, and item management with trading partners. Sensor groups, in particular, are an area prone to widespread disruption during the transition if classification rationale remains ambiguous.​

This article provides a deep dive into how transition decisions for automotive sensor groups under HS2028 should be approached from management, business, SCM, and trade compliance perspectives, broken down into actionable practical steps. Priority is given to regulatory accuracy, organized based on reliable primary information.

Key Official Timeline for HS2028 to Understand First

HS2028 is not simply about “numbers changing in 2028.” The starting point for preparation is January 2026.​

The World Customs Organization (WCO) provisionally adopted the HS2028 amendment recommendation at the 75th HSC session in March 2025, which was officially adopted at the end of December 2025, to be published in January 2026, and will enter into force on January 1, 2028.​

The WCO is also preparing Correlation Tables between HS2028 and the current HS2022, which will serve as important reference materials for implementation.​

In other words, the realistic battleground for companies is how thoroughly they can finalize classification rationale and master data preparation between 2026 and 2027.

Why Automotive Sensors Are Prone to Classification Fluctuation

Even When You Want to Treat Them as Vehicle Parts, HS Rules May Not Allow It

A common misconception at the operational level is the assumption that “since it’s used in vehicles, it should be vehicle parts (Chapter 87).” However, the HS is not a system determined solely by use.​

Note 2 of Section XVII (Vehicles, etc.) of the HS clearly lists items that are not classified as “parts and accessories,” which includes “electrical machinery of Chapter 85” and “instruments of Chapter 90 (measuring, testing, etc.)”.​

In other words, if a sensor falls under Chapter 85 or Chapter 90, it cannot in principle be classified as vehicle parts, even if it is exclusively for automotive use. This is the fundamental difficulty in sensor classification.​

The Concept of Sensors as Semiconductors Is Already Built into the HS

HS2022 defines “semiconductor-based sensors” within the definition of semiconductor devices. This refers to devices that detect physical or chemical quantities such as pressure, acceleration, magnetic fields, light, humidity, etc., and convert them into electrical signals.​

More importantly, there is a priority rule whereby headings 8541 and 8542 take precedence over other headings for articles falling under these definitions.​

Due to this structure, even with the same term “sensor,” they can branch into:

  • Sensors as semiconductor devices
  • Sensors as measuring instruments
  • Sensors as electrical machinery
  • Sensors as vehicle parts

The transition decision to HS2028 has a high probability of failure if this branching is left unaddressed and replacement is done using only correlation tables.

Aligning the Prerequisites for Transition Decisions

HS2028 compliance is not a code replacement exercise, but an inventory of classification rationale. For sensor groups in particular, aligning the following two items first makes subsequent processes more resilient.

Divide Product Groups into “Elements,” “Modules,” and “Assemblies”

Even when we say automotive sensors in one breath, the form in which they are imported/exported differs. It is here that classification actually changes.

  • Element-leaning: Dies, wafers, items close to packaged ICs
  • Module-leaning: Items including PCBs, connectors, housings, correction circuits, communication interfaces
  • Assembly-leaning: Items integrated with harnesses, brackets, or specific functional units of vehicles

Even for sensors performing the same function, the candidate chapter can change due to these differences in form, which cannot be absorbed by HS2028 correlation tables alone.

Translate Technical Information into “Descriptions for Classification” and Organize

Companies that reach impasses in classification discussions often have design documents but lack descriptions necessary for classification decisions. At a minimum, aligning the following items for each product increases decision speed:

  • Detection target (pressure, acceleration, light, electromagnetic waves, etc.) and detection principle
  • Whether output is electrical signal or data communication
  • Scope of built-in circuitry (signal conversion only, or including computation/control)
  • Implementation form (semiconductor chip, package, board mounting, housing integration)
  • Possibility of diversion to non-vehicle applications (dedicated vs. general-purpose)
  • Components at time of import/export (treatment of accessories, cables, software)

Once this translation is achieved, the applicability of HS Section Notes and Chapter Notes can be logically traced.

HS2028 Transition Decision Framework for Automotive Sensor Groups

This is where the main discussion begins. We structure the HS2028 transition decision to be resilient from both decision-making and implementation perspectives.

Step 1: Classify the Basis of Current Codes

First, classify “why that code” for current HS codes into four categories:

  • Based on written responses or advance rulings from customs
  • Based on official classification examples of similar products
  • Adopted presentations from customs brokers or trading partners
  • Decided by internal company practice

These four carry completely different risks during HS2028 transition. Especially for the latter two, reconstruction of the basis is necessary before applying correlation tables.

Step 2: Converge Issues at the 6-Digit Level First

The HS uses six digits as the internationally common foundation, with countries adding subdivisions below that. HS2028 amendments also change the structure first at the 6-digit level.​

For sensor group transition decisions, it is faster and more reliable to establish the logic of 6-digit classification rather than immediately diving into country-specific subdivisions (such as Japan’s 9 digits). The aforementioned Section Notes become important here. Even if you want to lean toward vehicle parts, you must first acknowledge that they may be excluded if they fall under Chapter 85 or 90.​

Step 3: Use Correlation Tables as a “Starting Point,” Not a “Replacement Table”

The WCO is preparing correlation tables between HS2028 and HS2022, which will serve as important reference materials for implementation.​

However, correlation tables do not guarantee:

  • That the old classification was correct
  • That country-specific subdivisions correspond directly
  • Essential classification judgment for composite products or modules

Therefore, after applying correlation tables, it is practical to keep boundary items within sensor groups as subjects for re-determination.

Step 4: Do Not End Impact Assessment with Tariffs Alone

For business transition decisions, focusing only on tax rates leads to failure. Automotive parts in particular have high EPA utilization rates, and alignment with rules of origin directly impacts profit.

In other words, the HS2028 transition affects not only tariff rate changes but also origin determination logic and agreement version management.​

For Sensor Groups Difficult to Determine, Use Advance Rulings Strategically

Sensors tend to overlap elements of composite products, new technologies, and semiconductor boundaries, and relying solely on internal decisions creates inconsistency. Here, advance rulings from customs become effective.​

Japan Customs provides advance ruling as a system where classification and tariff rates can be inquired about before import and written responses obtained. This makes cost calculation and sales planning easier, and clearance becomes smoother as the tariff number is fixed before declaration.​

Furthermore, written responses are in principle respected for a certain period, and are handled consistently across all customs offices nationwide, providing operational stability.​

For HS2028 transition decisions, not all items need advance rulings. Cost-effective types include:

  • Sensors on the boundary between 8708 (vehicle parts) and Chapters 85/90
  • Products on the boundary between elements and modules (same model number with multiple shipping forms)
  • Products bound for high-tariff countries where rate differences affect profitability
  • Products where EPA applicability determines project profitability

A Practical “Transition Decision” Landing Point for Management and Operations to Agree On

We now translate the discussion so far into decision-making. The key is creating reproducible internal decision criteria rather than finding the correct classification.

Divide Transition Decisions into Three Tiers

Sensor groups have different certainty levels for each product. Dividing decisions into the following three tiers advances decision-making:

  • Confirmed tier: Public basis exists, and smooth transition via correlation tables under HS2028 is highly likely
  • Verification-required tier: Correlation tables can be applied, but boundary issues remain, requiring re-determination
  • External confirmation-required tier: Advance rulings or major country determinations should be obtained

With this classification, company-wide workload and costs can be estimated in 2026.

Dual Master Data Is Often the Realistic Solution

The effective date of HS2028 is January 1, 2028. Since import declarations are in principle made using the latest HS at that point, last-minute bulk updates are risky.​

What is realistic for many companies is to:

  • Maintain current HS (for operations)
  • Maintain next-generation HS (assuming HS2028)

in coexistence in the master data, designed to be selectively used by transaction, country, and timing. This design becomes particularly effective later for origin determinations where HS versions differ by agreement.

Practical Roadmap from 2026

Finally, we make company actions concrete. Aligning with the WCO’s official schedule, 2026 is the starting point for preparation.​

First Half of 2026

  • Thoroughly read WCO-published HS2028 amendment content and identify impact scope for sensor groups
  • Inventory the basis of current classification and separate verification-required and external confirmation-required tiers
  • Begin trial production of primary mapping using correlation tables (provisional)

Second Half of 2026 Through 2027

  • Re-determination of boundary items and documentation of internal classification standards
  • Progress advance ruling acquisition for necessary items (especially high-tariff countries, EPA-critical items)
  • Design dual-code operations for ERP, PLM, trade systems, and customer-submitted documents

Second Half of 2027 Through Just Before 2028

  • Replacement with finalized versions of country-specific subdivisions, final testing
  • Final confirmation of item master matching with trading partners, invoice descriptions, and EDI impacts
  • Operational switchover aligned with effective date

Summary

The greatest danger in HS2028 transition decisions for automotive sensor groups is mechanically replacing via correlation tables and carrying forward the weakness of current classification rationale as-is. Sensors have the structural difficulty of the HS whereby even if they appear to be vehicle parts of Chapter 87, parts treatment can be excluded if they fall under Chapter 85 or 90.​

On the other hand, the timeline is clear. Amendment recommendations will be published in January 2026, entering into force on January 1, 2028.​

During these two years, inventory sensor groups by element/module/assembly, reconstruct them into strongly-grounded classifications, confirm necessary items via advance rulings, and prepare master data and systems for dual operations. This is the transition decision that minimizes losses for both management and operations.

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Spotlight on HS2028 Revisions: Reclassification Risks for Automotive Sensors and Practical Countermeasures

Preparing Now for the Future of Automotive Business

Automotive competitiveness is no longer determined solely by engines or motors. With the advancement of ADAS (Advanced Driver Assistance Systems), autonomous driving, electrification, and connectivity, sensors have become core components that dictate a vehicle’s value.

On the front lines of global trade, however, it is no exaggeration to say that “no item is more prone to HS code fluctuation than sensors.” This volatility is highly likely to surface with the upcoming HS2028 revisions—which is the theme of this article.

In this post, we will look at the overall picture of the HS2028 revisions, delve into why automotive sensors are at the center of reclassification risks, identify where the “landmines” are hidden, and discuss how businesses should prepare from a practical perspective.

What Will Happen with the HS2028 Revisions?

HS revisions are often viewed as a “world for customs practitioners,” but in reality, they trigger a chain reaction affecting tariff costs, FTA rules of origin, internal master data, contract terms, and statistical data. Since the HS serves as the common foundation for global customs and statistical classification—with the framework of Chapters, 4-digit headings, and 6-digit subheadings harmonized internationally—changes at the 6-digit level have a simultaneous global impact.

HS2028 Timeline

The timeline for the HS2028 revision is as follows:

  • March 2025: Provisional adoption of 299 sets of amendments at the 75th session of the WCO (World Customs Organization) HS Committee.
  • Late December 2025: Formal adoption by the WCO Council.
  • January 2026: Official publication of the revised nomenclature.
  • January 1, 2028: HS2028 enters into force (simultaneous global implementation).

The Role and Limitations of Correlation Tables

The WCO maintains Correlation Tables that show the relationship between the current HS2022 and the new HS2028 codes. However, these tables are not a “plug-and-play” solution.

The WCO explicitly states that Correlation Tables are guides to assist implementation and have no legal binding force. More importantly, for items where views currently differ among countries, multiple patterns of correlation may be listed. In other words, for items with high classification volatility, the Correlation Table alone is insufficient for making a final determination.

Why “Automotive Sensors” Are Most Prone to Volatility in HS Revisions

Automotive sensors are particularly difficult to classify because they simultaneously straddle the following three boundaries:

1. Vehicle Parts vs. Electrical Machinery vs. Measuring Instruments

Just because a sensor is used in an automobile does not mean it is automatically classified as a vehicle part (such as heading 8708 in Chapter 87).

Under the Legal Notes of the HS, even if an item appears to be a “part or accessory” of a vehicle, there are provisions that prioritize classification under Electrical Machinery (Chapter 85) or Measuring Instruments (Chapter 90). Specifically, Note 2 to Section XVII (Vehicles, Aircraft, Vessels) explicitly excludes electrical machinery falling under Chapter 85 from the definition of “parts and accessories.”

This puts sensors in a precarious position from the start, as they almost invariably contain electrical/electronic elements and are designed for measurement or detection.

2. Semiconductor Devices vs. Finished Modules

While sensors often contain chips, they are imported and exported in various forms—ranging from “resin-sealed semiconductor elements” to “modules with housings” and “ECU-like units.”

Note 9 to Chapter 85 defines semiconductor-based transducers (including sensors) and stipulates that headings for semiconductor devices (8541 or 8542) should be prioritized if certain conditions are met. Consequently, even for the same application, the classification logic changes depending on the structure and form of the product at the time of import.

This directly impacts the automotive industry, where procurement types—buying “chips only,” “modules,” or “units”—often coexist within the same supply chain.

3. Diversity of Physical Principles: Radar, Optical, Ultrasonic, Inertial, etc.

Even under the umbrella of “sensors,” the candidate Chapters and headings vary depending on the underlying principle. Practical customs rulings show:

  • Radar systems may be classified under 8526 (Radar apparatus, etc.).
  • LiDAR sensors may be classified under 9015 (Surveying instruments, etc.).
  • Ultrasonic sensors for proximity may be classified under 9031 (Measuring or checking instruments, etc.).
  • Camera sensors may be classified under 8525 (Television cameras, etc.).

These cases demonstrate that sensors are judged not by their name, but by “what the device does,” “what principle it uses,” and “to what extent functions are integrated.” HS2028 is specifically designed to incorporate these technological advancements. Items on the borderline are naturally the most susceptible to the waves of reclassification.

Four Patterns of High Reclassification Risk for “Automotive Sensors”

  1. Pattern A: “Mini-Computers” (Sensor + Control + Communication)Radar, LiDAR, and surround-view cameras increasingly integrate signal processing, object detection, tracking, and in-vehicle network communication alongside the sensing element. This raises classification debates: is it a “measuring device,” “radio apparatus,” or “video apparatus”?
  2. Pattern B: Modules with Composite FunctionsIn the case of composite goods, the argument centers on which function gives the product its essential character under the General Rules for the Interpretation (GRI). The quality of technical documentation is decisive here.
  3. Pattern C: Designed for Vehicles, but Unlikely to be Classified as Vehicle PartsAs clearly indicated in Section XVII Note 2, items falling under Chapter 85 or 90 are excluded from the scope of vehicle parts. Treating them uniformly as vehicle parts increases the risk of audit findings.
  4. Pattern D: “Intermediate Forms” Between Chips and Finished ProductsSub-assemblies and PCBA (Printed Circuit Board Assemblies) exist in the “gray zone” between semiconductor-level sensors and housing-integrated measuring instruments. This intermediate form is the most volatile zone for classification.

Business Impact: Reclassification is More Than Just a Cost Issue

Changes in HS codes or their interpretation directly hit profitability in several ways:

  • Tariff Rates and Additional Duty Risks: A code change changes the applicable tariff rate. An increase leads to higher costs, while a decrease necessitates a change in pricing strategy. Furthermore, disputes can escalate into retroactive assessments and penalties.
  • Disruption of FTA Origin Determinations: Product Specific Rules (PSRs) in FTAs are designed based on HS Chapters, Headings, and Subheadings. A 6-digit revision shifts the very foundation of origin determination.
  • Customer Audits and Supplier Management: OEMs and Tier 1s demand consistency in compliance information, including HS codes. Because sensors involve high volumes and granular SKUs, any discrepancy leads to a massive surge in corrective and explanatory workload.
  • Master Data and System Updates: The HS code is a key field in PLM, ERP, customs, procurement, and export control systems. An HS revision should be managed as an IT systems project to be successful.

Practical Actions: “How to Protect Your Sensor Classification” for HS2028

To control reclassification risks, the following sequence is effective:

Step 1: Inventory Sensors by “Principle and Structure,” Not Just “Application”

Maintain data on:

  • Detection Principle: Electromagnetic waves, laser, ultrasonic, acceleration, pressure, temperature, etc.
  • Output: Analog, digital, or specific communication protocols.
  • Signal Processing: Does it perform internal measurement or object recognition?
  • Form: Semiconductor element, PCBA, module with housing, or unit.
  • Inclusions: Treatment of harnesses, brackets, mounts, and software.

Step 2: Maintain “Alternative Candidate Codes” for Current Codes

Since sensors often cannot be uniquely determined, document “candidate codes if contested” and the “reasons for the difference” as internal evidence based on Legal Notes and the GRI.

Step 3: Use Correlation Tables as an “Entry Point for Investigation,” Not a “Replacement List”

As the WCO explains, correlation tables are guides and may show multiple correlations for items with split views. For borderline items like sensors, treating the table as an automatic conversion tool is risky.

Step 4: Anticipate National Implementation Schedules

While the HS is global, each country implements it with its own extended digits (7th digit and beyond). For example, the USITC (U.S. International Trade Commission) is expected to publish a draft in February 2026 and submit a final report to the President in September 2026.

Step 5: Share “Classification Assumptions” with Customers and Brokers

Ensure alignment with external parties. Confirm if customers have specified codes, if the importer’s view is fixed, and what codes have been used in past declarations. Consider seeking Advance Rulings where necessary.

Conclusion: HS2028 Sensor Reclassification is a “Management Issue,” Not a “Technical Task”

With the official publication of HS2028 expected in January 2026 and its entry into force in January 2028, the window for preparation is narrowing.

Automotive sensors straddle three boundaries: vehicle parts vs. electronics, semiconductors vs. modules, and a diversity of physical principles. This makes them the “canary in the coal mine” for HS revision impacts. Treating this as a mere “customs clerical task” will lead to significant rework later.

The optimal solution is to begin building a foundation for classification based on technical data now, and to expand this into master data, contracts, origin determination, and cost management.

Would you like me to create any of the supplementary materials mentioned at the end of the blog, such as the “Inventory Questionnaire” or the “Classification Logic Map (Chapter 85/90/Vehicle Parts)”?