Month: January 2026

++HS2028++　 APIs, Pharmaceutical Formulations, Vaccines, and Healthcare-Related Products Changing Under HS 2028

Vaccines to be subdivided under a new heading; INN implementation to increase practical impact on APIs.

The HS2028, effective January 1, 2028, is an amendment package (299 sets of amendments) compiled by the WCO (World Customs Organization). A distinctive feature is that it explicitly cites “health and pandemic response,” alongside the environment, as a rationale for the amendments. EU explanatory documents also highlight “vaccines and health-related groups (addressing needs underscored by the pandemic)” as a primary objective of these changes.

According to the WCO, the HS2028 Article 16 Recommendation will be formally adopted at the end of 2025, published in January 2026, and enter into force on January 1, 2028. (WCO)

This article organizes the expected impacts on corporate practices regarding APIs, pharmaceutical formulations, vaccines, and healthcare-related products, focusing exclusively on high-reliability primary information.

1. Key Highlight: Human Vaccines Expected to be Subdivided Under an “Independent Heading”

In the current HS, vaccines for human medicine are consolidated into a single subheading, meaning all types of vaccines fall under the same classification. The WTO has explicitly stated that this structure hindered policy responses (targeted tariffs and measures) and statistical monitoring during the pandemic. (WTO)

In response, a joint initiative by the WHO, WCO, and WTO has reported a policy to implement the following revisions in HS2028: (WTO)

  • Establishment of a new Heading 30.07: “Vaccines for human medicine.”
  • Creation of seven categories under this new heading.
  • Subdivisions covering a total of 36 named vaccines for specific diseases.

The WTO reports that the wording for this proposal has been approved by the WCO’s HS Review Sub-Committee and has progressed to the stage of submission to the HSC (HS Committee). (WTO) Furthermore, the WCO has announced that the HS2028 amendment recommendation package was provisionally adopted at the HSC meeting in March 2025, marking the conclusion of negotiations. (WCO)

Given this trajectory, it is reasonable to view the subdivision of vaccine classifications as a definitive change occurring in HS2028.

Impact on Corporate Practice:

  • Redesign of Item Master Data: Internal codes that previously categorized items simply as “vaccines” may now need to be split by disease type. Attribute management—such as product name, indication, dosage form, and cold-chain requirements—will become critical.
  • Strengthened Linkage Between Customs, Statistics, and Regulation: As statistics become more granular, companies must prepare information to explain “why this specific category was chosen” during authorities’ inquiries or internal audits. During the pandemic, the WCO, in cooperation with the WHO, created classification reference materials based on the existing HS to facilitate the cross-border movement of vaccines and related supplies. The HS2028 subdivision is an extension of this effort. (WCO)

2. Changes in Active Pharmaceutical Ingredients (APIs): “Classification Implementation” to Shift Before Code Changes

APIs are fundamentally categorized under Chapter 29 (Organic Chemicals, etc.), while pharmaceutical formulations (medicaments put up in measured doses) fall under Chapter 30. HS2028 will not fundamentally swap this structure.

However, the API sector is entering a phase where “practical impact will increase” due to the following reasons: The WCO announced as an outcome of the 75th HSC session that it has classified 441 items regarding APIs and related substances based on the WHO’s INN (International Nonproprietary Names) list. (WCO)

While this is separate from the HS2028 amendments themselves, it signifies the following for companies:

  • There is a strong global demand for the unified application of classification for APIs.
  • The organization of classifications based on INN will continue, leading to stricter scrutiny regarding product names and ingredient identification.

The WHO continuously publishes recommended and proposed INN lists, which serve as the common language for pharmaceutical naming and supply chains. (WHO) Even if product names are similar, classification may change based on salts, isomers, derivatives, concentration, or mixed states. In practice, regardless of whether a code itself changes, the frequency of rigorous checks by authorities and customs brokers is expected to increase during the transition to HS2028.

Effective Corporate Preparations (3 Key Points):

  • Link INN, CAS, salt form, concentration, and intended use (medicinal vs. research) to the item master.
  • Centrally manage evidence for ingredient identification, such as SDS, CoA, specifications, and manufacturing process summaries.
  • Maintain records of which HS edition (HS2022 or HS2028) was referenced for the classification.

3. Formulations and Healthcare: Increasing “Granularity for Pandemic Response”

EU explanatory documents cite “vaccines and health-related groups (directly addressing pandemic needs)” as a target of the HS2028 amendments.

While it is difficult to exhaustively list exactly which headings or subheadings will be split for pharmaceutical formulations and healthcare products based solely on currently available primary information (details must be confirmed via the HS2028 legal text and correlation tables), companies can identify “high-risk areas” from a practical perspective. The following areas were prone to becoming bottlenecks during pandemic responses: (WCO)

  • Vaccines themselves (lack of classification granularity).
  • Consumables for injection/vaccination (needles, syringes, etc.).
  • Storage and Transport (cold-chain equipment, etc.).
  • Diagnostics and Testing items (reagents, test kits, etc.).

Therefore, for the HS2028 transition, companies should anticipate that classifications and explanatory notes will be adjusted to ensure “healthcare-related items can be tracked for policy and statistical purposes.”

4. Business Practice Checklist

Reducing immediate actions to minimum steps:

  • Categorize Target Items into Three Groups:
    • Vaccines (Human, Veterinary, Research).
    • APIs (Pharmaceutical ingredients with INNs, including biopharmaceutical raw materials).
    • Healthcare-related (Diagnostics, vaccination consumables, storage/transport, medical devices).
  • Add Data Fields for Vaccines Assuming the “30.07 New Establishment”:
    • Prepare attributes capable of withstanding future subdivision, such as disease category and product type.
    • Identify connection points between internal statistics, import/export permits, and labeling. (WTO)
  • Maintain “Evidence of Ingredient Identification” for APIs:
    • Manage INN, CAS, salt form, concentration, use, SDS, CoA, and specifications as a set.
    • Always keep a “Classification Rationale Memo” (ensuring traceability for future explanations). (WCO)
  • Prepare for Dual Management of HS2022 and HS2028:
    • Manage the HS version switchover date (January 1, 2028).
    • Maintain history based on Item IDs so that bulk replacement can be performed once correlation tables are released. (WCO)

Summary

The most significant change in the pharmaceutical and healthcare sector under HS2028 is the creation of an independent heading and the subsequent subdivision of human vaccines. The WTO reports progress on a proposal to establish the new Heading 30.07, specifying 7 categories and 36 vaccines. (WTO)

Regarding APIs, the WCO is advancing the classification of numerous substances based on the WHO’s INN list. Even before code changes occur, the “stricter enforcement of classification application” will dictate corporate burden and risk. (WCO) For healthcare-related products, official documents indicate a shift toward making essential pandemic-response supplies traceable for policy and statistics.

The ultimate winning strategy is to conduct an early item inventory: rebuild masters for vaccines assuming increased granularity, and organize ingredient identification and evidentiary trails for APIs. These steps alone will establish a resilient system that “does not stop” during the 2028 transition.

Thailand HS Code Rigidity for Electronics Parts

When Thai Customs is reported to be “tightening the interpretation of HS codes for electronic equipment parts,” the two most important practical risk points are these:

  1. More requests for supporting documents at the time of import clearance, which slows down the initial clearance process.
  2. More post-clearance reclassification findings, which can lead to retroactive duty assessments and a heavier administrative burden.

In Thailand, differences in tariff classification have long been a common trigger for downstream impacts such as FTA eligibility and additional payments. JETRO has noted cases where an HS difference was pointed out at import clearance or during post-clearance audits, resulting in retroactive liabilities.
In recent years, authorities have also been upgrading digital controls and audit sophistication, moving toward stricter verification of declarations including HS codes. PwC Thailand likewise describes a tightening environment where post-clearance audits and AI-enabled enforcement are being strengthened.

Below is a professional HS-code perspective focused on electronic parts: what is likely changing, why this category is singled out, and how companies should prepare.

  1. What “tightening” means in practice: what changes on the ground

When the headline says “tightening of HS-code interpretation,” the operational changes typically fall into three patterns:

  1. More evidence requests at the declaration stage
    If invoice descriptions are generic, intended use is unclear, or specifications are insufficient, Customs is more likely to demand additional documents such as catalogues, spec sheets, photos, material composition, or functional descriptions. This trend is not limited to large shipments. In the small-parcel domain, Japan Post warns that, for Thailand-bound items from January 1, 2026, electronic customs data requirements are strengthened, and incomplete or inaccurate data increases the risk of delays or returns (with a recommendation to provide 6-digit HS and detailed descriptions).
  2. Stricter line drawing between parts, finished goods, and multi-function units
    Because electronics are increasingly modular, an item that a shipper calls “just a part” may be evaluated as a unit that completes a specific function. Once Customs begins applying stricter tests here, the impact is not limited to HS codes. It can cascade to permits, duty rates, and FTA application practice.
  3. More post-clearance re-determinations
    Thai authorities have been strengthening post-clearance frameworks, aiming for faster front-end processing while applying more rigorous checks after release.
    In this setting, companies with continuous imports of the same items face the greatest exposure, because findings can affect multiple past entries.
  1. Why “electronic equipment parts” are frequently targeted

Electronic parts have the characteristics that make tariff classification disputes more likely:

  • Rapid product diversification and short lifecycle changes in function and structure
  • Blurred boundary between parts and finished goods (modules, assemblies, kits)
  • Frequent chapter-boundary issues (for example, between Chapter 84, 85, and 90)
  • HS differences often spill over into regulation (permits, standards, controls) and FTA execution, not just duty rates

In addition, concerns such as “HS interpretation varies by officer” and “lack of transparency in classification criteria” have repeatedly surfaced in Japan’s external requests and business feedback related to Thailand.

  1. Common classification flashpoints for electronic parts: practical landmines

The goal here is not to assert a specific HS number, but to identify the exact questions Customs is likely to ask and to neutralize them in advance.

Issue A: Can it be accepted as “parts”
Checklist points

  • Is the item solely or principally used with a specific machine or apparatus?
  • Does it perform an independent function by itself (measuring, converting, communicating, controlling, etc.)?
  • Does it contain software and complete a specific function as a standalone unit?
  • Does it have a strong finished-goods character in appearance (housing, display, I/O, power, etc.)?

Evidence to prepare

  • Materials that identify use clearly (host equipment model, drawings, mounting location, BOM position)
  • Documents showing the scope of standalone function (specs, block diagrams, input/output specs)
  • Explanation of whether it is a general-purpose commercial item or a dedicated part

Issue B: Essential character or principal function for multi-function goods
Checklist points

  • If multiple functions exist, what is the principal function?
  • Which components support that principal function (value, volume, role)?
  • Is there a measuring function, a control function, or only signal conversion?

Evidence to prepare

  • Functional description (what it takes in, what it does, what it outputs, what it achieves)
  • Bill of materials or major component list (key ICs, sensor elements, power, communications, etc.)
  • Operating modes and realistic use cases

Issue C: HS mismatch risk for clearance and FTA
JETRO notes that Thailand frequently sees cases where the HS code stated on the certificate of origin is treated as inconsistent with the HS classification determined by Customs at import, resulting in denial of preferential FTA rates.
In a tightening phase, the frequency of such mismatches typically increases.

Evidence to prepare

  • A mapping between the HS used for FTA purposes (agreement baseline year and digit level) and the HS used for current tariff schedules in import clearance
  • An agreed HS-position memo with the importer in Thailand
  • A classification rationale record (the dossier described below)
  1. The minimum “classification dossier” set companies should build now

Companies that get stuck most often treat the HS code as a number, not as a decision record. Under tightening conditions, what works is a basic dossier like this:

  • Product overview: intended use, host equipment, photos
  • Functional description: input, processing, output, principal function
  • Specifications: electrical specs, communication specs, measuring ranges, etc.
  • Composition: major components, presence of PCB assemblies, software embedded or not
  • Classification logic: decision branches and why the conclusion follows (an internal memo is acceptable)
  • Transaction reality: invoice descriptions, part-number logic, packaging form, whether it is a set
  • Operational history: past declarations, inquiries, returns, and reclassification history

JETRO recommends using advance ruling systems, while noting that lead times can be significant depending on the case.
Therefore, even while waiting for an official response, the priority is to make sure you can meet the company’s burden of explanation at the border and during audits.

  1. What to do when a dispute arises in Thailand: do not stop shipments, do not let it escalate
  1. First, define the exact classification dispute point
    Companies that get drawn into long back-and-forth often fail to articulate the dispute. Is it parts vs finished goods? Is it the principal function? Is it a chapter boundary? You should be able to summarize the dispute in a one-page brief.
  2. Move early to advance rulings or the relevant consultation route
    In Thailand, there are operational routes where the importer can request confirmation of tariff classification interpretation from Customs in relation to the import process.
    Do not keep it internal. Build a coordinated approach involving the importer and customs broker.
  3. Prepare options to avoid holding cargo even while classification is unresolved
    Even when classification is disputed, a release mechanism can exist via a guarantee deposit or similar security, with the final conclusion handled later. Thai e-import procedure materials also discuss handling for disputes, including security and objection processes.
  1. Conclusion: winners under tightening conditions hold “rationale,” not just “numbers”

For electronic parts, technological evolution increases ambiguity, while Customs authorities raise the bar for explanation through digitalization and stronger post-clearance capability.
The fastest way to close that gap is to build classification dossiers and proactively address the parts test, multi-function logic, and chapter-boundary issues.

Tightening can also become a chance to raise predictability for well-prepared companies. To prevent clearance stops, avoid retroactive assessments, and protect FTA benefits, start by reviewing your top electronic-part SKUs and rebuilding the classification rationale from the ground up.

++HS2028++　 Plastic Waste and Recycling Changing Under HS 2028

Major Restructuring of Heading 3915 and Practical Impacts Including Collection Infrastructure Equipment

HS 2028, scheduled to take effect on January 1, 2028, comprises 299 sets of amendments compiled by the WCO (World Customs Organization). The amendment themes explicitly include enhanced monitoring for environmental and enforcement purposes, with the most prominent examples being plastic waste (heading 3915), single-use plastics, and equipment related to collection and sorting.wcoomd​

This article organizes, from a business perspective, what will change under HS 2028 and how it will impact corporate operations.

1. Why Are HS Codes for Plastic Waste Undergoing Major Changes Now?

The background lies in the Basel Convention’s plastic waste amendments. Adopted in 2019 and effective from January 1, 2021, new categories (A3210, Y48, B3011) came into force. The key point is that the scope of the Prior Informed Consent (PIC) procedure for transboundary movements of plastic waste has been clarified.wcoomd+1​

In particular, B3011—which may be exempt from PIC—covers “exclusively one non-halogenated polymer” or “mixtures of PE, PP, and PET (under certain conditions),” subject to requirements such as being almost free from contamination, free from other types of wastes, and destined for environmentally sound recycling.basel+1​

Under HS 2028, this framework is being substantially subdivided on the HS code side (3915) to facilitate classification by hazardousness, polymer type, and mixture composition for customs purposes.wcoomd​

2. The Core of HS 2028: Heading 3915 Redesigned by “Hazardousness” and “Material Type”

Under HS 2028, heading 39.15 (waste, parings, and scrap of plastics) is essentially being rebuilt. The broad framework consists of three tiers.wcoomd​

2-1. 3915.40: Carving Out Hazardous Plastic Waste

Subheading 3915.40 covers only plastic waste that “contains certain hazardous substances and exhibits hazardous characteristics,” as defined by a new subheading note. The note enumerates examples such as heavy metals and organic halogenated compounds, as well as hazardous characteristics including explosiveness, flammability, corrosiveness, acute toxicity, and ecotoxicity.wcoomd​

In practice, this is a domain where supporting documentation such as SDS (Safety Data Sheets), analyses, and contamination/additive information will be strongly required for import/export of waste.

2-2. 3915.51–3915.59: Non-Halogenated, Single-Polymer Waste with Low Contamination Classified by Polymer

Under HS 2028, single-material non-halogenated polymer waste (almost free from contamination and other types of wastes) is subdivided by material type. Representative examples are as follows:wcoomd​

  • 3915.51: Polyethylene-based
  • 3915.52: Polypropylene-based
  • 3915.53: Styrene-based
  • 3915.54: ABS
  • 3915.55: PET
  • 3915.56: Polycarbonate
  • 3915.57: Polyether
  • 3915.58: Urea resins, phenolic resins, melamine resins, epoxy resins, alkyd resins
  • 3915.59: Other

This reflects the philosophy aligned with Basel Convention entry B3011’s condition of “single polymer and almost free from contamination”.basel​

2-3. 3915.61, 3915.62, 3915.69: Clear Separation of Halogenated and Fluorinated Polymers

Waste containing halogenated polymers is organized separately. Items exclusively of PVC (3915.61), manufacturing scrap of certain fluorinated polymers (3915.62), and others are specified, with the remainder classified under 3915.69.wcoomd​

2-4. 3915.91: Mixtures of PE, PP, and PET (Under Conditions) as a Standalone Code

Mixtures consisting solely of PE, PP, and PET that are almost free from contamination and other types of wastes are classified under 3915.91. Others fall under 3915.99.basel​

A critically important element is the subheading note rule: “Mixed waste of physically separable dissimilar polymers” is explicitly stated as being classifiable only under 3915.40, 3915.69, 3915.91, or 3915.99—not under single-polymer categories.wcoomd​

This means that the common field practice of “forcing classification by predominant material even when mixed” will face constraints.

3. Beyond “Waste”: Definition and Code Provisions for Single-Use Plastics

Under HS 2028, a definition of “single-use” is introduced in Chapter 39, and subheading provisions are being developed with monitoring of single-use plastics in mind. The definition encompasses items that are normally discarded or recycled after a single use and are not intended for repeated or long-term use.wcoomd​

Specific examples include single-use drinking straws explicitly listed under 3917.24 or 3917.34, with single-use categories also added for packaging containers (3923) and tableware (3924).wcoomd​

This means that product manufacturers may face operational requirements to distinguish “single-use or not” by tariff code, making code management for products—in addition to waste (3915)—a subject for review.

4. Recycling-Related Equipment Also Affected: Reverse Vending Machines Clarified in the HS

Reverse vending machines used for deposit collection are also being clarified under HS 2028. The heading text for 84.76 now explicitly includes “reverse vending machines,” and a dedicated subheading 8476.30 is being created. It is stated that machines with sorting, compacting, and storage components attached are also covered.freightamigo​

For companies manufacturing or importing/exporting reverse vending machines, and for retail and beverage companies deploying equipment overseas, the standardization of tariff codes provides stability for contracts and customs clearance. However, if previously classified differently, master data revisions will be required at the time of transition.

5. Translating Impacts on Corporate Operations into Field-Level Language

5-1. As HS Codes Become More Granular, Required Evidence Becomes More Granular

Classification under 3915 will no longer pass on “self-declaration of material” alone. Determining whether something is single-polymer, mixed, halogen-containing, or has hazardous additives or contamination will require specifications, analyses, and process information.wcoomd​

5-2. Basel-Related Import/Export Operations Become More Directly Linked to Tariff Codes

Under the Basel Convention, even for B3011—which may be exempt from PIC—conditions such as “environmentally sound recycling” and “almost free from contamination” are explicitly stated. The subdivision of tariff codes serves as a practical tool for implementing these conditions in customs operations.basel​

While import/export regulations vary by country and are not uniform, at minimum, “changes in tariff codes may change permit requirements or scrutiny points” becomes a coordination topic between legal/environmental departments and customs departments.basel​

5-3. Ripple Effects on Contracts and Costs

When tariff codes change, risks of customs holds, additional analysis costs, re-sorting costs, and return shipping cost burdens materialize. Waste and scrap transactions often have low unit prices, and even minor additional costs can disrupt profitability.

6. Preparatory Actions You Can Start Now

The following are responses for plastic waste and recycling-related items, listed in order of practical effectiveness.

6-1. Change the Approach to Product Inventory

  • Reclassify transactions currently under 3915 into four categories: single-polymer, mixed, halogen-containing, and suspected hazardous
  • Clarify relevant departments (customs, environmental, legal, sales) for permits and notifications by import/export countrywcoomd​

6-2. Establish a Minimum Set of Supporting Documentation

  • Evidence of polymer type (process, material certification, analysis)
  • Rules for managing contamination/mixing (receiving inspection, sampling, storage methods)
  • Verification of recycling destination existence and processing content (contracts, processing flow, receipt records)basel​

6-3. Redesign Master Data and EDI for the 2028 Transition

  • Design item fields to retain both HS 2022 and HS 2028 (switching by effective date)
  • For 3915, include fields for material type, halogen presence/absence, mixing permissibility, and hazardous flag
  • Conduct inventory of applicable part numbers for equipment systems such as reverse vending machines (8476.30, etc.)freightamigo​

Conclusion

Under HS 2028, plastic waste (3915) is being redesigned by “hazardousness,” “polymer type,” and “mixture composition,” with the introduction of single-use plastic definitions and clarification of reverse vending machines.wcoomd+1​

This is not merely a matter of more codes being added; it signifies that transaction processing is shifting toward “classification accompanied by evidence.”

Waste and recycling do not end with customs alone. It is prudent to involve environmental, legal, procurement, and field operations, and to begin inventory and documentation design now—without waiting for 2028.

  1. https://www.wcoomd.org/en/media/newsroom/2025/april/hsc-provisionally-adopts-the-recommendation-for-hs-2028-amendments-at-75th-session.aspx
  2. https://www.wcoomd.org/en/media/newsroom/2020/december/new-international-rules-for-import-and-export-of-plastic-waste-come-into-effect-on-1-january-2021.aspx
  3. https://www.basel.int/implementation/plasticwaste/plasticwasteamendments/faqs/tabid/8427/default.aspx
  4. https://www.basel.int/implementation/plasticwaste/amendments/overview/tabid/8426/default.aspx
  5. https://www.wcoomd.org/-/media/wco/public/global/pdf/events/2022/greener-hs/session-4/1_tess_the-hs-and-plastic-pollution.pdf?la=en
  6. https://www.freightamigo.com/en/blog/hs-code/hs-code-for-vending-machines/
  7. https://www.wcoomd.org/en/media/newsroom/2024/july/amendment-to-the-recommendation-to-facilitate-the-collection.aspx
  8. https://www.env.go.jp/recycle/yugai/law/Summary_of_Import_Regulation_of_Plastic_Waste_in_Asian_Countries.pdf
  9. https://www.epa.gov/hwgenerators/new-international-requirements-export-and-import-plastic-recyclables-and-waste
  10. https://www.seair.co.in/hs-codes/heading-8476-goods-vending-food-beverage-machines.aspx
  11. https://www.basel.int/Portals/4/download.aspx?d=UNEP-CHW-ENFORCE.6-3.English.pdf
  12. https://www.wcoesarpsg.org/wp-content/uploads/2025/06/Conclusion-of-the-75th-Session-of-the-Harmonized-System-Committee-and-the-Provisional-Adoption-of-the-HS-2028-Amendments.pdf
  13. https://records.hawaiicounty.gov/WebLink/1/edoc/111073/21-05-26%20EMC%20-%20Basel%20Convention-Brochure-PlasticWasteAmendFAQs-2021.English.pdf
  14. https://www.credlix.com/hsn-code/8476
  15. https://www.oecd.org/content/dam/oecd/en/publications/reports/2024/04/monitoring-trade-in-plastic-waste-and-scrap_0c401097/013bcfdd-en.pdf

Key Updates on HS 2028 and Classification: A Business Guide for 2026

HS 2028 is moving from policy development into practical implementation, and classification work is accelerating in parallel. For business teams that depend on stable product nomenclature for trade, compliance, data, and reporting, 2026 is the year to start disciplined HS 2022 to HS 2028 mapping and to monitor national tariff schedule updates with a clear internal process.

This article translates the update into an executive-ready roadmap, grounded in official publications from the World Customs Organization and the U.S. International Trade Commission, plus EU public materials on the HS Recommendation and modernisation agenda. (World Customs Organization)

  1. What HS 2028 is, in one sentence, and why it matters outside Customs

The global Harmonized System is not only a Customs tool; it is the international product naming system used to categorize and monitor global trade in goods. National classification systems across countries and economic unions are based on it. When HS changes, national tariff schedules and related classification infrastructure must align, and businesses feel the impact through reclassification work, documentation, and operational change. (USITC)

  1. Where HS 2028 stands today: the official timeline

The World Customs Organization reported that the Harmonized System Committee provisionally adopted the Article 16 Recommendation that will form the new 2028 edition of the Harmonized System. The same WCO announcement states the sequence clearly: after formal adoption at the end of December 2025, the Recommendation will be made public in January 2026 and go into effect on 1 January 2028. (World Customs Organization)

For business planning, this creates a practical window:

  • January 2026: the Recommendation is expected to be made public, and national implementation work accelerates.
  • 2026 to 2027: national tariff schedules, internal master data, and broker systems prepare and test.
  • 1 January 2028: HS 2028 goes into effect. (World Customs Organization)
  1. The classification signal inside the HS 2028 update: not an “HS-only” event

The reason the email paired HS 2028 with “Classification” is that classification guidance is not static, and the WCO committee output shows continuous movement even before the 2028 edition takes effect.

At the 75th session (10 to 21 March 2025), the WCO reported results that matter for companies tracking classification stability:

  • 66 classification decisions
  • amendments to HS 2022 Explanatory Notes
  • new Classification Opinions
  • and the HS 2028 amendments package described as 299 sets of amendments, alongside amendment proposals and amendments to Explanatory Notes. (World Customs Organization)

Then, at the 76th session (September to October 2025), the WCO again reported classification outputs and, importantly, moved into the implementation tooling phase for HS 2028:

  • 40 classification decisions
  • amendments to HS 2022 Explanatory Notes
  • creation of new Classification Opinions and deletion of existing Opinions
  • initiation of discussions on the development of Correlation Tables between HS 2028 and HS 2022 editions, and an improved format for clarity and usability
  • explicit positioning of those tables as an essential reference tool for effective implementation of HS 2028 amendments
  • and a next session scheduled for March 2026 at WCO Headquarters. (World Customs Organization)

Business takeaway: HS 2028 readiness is not only a future cutover. Classification guidance and correlation work are actively evolving, and these outputs shape how “correct and uniform application” is achieved in practice. (World Customs Organization)

  1. What changed in HS 2028, at the strategic level: why the amendments exist

EU public materials summarise the intent behind HS 2028 changes in business-friendly terms. The HS amendments are described as reflecting the evolution of trade patterns, development of new technologies, and the need to modernise or adapt the nomenclature to address social, environment, and security concerns, including simplification by deleting low-volume headings and updates that support control and monitoring of particular products. (EU Monitor)

You do not need to know every technical amendment today to act. What you do need is a governance approach that assumes:

  • product scope definitions may shift
  • headings and subheadings can be deleted or reorganised
  • new technologies can trigger new classification logic
  • and control and monitoring priorities can increase scrutiny in targeted areas. (EU Monitor)
  1. The most practical instruction from the email: begin mapping HS 2022 to HS 2028

Mapping is not a cosmetic exercise. It is the backbone of:

  • reclassification decisions
  • tariff schedule alignment in each country
  • internal master data and downstream reporting stability
  • and broker and partner data exchange.

The WCO has already framed Correlation Tables as essential reference tools for effective implementation. (World Customs Organization)

In the United States, the USITC began the process to modify the Harmonized Tariff Schedule of the United States to align it with amendments to the global HS. It expects preliminary draft modifications for public comment in February 2026 and a report to the President in September 2026. (USITC)

The formal notice for the USITC investigation also sets out a schedule that includes January 2026 posting of the WCO Recommendation on the Commission’s website, February 2026 posting of proposed recommendations, and September 2026 transmittal of the report to the President. (USITC)

Business takeaway: if your business has meaningful U.S. import or export exposure, February 2026 is not just a date on a calendar. It is a likely external milestone where draft classification structure changes become visible for review, comments, and internal testing. (USITC)

  1. A 2026 action plan for businesses: how to turn “updates” into execution

Below is a practical sequence you can run as a cross-functional initiative. It is written for business operators who need an implementable plan, not only technical background.

Step 1: Build a controlled HS 2022 baseline
Create a single internal view of:

  • products and goods descriptions used for trade
  • current HS 2022 codes used in declarations, reporting, or systems
  • internal owners for each product group
  • classification rationale and supporting documentation.

Your objective is not perfection; it is traceability. When HS 2028 changes arrive, you need to know which internal records will move.

Step 2: Establish an HS 2022 to HS 2028 mapping workstream
Use Correlation Tables and related WCO materials as they develop, and define your internal method for:

  • mapping logic
  • exception handling for unclear cases
  • and decision escalation.

Because the WCO itself emphasises correlation work as a tool for effective implementation, treat the mapping as a controlled project deliverable, not an informal spreadsheet task. (World Customs Organization)

Step 3: Create a monitoring routine for national tariff schedule updates
HS is global, but tariff schedules are national. The “watch national tariff updates” instruction is a reminder that the operational impact becomes real as each administration publishes its aligned nomenclature and schedules.

For the United States, align your monitoring cadence with the USITC dates: February 2026 for preliminary draft modifications and September 2026 for the report to the President. (USITC)

Step 4: Test your data and reporting dependencies
Even if your trade team handles declarations through a broker, your business likely uses HS-based groupings in:

  • trade reporting
  • product analytics
  • compliance screening workflows
  • or master data structures.

Run a controlled test with mapped HS 2028 codes to identify where reporting breaks, where categories change, and where systems assume fixed code lengths or fixed hierarchies.

Step 5: Coordinate with brokers and partners early
The WCO and USITC materials show that multiple authorities and stakeholders are involved. The practical effect is that your brokers, forwarders, and internal systems teams will be doing similar alignment work. Synchronise:

  • when you will start using mapped codes in test environments
  • how changes will be communicated to operations
  • and what evidence you will retain for classification decisions.
  1. Why “origin” often appears in the same message as HS and classification

Many businesses experience HS and origin as a combined operational reality: classification and origin-related processes are both core to trade compliance and to efficient procedures under trade agreements.

The WCO is actively running global forums focused on origin self-certification, with an explicit theme of building trust and compliance, and a focus on simplifying trade procedures, boosting efficiency, enhancing compliance, and strengthening global value chains. (World Customs Organization)

Separately, the WCO also published an Interconnectivity Framework for Certificates of Origin to align platforms supporting electronic Certificates of Origin exchanges with protocols, standards, and guidelines, highlighting digitalization, interoperability, and efficient, transparent, and secure trade under Free Trade Agreements. (WCO News)

Business takeaway: if your email bundled HS 2028, classification, and origin guidance, that is consistent with the direction of travel: more standardisation, more digital exchange, and more emphasis on clear guidance and compliance mechanisms across borders. (World Customs Organization)

  1. What to watch next, in plain terms

If you want a short list of official signals that indicate when to accelerate internal work, these are the most practical ones.

  • WCO outputs on Correlation Tables between HS 2028 and HS 2022, and any format changes aimed at clarity and usability. (World Customs Organization)
  • Continued WCO classification decisions, Explanatory Notes amendments, and Classification Opinions, which influence interpretation and application. (World Customs Organization)
  • U.S. milestones: preliminary draft modifications for public comment in February 2026, and the report timeline in September 2026. (USITC)
  • EU public positioning on HS modernisation and the 1 January 2028 entry into force. (Taxation and Customs Union)

Conclusion

The message in today’s email can be summarised in operational terms: do not wait for 2028 to start acting. The official record shows HS 2028 is on a defined path to go into effect on 1 January 2028, while classification decisions and correlation work are already active and visible through WCO outputs. (World Customs Organization)

For businesses, the most valuable next step is disciplined execution: establish a clean HS 2022 baseline, begin HS 2022 to HS 2028 mapping using correlation tools, and monitor national tariff schedule updates with the same seriousness you apply to other core operational changes.

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.

​

No More Getting Lost in the Labyrinth of “Notes”: Transform HS Code Classification into an “Expert Consultation”

Today, we conducted a demonstration of HSCF, our HS code classification support system, for a group of Japanese companies.

With participants joining from multiple departments, we performed trials using their actual business cases. What this session highlighted once again was the sheer intensity and difficulty of HS code classification.

■ The Struggle: Wrestling with Fine-Print “Notes”

Until now, our clients have been navigating a mountain of “Section and Chapter Notes,” piecing together answers like a complex puzzle. Their heartfelt comment—”It’s just so complicated and exhausting”—left a lasting impression on me.

■ A “New Experience” Proposed by HSCF

During the demo, there were moments where the initial data provided was insufficient for a definitive classification. This is where HSCF truly shines.

By simply providing a quick supplement to the missing information in plain language, the system immediately re-evaluated and updated the results.

HSCF is not just a “mechanical tool” that spits out results from data entry. It facilitates a process of “reaching the right answer by ‘consulting’ an expert while filling in the blanks.” I truly believe this human-like interaction is what makes it so intuitive and user-friendly.

■ We’ll Walk with You Until You’re Fully Satisfied

Since we do not offer standalone trial licenses, we are committed to providing as many demonstrations as you need until you are completely convinced of its value.

What the WCO’s Article 16 Recommendation for HS 2028 Contains: A Business-Focused Brief

When people hear “HS 2028,” many assume it is a distant topic. In reality, the key document defining the HS 2028 change set is the HS Convention Article 16 Recommendation, recently adopted through the World Customs Organization (WCO) process. For companies, this Recommendation is the critical trigger to begin impact analysis on product master data, customs clearance, duty planning, FTA/EPA usage, and compliance documentation.

This article summarizes the HS 2028 Article 16 Recommendation package based on official sources. For a detailed, code-by-code list, consult the draft Recommendation itself (identified in EU documents as Annex Q to Document NC3358Ba / Report HSC/75, March 2025).

1. The “Article 16 Recommendation” Package: Scope and Scale

At the 75th Session of the Harmonized System Committee (HSC) (March 10–21, 2025), the committee provisionally adopted the Recommendation for HS 2028 amendments. The WCO describes this as a comprehensive package comprising all 299 sets of amendments agreed upon during the 7th Review Cycle.

According to official WCO announcements, the HS 2028 package consists of:

  • 105 amendment proposals (covering specific nomenclature changes)
  • 5 amendments to the Explanatory Notes
  • A total of 299 sets of amendments forming the core of the HS 2028 update.

Practical Note: While the HSC also produced various classification decisions during the 75th session, these are separate from the Article 16 Recommendation package, which focuses specifically on the legal amendment of the HS Nomenclature.

2. Strategic Objectives: Beyond Simple Renumbering

The HS 2028 amendments are designed to reflect modern global priorities. According to the EU’s explanatory memorandum, the package aims to:

  • Adapt to New Technologies: Reflect evolving trade patterns and innovations (e.g., E-bikes, drones).
  • Address Social & Environmental Concerns: Modernize the nomenclature to help authorities monitor specific products like plastic waste.
  • Simplify the Nomenclature: Delete headings and subheadings with low trade volume to reduce administrative burden.
  • Enhance Alignment: Better align the French and English versions to reduce divergence in global classification outcomes.
  • Enforcement: Strengthen the fight against fraud and illegal trade, particularly in the health and environmental sectors.

3. Key Changes by Business Theme

Based on official scoping, companies should prepare for impact in the following high-priority areas:

3.1 Environment and Circular Economy

  • Focus: Plastic waste provisions, rubber powders from end-of-life tires, and glass fiber waste.
  • Equipment: Introduction of specific codes for reverse vending machines (used in recycling collection).
  • Impact: Expect tighter definitions and more granular subheadings for scrap, recyclates, and secondary raw materials.

3.2 Public Health and Medical Supply Resilience

  • Focus: Vaccines and health-related goods, responding directly to needs highlighted by the global pandemic.
  • Impact: Refined structures for better monitoring and policy reporting, requiring companies to maintain precise product descriptions and composition details.

3.3 Food and Agriculture

  • Focus: Food fortification mixes and food supplements.
  • Impact: These categories often sit on the boundary between “food preparations” and “medicaments.” Increased scrutiny and potential reclassification are likely.

3.4 Technology Transitions

  • Focus: E-bikes, semiconductors, transducers, cleaning robots, and drones.
  • Impact: Even if 6-digit headings remain the same, changes in boundary logic and definitions can shift national-level (8, 9, or 10-digit) duty rates and regulatory requirements.

3.5 Security and Enforcement

  • Focus: Illicit manufacture of drugs and fraud prevention.
  • Impact: Chemical precursors and dual-use adjacent items may be restructured to improve visibility for enforcement agencies, requiring stronger classification documentation from legitimate businesses.

4. Process and Timing: The Road to 2028

The legal mechanism under the HS Convention follows a strict timeline:

MilestoneDate / Detail
HSC 75th MeetingMarch 10–21, 2025: Recommendation finalized.
WCO Council AdoptionJune 2025: Expected formal adoption of the Article 16 Recommendation.
Objection Period6 months following notification: Amendments are deemed accepted if no Contracting Party objects.
Entry into ForceJanuary 1, 2028: The revised HS Nomenclature becomes legally binding globally.

5. Recommended Actions for Global Trade Teams

A business-ready HS 2028 program should start with targeted scoping rather than a full reclassification.

  1. Build a Product Inventory: Anchor your list on current HS 2022 6-digit codes, including product function and composition.
  2. Flag High-Risk Products: Identify items in the focus areas mentioned above (e.g., heat pumps, semiconductors, food supplements, and plastic recyclates).
  3. Monitor Correlation Tables: Prepare to map HS 2022 codes to HS 2028 as soon as official correlation tools and national tariff schedules are released.
  4. Align Master Data: Ensure your ERP, logistics systems, and customs broker instructions are updated in sync with the 2028 cutover.

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Official Timeline for HS 2028 Adoption and Correlation Table Development

Strategic Roadmap for Enterprise Readiness based on WCO Procedures

Preparing for HS 2028 is not merely about updating a code list. It is a comprehensive enterprise-wide project that triggers a chain reaction across customs clearance, tariff management, Rules of Origin (RoO), trade statistics, master data integrity, and contractual product definitions.

A common challenge for operational teams is understanding exactly “what is finalized and when.” Because HS 2028 is based on an international treaty, the adoption process and the development of Correlation Tables occur in distinct legal stages. This guide breaks down the timeline from an enterprise perspective, based on official WCO information and HS Convention procedures.

Note: Where specific dates (such as the release of Correlation Tables) are not yet confirmed, we clearly distinguish between established facts and historical precedents.

1. Understanding the Three Stages of “Adoption”

In the context of the HS Convention, “adoption” does not refer to a single event. Under the treaty framework, there are three critical phases:

  • Consolidation by the HS Committee (HSC): The Harmonized System Committee (HSC) debates and consolidates the draft amendment package. The HSC typically meets twice a year, and complex issues often span multiple sessions.
  • Council Approval and Recommendation to Contracting Parties: The package is submitted to the WCO Council for approval. Once approved, it is formally issued as a Recommendation under Article 16 of the HS Convention.
  • Deemed Acceptance and Confirmation of Entry into Force: Under the Convention, a recommended amendment is “deemed accepted” if no objection is lodged within six months of notification by the Secretary-General. The date of notification determines whether the amendment enters into force on January 1 of the second or third year following the notification.

2. The Logic Behind the January 1, 2028, Implementation

HS revisions follow the strict calendar rules set forth in Article 16 of the HS Convention:

  1. The Six-Month Rule: Amendments are deemed accepted six months after notification, provided no objections remain.
  2. The Entry into Force Rule: If notified before April 1, the changes take effect on January 1 of the second year (the “year after next”). If notified after April 1, they take effect on January 1 of the third year.

The scheduled implementation of HS 2028 on January 1, 2028, aligns with the standard practice of Council approval and notification occurring around June. Official EU documents already assume that the Council will adopt the Recommendation during its June 2025 session, setting the stage for 2028 implementation.

3. Official Milestones: 2025–2028

Based on confirmed WCO and EU announcements, the timeline is as follows:

  • March 2025: Consolidation of the Amendment Package (75th HSC)The WCO announced that the 75th HSC session (March 10–21, 2025) provisionally adopted the Article 16 Recommendation package for HS 2028, consisting of 299 sets of amendments.
  • June 2025: Formal Recommendation by the WCO CouncilThe WCO Council (sessions 145/146) is expected to formally adopt the Article 16 Recommendation. This triggers the six-month objection period.
  • July–December 2025: The Objection PeriodContracting Parties have six months to enter reservations or objections.
  • Late December 2025: Deemed AcceptanceOnce the six-month window closes without objections, the amendments are legally “accepted.”
  • January 2026: Official Publication by the WCOThe WCO intends to publish the final 2028 edition in January 2026. This is the definitive starting point for enterprises to begin systematic internal mapping.
  • January 1, 2028: Entry into ForceAll Contracting Parties must align their national customs tariffs and statistical nomenclatures with the revised HS by this date.

4. Correlation Tables: Legal Status and Importance

Correlation Tables (or “Transposition Tables”) show the relationship between the old version (HS 2022) and the new version (HS 2028).

Crucial Point: Correlation Tables are not legally binding documents. However, the WCO explicitly states that they are “essential tools” for preparing for a new edition. In October 2025 (76th HSC), the WCO commenced discussions on developing these tables and adopted decisions to improve their format for HS 2028.

5. Schedule for Correlation Table Development

5.1 Work is Already Underway

Confirmed WCO reports indicate that as of October 2025, the HSC has already begun developing the correlation between HS 2022 and HS 2028. This proves that the tables are not a “last-minute” release but a multi-stage technical project.

5.2 Concurrent Development with Auxiliary Tools

The preparation period between Council approval and entry into force involves a massive workload for the WCO Secretariat, including:

  • Drafting the Correlation Tables.
  • Updating the Explanatory Notes and Classification Opinions.
  • Aligning databases and training materials.
  • National-level implementation.

5.3 Historical Precedent: The HS 2022 Timeline

For the HS 2022 edition, the WCO published the Correlation Tables on November 13, 2020—approximately 14 months before the entry-into-force date. If HS 2028 follows this precedent, enterprises can expect official WCO Correlation Tables to be available around November 2026.

6. The “Local Gap” Pitfall: WCO vs. National Tables

Enterprises must distinguish between International (6-digit) and National (8-10 digit) levels:

  • WCO Tables only cover the 6-digit international subheadings.
  • National Tables cover the domestic subdivisions (e.g., HTSUS, CN, etc.).A simple “one-to-one” move at the 6-digit level may result in a “one-to-many” split at the national level. Monitoring national implementation is as critical as monitoring the WCO.

7. National Timelines: The U.S. Example

While international work progresses, major economies begin their domestic legal updates. For example, the USITC has outlined its schedule for updating the Harmonized Tariff Schedule of the United States (HTSUS):

  • February 2026: Publication of preliminary proposed amendments for public comment.
  • September 2026: Final report submitted to the President.This highlights that major trading partners will move toward concrete national codes almost immediately after the WCO’s January 2026 publication.

8. Implementation Action Plan: 2026–2028

Phase 1: 2026 – Inventory and Mapping Design

  • List all Master Data by 6-digit HS codes.
  • Identify High-Risk Items: Pinpoint products likely to be affected by the 299 amendment sets.
  • Define Mapping Rules: Establish protocols for handling many-to-one or one-to-many transitions and designate internal classification owners.

Phase 2: 2027 – National Alignment and Impact Assessment

  • Track National Gazettes: Monitor domestic correlation tables in key jurisdictions.
  • Assess Financial/Legal Impact: Evaluate changes in tariff rates, FTA/EPA eligibility, and origin determinations.
  • System Integration: Update ERP, Customs Management Systems (CMS), and product databases.

Phase 3: Late 2027 – Transition Management

  • Develop Cutover Procedures: Standardize handling of goods in transit or in bonded warehouses during the Jan 1 transition.
  • Training & Notification: Educate internal teams and notify supply chain partners of code changes.

9. Summary

  • HS 2028 follows a rigid treaty cycle: HSC consolidation $\rightarrow$ Council Recommendation $\rightarrow$ 6-month objection period $\rightarrow$ Deemed Acceptance.
  • The WCO timeline targets January 2026 for full publication and January 1, 2028, for implementation.
  • Correlation Tables are currently in development as of late 2025. Historically, they are released about 14 months before implementation.
  • Enterprises must track WCO (6-digit) and National (8+ digit) schedules concurrently to avoid compliance gaps.

Changes to Semiconductor and Sensor Classifications in HS 2028:　Business Implications and Proactive Strategic Preparation

Semiconductors and sensors are quintessential examples of the “fast-paced technology vs. slow-evolving classification” dilemma in the world of customs. With the HS 2028 revision approaching, the impact extends far beyond mere code changes. In practice, it triggers a chain reaction affecting tariff rates, Rules of Origin (RoO), trade statistics, export controls, and the integrity of internal master data.

This guide is designed not for engineers, but for business divisions—including Procurement, Sales, Corporate Planning, Trade Compliance, and Logistics. It aims to clarify how to interpret the HS 2028 semiconductor/sensor amendments and where specific risks and opportunities will emerge. The HS 2028 amendments are currently progressing through formal WCO procedures, with a confirmed entry-into-force date of January 1, 2028.

1. Understanding HS 2028: Timeline and Background

Why 2028? Understanding the Implementation Cycle

While the Harmonized System (HS) is typically revised every five years, the 7th Review Cycle was extended by one year due to the pandemic and other factors. Consequently, the next edition will be implemented on January 1, 2028. The WCO has explicitly stated that the cycle will then return to its five-year cadence, with HS 2033 to follow.

At the 75th HS Committee (HSC) session in March 2025, the HS 2028 Recommendation Package—comprising 299 sets of amendments—was provisionally adopted as an Article 16 Recommendation. This package includes:

  • 105 sets of amendments to the Nomenclature
  • 5 amendments to the Explanatory Notes
  • 66 Classification Decisions
  • 14 New Classification Opinions

Final adoption is scheduled for late December 2025, with the final version published in January 2026 for implementation on January 1, 2028.

Critical Note: HS revisions are “international standards requiring consensus.” Following approval by the WCO Council, contracting parties have a six-month objection period. Any item facing a formal objection may be excluded. Therefore, companies must estimate impacts early while remaining prepared to re-verify against the definitive version.

2. Why Semiconductors and Sensors are a Focal Point of HS 2028

Business Implications Beyond “Tariff Rates”

Industry bodies have long argued that technological evolution outpaces the five-year HS cycle. Products such as Multi-Chip Optoelectronics (MCOs) and integrated sensor products often face classification ambiguity—wavering between “functional classification” and “element-based classification.” This led to the expansion of semiconductor definitions in the 2017 and 2022 revisions.

In HS 2028, semiconductor-based transducers are again on the agenda. These changes are not merely for statistics; they are linked to the following operational elements:

  • Tariff Rates & Trade Remedies: MFN rates, supplemental duties, safeguards, and anti-dumping measures are tied to HS codes. A code change can trigger or bypass these measures.
  • Rules of Origin (RoO): Most FTAs define Product Specific Rules (PSR) at the Chapter, Heading, or Subheading level. An HS shift changes which rule applies to the same product.
  • Export Control & Compliance: While control lists are based on performance specifications, operational screening often uses HS codes as a primary key. Classification changes impact monitoring logic.
  • Corporate Decision-Making: HS classification is embedded in supply chain KPIs, including sourcing diversification, inventory positioning, manufacturing site selection, and price negotiations.

3. The “Gray Zones” in Semiconductor and Sensor Classification

Typical Friction Points During HS Revisions

Semiconductors and sensors exist on a technological continuum:

  1. Wafers and Dies
  2. Packaged Elements
  3. Modules integrated with Signal Processing ICs
  4. Finished Goods (including housing, communication, power, and software)

HS classification is the process of “drawing the line” on this continuum. Business impact is most significant for products sitting near these boundaries.

Frequent points of contention for sensors:

  • Sensor Element vs. Measuring Instrument: Elements lean toward components (Heading 85.41), while measuring instruments lean toward finished goods (various other chapters). The closer a product gets to a “finished” state, the more likely it is to move away from Chapter 85.
  • Transducer vs. Signal Processor: The point at which a device moves from merely converting physical quantities into electrical signals to performing calibration, computation, and digital output changes the customs evaluation.
  • Single-function vs. Multi-function: Environmental sensors often integrate multiple elements (temp/humidity, pressure, gas, light). Multi-functionality intensifies the debate over the “principal function.”
  • Industrial Application: While classification is not determined by application alone, the variations in composition for automotive, medical, or industrial use directly influence the final code.

4. What Exactly “Changes” in HS 2028?

Distinguishing Fact from Speculation

To ensure reliability, we must separate confirmed information from items requiring further verification.

4.1 Confirmed Facts from Primary Sources

  • Effective Date: HS 2028 will enter into force on January 1, 2028.
  • Scope: A recommendation package containing 299 amendment sets has been provisionally adopted.
  • Breakdown: This includes 105 nomenclature amendments and 66 classification decisions.
  • Subject Matter: Semiconductor-based transducers are explicitly included in the revision agenda.

4.2 Proactive Identification of “High-Risk” Items

Final confirmation of specific 6-digit codes requires the official HS 2028 legal text and correlation tables, expected in January 2026.

The business objective is not to memorize the code table, but to identify if your products sit in the “center of a classification boundary.” High-impact categories include:

  • Semiconductor-based transducers
  • Modules where sensor elements are paired with signal processing ICs
  • Composite sensors (integrating multiple measurement elements)
  • Smart sensors (incorporating internal calibration, calculation, and communication)
  • Units or sub-assemblies where the sensor is inseparable from other functions

5. Common Pitfalls: Why “Leaving it to Customs” Fails

Delegating HS 2028 entirely to the customs clearance team often leads to:

  1. Insufficient Master Data Granularity: If the master data lacks attributes (role of the element, presence of signal processing, etc.), it is impossible to apply correlation tables systematically.
  2. Delayed RoO Assessment: Even if the tariff is 0%, an HS change can change the PSR. This can lead to unexpected spikes in origin-compliance costs.
  3. Broken Export Screening: If internal export controls use HS codes as a trigger, misclassification or outdated codes will lead to screening failures.

6. Practical Checklist for Business Professionals

Milestones to Complete by 2028

  • Step 1: Impact Inventory
    • Categorize products into “Elements,” “Modules,” and “Finished-leaning Goods.”
    • Prioritize by revenue, profit margin, and regulatory risk.
    • Map tariff rates and FTA usage by key import/export countries.
  • Step 2: Internal Standardization of Classification Attributes
    • Technical specs for semiconductors/sensors cannot be determined by product name alone. Embed these attributes into your master data:
      • Measured variable (temp, pressure, gas, etc.)
      • Conversion method (Semiconductor-based, MEMS, etc.)
      • Signal processing scope (Amplification, A/D, Computation)
      • Output format (Analog, Digital, Protocol)
  • Step 3: Avoid “Auto-Conversion”
    • Correlation tables are only a starting point. Final classification must be verified against national tariff schedules (which include local sub-divisions) and specific product specs.
  • Step 4: Identify Downstream Impacts
    • Pricing terms (Who bears the tariff?)
    • Origin certification (PSR reference changes)
    • Licensing and internal screening flows
    • Management reporting (KPIs by product category)

7. Summary

HS 2028 is a revision where the “line-of-demarcation for semiconductors and sensors” directly translates into business cost. While the framework is set, final confirmation of specific codes will not be possible until the January 2026 publication of the official text and correlation tables.

The key to success for semiconductor and sensor companies is not a frantic replacement of codes in late 2027. Success lies in identifying “boundary products” now and building a master data infrastructure that allows for specification-based classification decisions.

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)”?