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:
- The Six-Month Rule: Amendments are deemed accepted six months after notification, provided no objections remain.
- 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.