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:
| Milestone | Date / Detail |
| HSC 75th Meeting | March 10–21, 2025: Recommendation finalized. |
| WCO Council Adoption | June 2025: Expected formal adoption of the Article 16 Recommendation. |
| Objection Period | 6 months following notification: Amendments are deemed accepted if no Contracting Party objects. |
| Entry into Force | January 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.
- Build a Product Inventory: Anchor your list on current HS 2022 6-digit codes, including product function and composition.
- Flag High-Risk Products: Identify items in the focus areas mentioned above (e.g., heat pumps, semiconductors, food supplements, and plastic recyclates).
- Monitor Correlation Tables: Prepare to map HS 2022 codes to HS 2028 as soon as official correlation tools and national tariff schedules are released.
- Align Master Data: Ensure your ERP, logistics systems, and customs broker instructions are updated in sync with the 2028 cutover.
.