Clients often say “we’ve used the same harmonized codes for years” and “our products are duty free“. As a Licensed Customs Broker and consultant this tells me that I need to do some checking on the client’s behalf. Using obsolete or invalid HTS (Harmonized Tariff Schedule) codes is a sign of an amateurish operation. The risks are customs delays, fines and penalties, or surprise duty/tax bills. It is likely that, for these clients, commercial invoice descriptions need updating. If they are also an exporter we should check ECCNs, License Exceptions, Countries of Origin, and Schedule B numbers as well.

The tariff archives show that the 2022 HTS was revised 15 times. The 2023 version already lists 8 revisions. Schedule B codes change frequently too. Here are the links to the changes:

https://hts.usitc.gov/download/archive

https://www.census.gov/foreign-trade/schedules/b/index.html

Don’t assume that your codes are valid. A little due diligence helps avoid problems down the road. Contact mitch@adhoclogistics.com for a review of your HTS codes.