0. Bottom line first: What is in / not in this Chapter (ultra-summary)
- Typical examples INCLUDED in this Chapter (3–6):
- Unworked human hair and waste human hair (e.g., raw hair collected for industrial use). (関税局)
- Pigs’/wild boars’ bristles and other brush-making hair (as raw hair/bristles or waste). (関税局)
- Animal guts (other than fish), including intestines for sausage casings, preserved by salting/brining/drying/smoking, etc. (関税局)
- Feathers and down only cleaned/disinfected/treated for preservation (not “prepared”/decorated). (関税局)
- Unworked / simply prepared bones, horn-cores, ivory, horns, antlers, shells, coral (not cut to shape / not carved). (関税局)
- “Other” animal products n.e.s. such as bovine semen, horsehair, certain fish waste, dried animal blood, etc. (関税局)
- Typical examples commonly EXCLUDED (3–6; include likely alternative Chapter/Heading):
- Most edible animal products (food) → typically Chapters 2, 3, 4, 16 (with specific exceptions in Chapter 5 for certain offal/blood). (関税局)
- Raw hides/skins (incl. furskins) → Chapter 41 or 43 (except bird skins with feathers in 05.05, and certain hide/skin parings/waste in 05.11). (関税局)
- Animal textile materials (e.g., wool, animal hair used as textile) → Section XI (with a practical exception: “horsehair” for Chapter 5 purposes is treated differently). (関税局)
- Prepared knots/tufts for brooms/brushes → heading 96.03 (not Chapter 5). (関税局)
- Worked/cut-to-shape ivory/bone/coral/horn and articles thereof → often Chapter 71 or 96 (depending on the product form/use), not Chapter 5. (関税局)
- Prepared feathers/down and articles (decorative feather goods) → typically Chapter 67, not 05.05. (関税局)
- The top practical decision points (1–3):
- Edible vs non-edible, and whether the Chapter 5 “exceptions” apply (guts/bladders/stomachs; animal blood). (関税局)
- Degree of processing: unworked/simply prepared/cleaned vs worked (cut to shape, carved, assembled into articles, dyed/bleached as “prepared”). (関税局)
- Presentation/state: raw hair/bristles vs prepared brush tufts; raw feathers vs prepared decorative feathers; raw materials vs finished articles. (関税局)
- (Optional) Situations where misclassification tends to be “high-cost” in practice:
- Any product that may be CITES-controlled (ivory, certain corals/shells/species-based materials): classification errors often trigger permit failures, seizures, or long holds. (CITES)
- Any product that may trigger animal quarantine in Japan (bones, hair, feathers, horns, tendons, semen, etc.). (農林水産省)
- FTA/EPA origin work where the agreement HS edition differs from HS2022 (PSR selection can break). (Australian Border Force Website)
1. How to reach this Chapter (classification logic)
1-1. Core classification rules (where GIR matters)
- In practice, this Chapter is mostly a GIR 1 and GIR 6 exercise:
- GIR 1: start from the legal scope (Headings + Notes). Chapter 5 is a “residual” animal-origin chapter, but it still contains very specific headings (hair, guts, feathers, bones, ivory, coral, etc.).
- GIR 6: once the Heading is clear, choose the correct 6-digit Subheading (e.g., “ivory vs other”, “acid-treated bones vs other”, etc.). (関税局)
- Terms to keep consistent (to avoid HS vs national-code confusion):
- Practical warning (Japan operations):
- Japan customs declarations commonly use a 9-digit statistical code = HS6 + 3-digit domestic code (and the domestic splits for export/import can differ). Treat anything beyond HS6 as national code. (関税庁)
1-2. Decision flow (pseudo flowchart)
- Step 1: Confirm the item is an animal-origin product (material source + what part of the animal + condition).
- Step 2: Screen out “common exit doors” created by Notes:
- Is it mostly edible food? → usually Chapters 2/3/4/16 (unless it is guts/bladders/stomachs or animal blood per Chapter 5 Note). (関税局)
- Is it a hide/skin/furskin (not bird skin with feathers)? → Chapters 41/43. (関税局)
- Is it an animal textile material (wool/hair used as textile)? → Section XI (except “horsehair” as defined for Chapter 5 purposes). (関税局)
- Is it a prepared brush tuft/knot? → heading 96.03. (関税局)
- Is it worked/cut-to-shape into an article/material? → likely not Chapter 5. (関税局)
- Step 3: If still in Chapter 5, map to the most specific Heading by the material:
- Human hair → 0501
- Brush-making bristles/hair → 0502
- Guts/bladders/stomachs → 0504
- Feathers/down (only minimally treated) → 0505
- Bones/horn-cores (unworked/simply prepared) → 0506
- Ivory/horns/antlers/hooves etc (unworked/simply prepared) → 0507
- Coral/shells/cuttle-bone (unworked/simply prepared) → 0508
- Ambergris/musk/bile/glands for pharma (provisionally preserved) → 0510
- “Other” animal products n.e.s. (incl. bovine semen; horsehair; natural sponges of animal origin; fish waste, etc.) → 0511 (関税局)
- Common boundary disputes (e.g., boundary between Chapter X and Chapter Y):
- 0505 (raw/cleaned feathers/down) vs Chapter 67 (prepared feathers and feather articles). (関税局)
- 0502 (raw bristles/hair) vs 9603 (prepared knots/tufts for brush-making). (関税局)
- 0507/0508 (unworked/simply prepared) vs “worked” articles/materials (often Chapter 96 or 71 in practice). (関税局)
- 0510 (provisionally preserved animal glands for pharma) vs Chapter 30 (pharmaceutical substances/processed extracts). (This is highly fact-specific; confirm the condition and processing stage.) (関税局)
2. Main Headings (4-digit) and what they cover
2-1. Table of key 4-digit Headings (REQUIRED)
- Rule:
- If the Chapter has few Headings: list ALL
- If many: list 10–20 that are operationally important (frequent / high error / regulatory or origin-impacting) + group “Others”
Use this table format:
| Heading (4-digit) | Plain-English summary | Typical examples (products) | Key decision criteria / exclusions / cautions |
|---|---|---|---|
| 0501 | Unworked human hair; waste human hair | Raw hair bundles; hair waste from salons | “Unworked” matters. Sorting by length may still count as unworked depending on how it is arranged. Exclude “prepared/dressed” hair for wigs (often Chapter 67). |
| 0502 | Bristles/hair for brush-making (pig/boar; badger; other) and waste | Boar bristles for brushes; badger hair; mixed brush hair waste | If it is already a prepared tuft/knot, it moves to 9603. Species/detail matters for 6-digit split. |
| 0504 | Animal guts, bladders, stomachs (not fish), whole/pieces, preserved | Salted intestines for sausage casings; dried stomachs | Note-driven inclusion: many edible products are excluded from Ch.5, but this heading remains a Ch.5 “exception”. Fish offal is not here. |
| 0505 | Bird skins with feathers/down; feathers/down (only cleaned/disinfected/preservation-treated); feather powder/waste | Duck/goose down (not prepared); feathers for stuffing | If feathers are prepared (e.g., dyed/curled/assembled/ornamental), often Chapter 67. |
| 0506 | Unworked/simply prepared bones & horn-cores; acid-treated bones (ossein); powders/waste | Bone pieces; horn-cores; bone powder | “Not cut to shape” is key. If carved/cut into blanks or articles, often not Ch.5. |
| 0507 | Unworked/simply prepared ivory & similar materials (tortoise-shell, whalebone, horns, antlers, hooves, claws, beaks); powders/waste | Ivory powder; antlers; horn pieces | “Ivory” has a broad definition (includes certain tusks/teeth/horns). CITES risk is high. “Not cut to shape” is key. |
| 0508 | Unworked/simply prepared coral; shells; cuttle-bone; powders/waste | Coral chunks; shells for craft raw material; cuttle-bone | If worked (polished/drilled/shaped into jewelry components), likely another Chapter. CITES may apply to some coral species. |
| 0510 | Ambergris/castoreum/civet/musk; cantharides; bile; animal glands/products for pharma, provisionally preserved | Fresh animal glands for pharma extraction; dried bile | Key is the “provisionally preserved” stage vs processed pharmaceutical substances (often Chapter 30). |
| 0511 | Other animal products n.e.s.; dead animals of Ch.1/3 unfit for consumption | Bovine semen; fish waste; horsehair; natural sponges of animal origin; dried animal blood | This is a “catch-all” only after checking 0501–0510 and Chapter Notes. It contains important subheadings (semen; aquatic products; “other”). |
(Headings, scope signals, and key exclusions/definitions are summarized from the published Chapter/Section notes and tariff-line structures shown in webTARIFF and Australia’s tariff materials.) (関税局)
2-2. Operationally important splits at the 6-digit Subheading level (REQUIRED)
- Main split criteria you’ll actually use in Chapter 5:
- 2–5 confusing Subheading pairs/groups:
- 0502.10 vs 0502.90 (bristles/hair)
- Where the split happens: whether it is pigs’/hogs’/boars’ bristles & hair (and waste) vs other brush-making hair. (関税局)
- Information needed to decide: species/source (pig/boar? badger? other?), and whether it is waste or usable hair.
- Typical mistake pattern: “all brush hair is 0502.10” (overusing the pig/boar line).
- 0505.10 vs 0505.90 (feathers/down)
- Where the split happens: stuffing-type feathers/down vs other feather materials/waste. (関税局)
- Information needed to decide: is it down/ stuffing feathers, or other feathers/parts/powder/waste?
- Typical mistake pattern: decorative/processed feathers mistakenly treated as “other” under 0505 instead of moving out of Chapter 5 (often to Chapter 67) because the “not further worked than…” condition was missed. (関税局)
- 0506.10 vs 0506.90 (bones/horn-cores)
- Where the split happens: “ossein and bones treated with acid” vs other bones/horn-cores/powder. (関税局)
- Information needed to decide: production process (acid treatment? degelatinised?), and whether it remains “not cut to shape.” (関税局)
- Typical mistake pattern: calling any bone powder “0506.10” without evidence of acid treatment.
- 0507.10 vs 0507.90 (ivory vs other materials)
- Where the split happens: ivory (including powder/waste) vs other (horns, antlers, hooves, etc.). (関税局)
- Information needed to decide: whether the material meets the broad “ivory” definition (tusks/teeth/horns as defined). (関税局)
- Typical mistake pattern: classifying “animal tooth” as “other” when it is treated as “ivory” for HS purposes.
- 0511.10 vs 0511.91 vs 0511.99
- Where the split happens: bovine semen vs aquatic by-products/dead animals of Ch.3 vs other animal products n.e.s. (関税局)
- Information needed to decide: (a) bovine or not, (b) aquatic origin or not, and (c) whether a more specific heading applies.
- Typical mistake pattern: overusing 0511.99 as a “miscellaneous animal goods” bucket before checking headings 0501–0510 and note-driven exclusions.
- 0502.10 vs 0502.90 (bristles/hair)
3. Interpreting Section Notes and Chapter Notes (legal text → practical meaning)
3-1. Relevant Section Notes
- Key points (summary):
- Practical meaning (with concrete examples):
- Typical patterns where a Section Note “moves you to another Chapter”:
- Section notes are usually definitions; the big “moves” in Chapter 5 come from the Chapter Notes (see 3-2).
3-2. Chapter Notes for this Chapter
- Key points (summary):
- Chapter 5 is not for most edible products—except it does still cover certain offal/blood categories called out in the note (practically: don’t assume “edible” automatically means Chapter 2/4/16). (関税局)
- Most hides/skins are excluded (Ch.41/43), except:
- Bird skins with feathers/down (05.05), and
- Parings and similar waste of raw hides/skins that are specifically in 05.11. (関税局)
- Animal textile materials are excluded to Section XI except horsehair/hair waste (as defined) which remains relevant within Chapter 5 scope logic. (関税局)
- Prepared brush knots/tufts are excluded to heading 96.03. (関税局)
- Definitions (if any):
- Unworked human hair: certain “sorting by length” operations are not treated as “working” for 05.01, depending on how roots/tips are arranged. (関税局)
- “Ivory” is defined broadly for HS purposes (includes certain tusks/teeth/horns). (関税局)
- “Horsehair” is defined (manes/tails of equine or bovine), and the notes highlight that 05.11 covers horsehair and its waste. (関税局)
- Exclusions (state alternative Chapter/Heading explicitly):
4. How the Chapter Notes change classification outcomes (where the code flips)
Purpose: make “note-driven splits” visible.
- Impact point 1: Edible vs Chapter 5 “exceptions”
- What to check (information needed):
- Is the product intended/fit for human consumption?
- If edible, is it still one of the Chapter 5 carve-outs (e.g., guts/bladders/stomachs; animal blood)? (関税局)
- Evidence to collect in practice:
- Product spec sheet + intended use statement
- Veterinary/health certificates (if any), labeling, photos of form (whole/pieces), preservation method
- Typical misclassification:
- Treating sausage casings/intestines as “meat/offal” without checking the Chapter 5 note carve-out.
- What to check (information needed):
- Impact point 2: Hide/skin vs bird skin with feathers vs hide waste
- What to check (information needed):
- Is it a bird skin with feathers/down still attached (points to 05.05)?
- Is it parings/similar waste of raw hides/skins (can point to 05.11)?
- Otherwise, raw hide/skin tends to leave Chapter 5. (関税局)
- Evidence to collect in practice:
- Photos (feathers attached? yes/no)
- Manufacturing flow: “skinned then plucked” vs “plucked then skinned”
- Typical misclassification:
- Declaring featherless bird skin under 05.05.
- What to check (information needed):
- Impact point 3: Raw bristles/hair vs prepared brush tufts
- What to check (information needed):
- Is it presented as a prepared knot/tuft for brush-making (exclusion to 96.03)? (関税局)
- Evidence to collect:
- Photos of packaging/presentation (bundled + glued/knotted? ferrules? pre-formed brush heads?)
- Catalog/technical drawings
- Typical misclassification:
- Using 0502 for brush “tufts” that are actually ready-to-use components.
- What to check (information needed):
- Impact point 4: “Not cut to shape” / “not otherwise worked”
- What to check (information needed):
- For 0506/0507/0508: has the material been cut to shape, drilled, carved, polished to a defined article, etc.? (関税局)
- Evidence to collect:
- Before/after processing photos, machining specs, purchase order language (“blanks”, “beads”, “cabochons”, “carvings”)
- Typical misclassification:
- Treating worked coral beads as 0508 rather than a worked-material heading.
- What to check (information needed):
5. Common mistakes in practice (cause → correction)
Write 5–10 items using this exact pattern:
- Mistake:
- Declaring bleached/dyed/dressed human hair as 0501 (raw human hair).
- Why it happens:
- Hair is “still hair,” and teams don’t separate “unworked” vs “prepared for wig-making.”
- Correct approach (which Note / which Heading logic supports it):
- 0501 is for unworked hair; check processing steps. If it is “prepared/dressed” for wigs or presented as a wig/article, you’re likely outside Chapter 5. (関税局)
- Prevention (documents to verify / internal questions to ask):
- Verify bleaching/dyeing/straightening/perming steps; request supplier process description and photos.
- Mistake:
- Classifying prepared brush tufts under 0502 (bristles/hair).
- Why it happens:
- Product is still “bristles,” but the note-driven exclusion is missed.
- Correct approach (which Note / which Heading logic supports it):
- Prepared knots/tufts for brush making are excluded from Chapter 5 to heading 96.03. (関税局)
- Prevention (documents to verify / internal questions to ask):
- Ask: “Is it knotted/glued as a tuft? Ready to mount in a brush head?” Collect photos + catalog page.
- Mistake:
- Treating sausage casings (intestines) as “food/offal” and moving them to a food chapter automatically.
- Why it happens:
- Teams use “edible/non-edible” as the only rule.
- Correct approach (which Note / which Heading logic supports it):
- Chapter 5 notes carve out certain offal/blood categories (guts/bladders/stomachs; animal blood) from the general edible exclusion. (関税局)
- Prevention (documents to verify / internal questions to ask):
- Confirm the anatomical part (intestine vs other edible product), preservation method, and whether it is “guts/bladders/stomachs” per the Chapter Note.
- Mistake:
- Classifying feather products under 0505 even when they are decorative/prepared.
- Why it happens:
- “Feathers = 0505” shortcut.
- Correct approach (which Note / which Heading logic supports it):
- 0505 is limited to feathers/parts/down not further worked than cleaned/disinfected/preservation-treated. Once prepared/ornamental, review Chapter 67-type outcomes. (関税局)
- Prevention (documents to verify / internal questions to ask):
- Ask whether feathers are dyed, curled, shaped, sorted to decorative grade, assembled into trims; collect process flow.
- Mistake:
- Declaring carved or cut-to-shape horn/bone/coral as 0506/0507/0508.
- Why it happens:
- Purchasing calls them “raw materials,” but they are actually “blanks” or near-finished.
- Correct approach (which Note / which Heading logic supports it):
- Chapter 5 headings for these materials commonly require unworked/simply prepared and not cut to shape / not otherwise worked. (関税局)
- Prevention (documents to verify / internal questions to ask):
- Request drawings + dimensions + machining steps; ask “Can it be used as-is as a component?”
- Mistake:
- Putting any animal-origin “miscellaneous” into 0511.99 without checking 0501–0510 first.
- Why it happens:
- 0511 is treated as a dumping ground.
- Correct approach (which Note / which Heading logic supports it):
- 0511 is “n.e.s.” only after excluding more specific headings and note-driven exits. (関税局)
- Prevention (documents to verify / internal questions to ask):
- Internal checklist: “Did we rule out 0501/0502/0504/0505/0506/0507/0508/0510?”
- Mistake:
- Misidentifying “ivory” materials and using 0507.90 (“other”) when the HS definition treats it as “ivory.”
- Why it happens:
- Teams think ivory = elephant only.
- Correct approach (which Note / which Heading logic supports it):
- The Chapter Note treats certain tusks/teeth/horns as “ivory” for HS purposes; that affects the 0507 split. (関税局)
- Prevention (documents to verify / internal questions to ask):
- Get species/material declaration; if CITES-related, align the HS material identity with permit/species documentation.
- Mistake:
- Using the correct HS6 but the wrong Japan domestic split (9-digit statistical code), causing duty/regulatory mismatch.
- Why it happens:
- HS6 is correct, but staff select the first domestic code they see.
- Correct approach (which Note / which Heading logic supports it):
- Keep HS6 stable; select domestic split using Japan’s statistical-code schedule and ensure invoice description supports that split. (関税庁)
- Prevention (documents to verify / internal questions to ask):
- Add a “domestic split check” step: unit, intended use (e.g., sausage casings vs other guts), and any value thresholds if present in the national schedule.
6. Points to watch for FTA/EPA origin certification
6-1. Relationship between HS classification and PSR (Product-Specific Rules)
- HS assignment drives PSR selection (misclassification breaks the origin analysis)
- PSRs are written by HS code. If you classify the finished good under the wrong HS6, you can end up applying the wrong transformation rule (CTC/RVC/etc.), which can invalidate the origin claim.
- Common pitfalls (HS for materials vs HS for final goods; evaluating processes; etc.)
- Using HS codes of inputs (materials) as if they were the HS code of the finished good.
- Applying an HS2022 code to search a PSR table that is written in an older HS edition (common in practice). (関税庁)
6-2. HS version differences referenced by agreements (HS2012 / HS2017 / HS2022)
- Explicitly state which HS edition each agreement uses (examples that commonly affect Japan-facing trade):
- CPTPP: PSR annex uses HS2012 nomenclature (so PSR lookup is HS2012-based). (Australian Border Force Website)
- RCEP: PSR/tariff commitments were finalized in HS2012, and a transposed HS2022 version is used by parties from January 1, 2023 (for proof-of-origin handling). (外務省)
- EU–Japan EPA: operational guidance for checking tariffs/usage commonly references HS2017 code alignment for EU-Japan use cases. (EU貿易)
- Practical cautions if the agreement’s HS edition differs from HS2022
- If your operational HS is HS2022, but the agreement PSR table is HS2012/HS2017:
- Classify the finished good in HS2022 (for customs declaration).
- Map HS2022 → agreement HS edition using an official correlation table (or agreement-provided transposition guidance where applicable). (関税庁)
- Apply PSR in the agreement’s HS edition and keep an audit trail (HS2022 code, mapped code, mapping source, product facts that justify the mapping).
- If your operational HS is HS2022, but the agreement PSR table is HS2012/HS2017:
- How to handle transposition (old → new mapping) in general
- Do not “guess” mappings if splits/merges exist: treat it as Information needed to decide and collect the exact facts that determine which mapped code applies.
6-3. Practical checklist (data needed for origin analysis)
- BOM, cost data, processing steps, country of origin, HS for non-originating materials, RVC assumptions
- BOM with HS codes for non-originating inputs (at least to the level the PSR requires)
- Production process narrative (what happens, where, and what transformation is achieved)
- Costed BOM if RVC is used
- Supporting documents & retention (general guidance)
- Supplier declarations, production records, invoices, shipping documents
- A mapping memo if HS edition transposition was required
7. Differences between HS2022 and earlier HS editions (what changed and why)
7-1. Change summary (REQUIRED TABLE)
| Comparison (e.g., HS2017→HS2022) | Change type (new / deleted / split / merged / wording / scope) | Codes affected | Practical meaning of the change | Operational impact |
|---|---|---|---|---|
| HS2017→HS2022 | No change identified for Chapter 05 at HS6 level (no Chapter 05 entries in the WCO correlation tables listing changes) | Chapter 05 HS6 set | Expect stable HS6 selection for Ch.05 goods across these two editions | Lower mapping burden for HS classification itself; but FTA PSR HS-edition differences can still require mapping work |
7-2. Why it changed (REQUIRED)
- Sources relied on:
- WCO HS2017→HS2022 correlation tables page (and its Table I/II documents). (国際税関機構)
- Basis / explanation:
- The WCO correlation tables summarize HS6-level changes between HS2017 and HS2022. In reviewing these materials, no Chapter 05 HS codes appear as changed/new (e.g., no “050x/051x” entries are found in the tables), so for Chapter 05 the practical conclusion is: No HS6-level structural change identified from HS2017 to HS2022. (国際税関機構)
8. HS codes added or removed before HS2022 (historical perspective)
- Summary table (what we can state from available official/public sources):
| HS edition | What appears structurally notable for Chapter 05 | Evidence / practical note |
|---|---|---|
| HS2007 | Headings 05.03 and 05.09 appear as reserved/bracketed entries | WCO HS2007 Chapter excerpt shows [05.03] and [05.09] as reserved. (国際税関機構) |
| HS2012 | Information needed to decide | Confirm using HS2012 legal text / correlation tables (not established here). |
| HS2017 | Information needed to decide at a “legal text” level, but no HS6 change vs HS2022 is indicated by WCO correlation tables | Use WCO HS2017→HS2022 correlation tables to support stability into HS2022. (国際税関機構) |
| HS2022 | Operational structure in current schedules shows Chapter 05 headings as 0501, 0502, 0504, 0505, 0506, 0507, 0508, 0510, 0511 (no 05.03 / 05.09 as headings in use) | Current published schedules/notes show the active heading set and the note text. (関税局) |
- Practical takeaway:
- If older internal master data contains legacy “0503 / 0509,” treat that as a red flag for edition mismatch and run a correlation-table check before using it operationally.
9. Clearance trouble scenarios caused by violating Notes (case-style)
Provide 3–5 cases in this exact pattern:
- Case name (short): “Decorative feathers declared as 0505”
- What went wrong (which Chapter Note / Section Note was violated):
- Missed the “not further worked than cleaned/disinfected/preservation-treated” limitation; decorative/prepared feathers can move out of Chapter 5. (関税局)
- Why it happens:
- Product naming (“feathers”) overrides processing state.
- Typical impacts (general: amendments, additional duty/tax, increased inspection, delays, etc.):
- Reclassification, delays, and higher scrutiny (especially if the goods look like finished accessories).
- Prevention (advance ruling, pre-check, document readiness, etc.):
- Keep a process statement from supplier (cleaned only vs dyed/curled/assembled), with photos.
- What went wrong (which Chapter Note / Section Note was violated):
- Case name (short): “Brush tufts declared as bristles (0502)”
- What went wrong (which Chapter Note / Section Note was violated):
- Ignored the exclusion of prepared knots/tufts for brush making to 96.03. (関税局)
- Why it happens:
- Component is still hair/bristles; teams focus on material not presentation.
- Typical impacts:
- Post-entry amendment, potential penalty exposure, shipment hold for inspection.
- Prevention:
- Add a packaging/presentation checklist (“Is it knotted? glued? ready to mount?”).
- What went wrong (which Chapter Note / Section Note was violated):
- Case name (short): “Ivory/horn material missing CITES alignment”
- What went wrong (which Chapter Note / Section Note was violated):
- Incorrectly identified the material (e.g., assuming “ivory = elephant only”) and selected the wrong HS material category; permits didn’t match goods. (関税局)
- Why it happens:
- Incomplete species/material declarations; permit and HS classification handled by different teams.
- Typical impacts:
- Seizure/return/destruction risk; long detention; reputational risk.
- Prevention:
- Align HS material description, scientific/common name, and CITES paperwork before shipping; consider an advance ruling for borderline cases.
- What went wrong (which Chapter Note / Section Note was violated):
- Case name (short): “Sausage casings: edible logic applied too simplistically”
- What went wrong (which Chapter Note / Section Note was violated):
- Used “edible → food chapter” shortcut without checking Chapter 5 exceptions. (関税局)
- Why it happens:
- Teams rely on food/non-food instead of exact anatomical part + note carve-outs.
- Typical impacts:
- Classification correction and potential SPS/quarantine workflow disruptions.
- Prevention:
- Collect: anatomical description, preservation method, and intended use (casing).
- What went wrong (which Chapter Note / Section Note was violated):
10. Import/export regulatory considerations (compliance)
- For Japan, summarize frequent regulations/permits/quarantine relevant to this Chapter (only if applicable)
- Animal quarantine / SPS (Japan): Many animal-derived items are subject to animal quarantine controls, including (examples listed by the Animal Quarantine Service) bones, fat, blood, skin, hair, feathers, horns, hooves, tendons and also semen and eggs; finished products (e.g., leather bags, wool sweaters) may be excluded. Verify item-by-item. (農林水産省)
- CITES / species restrictions: If the item involves listed species (e.g., ivory, certain wildlife materials, some corals), Japan’s CITES-related import process may require export permits/re-export certificates from the exporting country, and for certain species additional approvals by METI. (経済産業省)
- Ivory-specific caution (Japan): Ivory is highly restricted and documentation requirements depend on circumstances (e.g., “pre-convention” conditions and licensing). Treat as high-risk and verify official guidance before shipment. (経済産業省)
- Use these axes (only those that apply):
- Quarantine / sanitary & phytosanitary (SPS)
- Typical triggers: animal-origin raw materials, offal/casings, feathers/down, semen, blood, bones/horns. (農林水産省)
- CITES / species restrictions
- Typical triggers: ivory/teeth/tusks, tortoise-shell, some corals, certain wildlife-derived raw materials. (CITES)
- Export controls (if applicable)
- Not typically applicable by HS Chapter alone; confirm based on destination, end-use, and specific controlled species/materials.
- Other permits / notifications
- Health/pharma boundary products (e.g., glands/bile for pharma) may trigger additional sectoral controls depending on product form and intended use (confirm with competent agencies).
- Quarantine / sanitary & phytosanitary (SPS)
- Official places to verify (agencies / official guides / contact points):
- Typical preparatory documents (general):
- Accurate commercial invoice description (material, species where relevant, processing state)
- Photos and specs
- Quarantine certificates/inspection certificates where required
- CITES permits (export/re-export/import approvals as applicable)
11. Practical checklist (classification → clearance → origin → regulations)
- Before classification (collect product information)
- Species/material identity (including “ivory” definition risk; horsehair definition risk) (関税局)
- Part of animal (hair vs feather vs bone vs gland, etc.)
- Processing state (unworked/simply prepared/cleaned vs worked/cut-to-shape/prepared)
- Intended use (sausage casing; stuffing; pharma input; decorative accessory)
- After classification (re-check Notes / exclusions / boundaries)
- Before declaration (invoice description, units, supporting documents)
- Make invoice descriptions match the deciding facts (e.g., “cleaned only”, “not cut to shape”, “acid-treated bones”).
- For Japan: confirm HS6 + correct 9-digit statistical code domestic split and unit. (関税庁)
- FTA/EPA checks (PSR, materials, processes, retention)
- Confirm which HS edition the agreement uses (HS2012/2017/2022) and map correctly if needed. (Australian Border Force Website)
- Retain BOM, origin evidence, and mapping memo.
- Regulatory checks (permits/notifications/inspection)
12. References (sources)
- WCO (HS2022 legal text, correlation tables, amendment package, etc.)
- [WCO-CORR-2017-2022] Correlation Table HS2017→HS2022 — World Customs Organization.
https://www.wcoomd.org/en/topics/nomenclature/instrument-and-tools/hs_nomenclature_previous_editions/hs2017_to_hs2022_correlations_tables.aspxAccessed: 2026-02-14. (国際税関機構)
- [WCO-CORR-2017-2022] Correlation Table HS2017→HS2022 — World Customs Organization.
- Japan customs and public-agency guidance (Japan)
- [JP-STATCODE-EXPLAIN] Code Lists – Trade Statistics of Japan (9-digit statistical code = HS6 + 3-digit domestic) — Ministry of Finance Japan / Japan Customs.
https://www.customs.go.jp/toukei/sankou/code/code_e.htmAccessed: 2026-02-14. (関税庁) - [JP-TARIFF-INDEX] Japan’s Tariff Schedule (Statistical Code for Import) — Japan Customs.
https://www.customs.go.jp/english/tariff/index.htmAccessed: 2026-02-14. (関税庁) - [JP-CUSTOMS-CITES] Importing restricted goods under CITES (FAQ/guidance) — Japan Customs.
https://www.customs.go.jp/english/c-answer_e/imtsukan/1808_e.htmAccessed: 2026-02-14. (関税庁) - [JP-AQS-IMPORT] Bring animal products into Japan from overseas — MAFF Animal Quarantine Service.
https://www.maff.go.jp/aqs/english/product/import.htmlAccessed: 2026-02-14. (農林水産省)
- [JP-STATCODE-EXPLAIN] Code Lists – Trade Statistics of Japan (9-digit statistical code = HS6 + 3-digit domestic) — Ministry of Finance Japan / Japan Customs.
- Tariff schedules / notes used for Chapter 05 scope wording
- [WEBTARIFF-CH05] webTARIFF Chapter 05 headings list — Japan Tariff Association.
https://www.kanzei.or.jp/statistical/tariff/headline/hs2dig/e/05Accessed: 2026-02-14. (関税局) - [WEBTARIFF-CH05-NOTES] webTARIFF Chapter 05 Notes (English) — Japan Tariff Association.
https://www.kanzei.or.jp/statistical/popcontent/note/tariff/hs2dig/e/05Accessed: 2026-02-14. (関税局) - [WEBTARIFF-SEC01-NOTES] webTARIFF Section 01 Notes — Japan Tariff Association.
https://www.kanzei.or.jp/statistical/popcontent/note/tariff/hs1dig/e/01Accessed: 2026-02-14. (関税局) - [WEBTARIFF-0511] webTARIFF heading 0511 detail page (shows HS6 and Japan domestic splits) — Japan Tariff Association.
https://www.kanzei.or.jp/statistical/tariff/headline/hs4dig/e/0511Accessed: 2026-02-14. (関税局) - [ABF-CH05] Australia Customs Tariff – Chapter 5 page (notes + tariff lines as published) — Australian Border Force.
https://www.abf.gov.au/importing-exporting-and-manufacturing/tariff-classification/current-tariff-classification/chapter-5Accessed: 2026-02-14. (Australian Border Force Website) - [WCO-HS2007-CH05] HS2007 Chapter 5 excerpt showing reserved headings (historical context) — WCO (archived PDF).
https://www.wcoomd.org/-/media/wco/public/global/pdf/topics/nomenclature/hs/hs-2007/0105_2007e.pdfAccessed: 2026-02-14. (国際税関機構)
- [WEBTARIFF-CH05] webTARIFF Chapter 05 headings list — Japan Tariff Association.
- FTA/EPA texts, annexes, operational guidance (HS-edition alignment)
- [CPTPP-PSR-HS2012] CPTPP importers guide stating PSR lookup uses HS2012 nomenclature — Australian Border Force (PDF).
https://www.abf.gov.au/free-trade-agreements/files/tpp-11-importers-guide.pdfAccessed: 2026-02-14. (Australian Border Force Website) - [CPTPP-ANNEX-3D] CPTPP Annex 3-D PSR table labeled “HS Classification (HS2012)” — (PDF mirror).
https://fta.miti.gov.my/miti-fta/resources/Text%20of%20TPPA%20%28160516%29/Annex_3-D._Product-Specific_Rules_of_Origin_.pdfAccessed: 2026-02-14. (fta.miti.gov.my) - [RCEP-HS2022-TRANSPOSE] MOFA Japan RCEP page note on using transposed PSR in HS2022 from 2023-01-01 — Ministry of Foreign Affairs of Japan.
https://www.mofa.go.jp/policy/economy/page1e_kanri_000001_00007.htmlAccessed: 2026-02-14. (外務省) - [RCEP-ROO-GUIDE] RCEP Rules of Origin Guide (mentions HS2012 finalization and HS2022 use from 2023-01-01) — Australian Border Force (PDF).
https://www.abf.gov.au/free-trade-agreements/files/RCEP-rules-of-origin.pdfAccessed: 2026-02-14. (Australian Border Force Website) - [EU-JP-EPA-HS2017] EU Access2Markets EU–Japan EPA page referencing HS2017 codes for tariff checks — European Commission.
https://trade.ec.europa.eu/access-to-markets/en/content/eu-japan-economic-partnership-agreementAccessed: 2026-02-14. (EU貿易) - [JP-CUSTOMS-ROO-CASE] Japan Customs ROO verification case labeled HS2017 for Japan–EU EPA (example case PDF) — Japan Customs.
https://www.customs.go.jp/roo/english/verification/case/2204e.pdfAccessed: 2026-02-14. (関税庁)
- [CPTPP-PSR-HS2012] CPTPP importers guide stating PSR lookup uses HS2012 nomenclature — Australian Border Force (PDF).
- Other official sources (permits, SPS, CITES)
- [CITES-APP] The CITES Appendices — CITES.
https://cites.org/eng/app/index.phpAccessed: 2026-02-14. (CITES) - [JP-METI-CITES-IMPORT] Imports of goods related to the CITES — METI Japan.
https://www.meti.go.jp/english/policy/external_economy/CITES/cites_imports.htmlAccessed: 2026-02-14. (経済産業省) - [JP-METI-IVORY] METI guidance on ivory souvenirs / licensing context — METI Japan.
https://www.meti.go.jp/policy/external_economy/trade_control/02_exandim/06_washington/to_tourist_en_souvenir.htmlAccessed: 2026-02-14. (経済産業省)
- [CITES-APP] The CITES Appendices — CITES.
Internal knowledge files used (template & standard cautions):
Disclaimer (MUST BE INCLUDED VERBATIM; DO NOT MODIFY)
This material is provided for general informational purposes regarding HS classification, customs clearance, FTA/EPA rules of origin, and import/export regulations. It does not constitute legal advice, tax advice, customs advice, or a definitive classification ruling for any specific transaction. Final HS classification is determined by the customs authority of the importing/exporting country, and classification outcomes may differ for the same or similar products depending on specifications, composition, end-use, form, degree of processing, commercial reality, documentation, and other transaction-specific facts. Tariff rates, origin rules, import/export regulations, permits, and inspection requirements may change due to legal amendments or administrative updates; you must always verify the latest official laws, regulations, public notices, and agreement texts. For important transactions, you should consider using the customs advance ruling system and/or consulting qualified professionals (customs brokers, attorneys, tax advisors) and conduct appropriate verification before making decisions. The author assumes no liability for any damages arising from the use of, or inability to use, this material.