Right, let's cut through the confusion. HS codes — formally known as commodity codes in the UK — are one of those things that every importer knows they need, but far fewer actually understand. Get them wrong and you'll overpay duty for years without realising it, or face an HMRC audit that brings your supply chain grinding to a halt. And with the UK Global Tariff continuing to evolve post-Brexit, the stakes in 2026 are higher than ever.
This guide is written for UK business owners, brand founders, and import managers who are sourcing products from China, Vietnam, or elsewhere in Asia and want to understand exactly how the UK's commodity code system works, what's changed in 2026, and how to use the system to your advantage — including claiming preferential duty rates under the UK-Vietnam Free Trade Agreement (UKVFTA).
At Epic Sourcing, we've guided dozens of UK businesses through customs classification challenges, supplier negotiations, and landed-cost calculations. This is what we've learned.
An HS code — or "commodity code" as it's called in the UK — is a standardised numerical code used to classify goods for customs purposes. The Harmonised System (HS) is maintained by the World Customs Organisation (WCO) and forms the basis for import duties, trade statistics, and customs declarations across more than 200 countries.
The UK uses a 10-digit commodity code for imports. Understanding the anatomy of that code is the first step to using the system confidently.
| Digits | Layer | What It Represents | Who Sets It |
|---|---|---|---|
| 1–6 | HS Code | International product classification (shared globally) | World Customs Organisation |
| 7–8 | CN Subheading | Combined Nomenclature — formerly EU, now UK-adapted | UK government (post-Brexit) |
| 9–10 | UK Suffix | UK-specific detail — determines exact duty rate applicable in Great Britain | HMRC / UK Trade Tariff |
For example, a commodity code for a cotton T-shirt might be 6109 10 10 00. The first six digits (610910) classify it internationally as a cotton knitted or crocheted T-shirt. The last four digits refine the exact UK duty treatment.
For exports, the UK uses an 8-digit code — the first 8 digits of the import commodity code. Export codes are used on export declarations filed via the Customs Declaration Service (CDS) and are referenced in certificates of origin for free trade agreements like the UKVFTA.
Before 31 December 2020, UK businesses importing goods followed the EU's Combined Nomenclature and TARIC database. Since the UK left the EU's customs union, the UK Global Tariff (UKGT) has applied. The UKGT diverges from the EU in several meaningful ways — duty rates, tariff suspensions, and trade remedy measures are no longer identical. This means a commodity code lookup on an EU TARIC database will sometimes give you the wrong duty rate for UK imports.
Never rely on the EU TARIC database for UK import duty calculations. Since Brexit, the UK Global Tariff has its own rates and measures that diverge from EU ones. Always use the official UK Trade Tariff tool at gov.uk/trade-tariff to get the correct rates for Great Britain imports.
The commodity code you declare on your import entry determines three things simultaneously: how much import duty you pay, whether any anti-dumping or safeguard measures apply, and whether you're eligible for preferential (zero or reduced) duty under a free trade agreement. Getting it wrong in any direction has consequences.
If you underclassify goods — deliberately or accidentally — HMRC can issue a customs audit and demand backdated duty plus penalties. Post-import audits can look back up to three years, so a classification error made when you started sourcing can come back with a substantial bill attached. We've seen UK importers face five-figure duty demands from errors that looked minor at the time.
Overclassification — where your goods are assigned to a higher-duty code than they should be — means you're silently paying more duty than you owe on every single shipment. Most businesses never discover this because they don't routinely review their codes. Over a year, this can add up to thousands of pounds in unnecessary cost.
Since Brexit, the UK Trade Remedies Authority (TRA) has been conducting its own anti-dumping and countervailing duty reviews independently of the EU. This means some categories of goods — particularly steel products, ceramics, certain chemicals, and bicycle parts — carry additional trade remedy duties in the UK that aren't reflected on the EU TARIC schedule. The rate is applied per commodity code, so misclassification can result in either inadvertently avoiding (a legal risk) or paying (a cost risk) these additional measures.
Every UK importer building a pricing model needs an accurate landed cost. That means: FOB price + freight + marine insurance + UK import duty + UK VAT (at 20%) + customs broker fees + delivery to warehouse. If you're using the wrong duty rate — because you looked it up on the wrong database, or guessed based on a similar product — your margin calculation is flawed from day one. We see this regularly with clients who come to us after discovering their financials don't stack up.
The UK Global Tariff (UKGT) came into force on 1 January 2021 as the UK's independent trade policy regime. It was designed to be simpler and lower than the EU's Common External Tariff (CET) in many categories, whilst maintaining protections for specific domestic industries.
Some categories — particularly agricultural goods, steel, and certain food products — operate under Tariff Rate Quotas (TRQs). Within the quota, a lower (or zero) duty rate applies. Once the quota is exhausted, the out-of-quota rate — which can be significantly higher — applies for the rest of the year. UK TRQs are managed by HMRC and the Rural Payments Agency, depending on the product category.
For most UK importers sourcing manufactured goods from China and Vietnam — clothing, electronics, homewares, pet products, health and beauty — TRQs are not typically relevant. They matter most in food, steel, and agricultural sectors.
| Category | EU CET Rate | UK Global Tariff Rate | Impact for UK Importers |
|---|---|---|---|
| Electronics & components | 0–14% | 0–3.7% (simplified) | Lower duties in many cases |
| Clothing & textiles | 6.5–12% | 6.5–12% (broadly unchanged) | Similar — UKVFTA matters here |
| Furniture & homeware | 2.7–5.6% | 0–5.6% (some reductions) | Marginal improvements |
| Sports & gym equipment | 2.7–4.7% | 0–4.7% | Some categories at zero |
| Footwear | 3.7–17% | 3.5–16.9% | Broadly unchanged |
| Pet products (non-food) | 0–3.7% | 0–2.5% | Slight reductions |
Note: Rates are indicative and subject to change. Always verify the current rate for your specific 10-digit commodity code via the UK Trade Tariff tool before making commercial decisions.
The UK has been actively reviewing and adjusting its tariff schedule as part of its post-Brexit independent trade policy. Several changes have been either implemented or consulted on during 2025–2026 that UK importers should be aware of.
The UK Government has periodically granted tariff suspensions — temporary reductions to zero duty — on specific goods where there is no sufficient domestic production and UK businesses need access to lower-cost imports. These suspensions are applied at the commodity code level and typically run for one to three years. As of 2026, active suspensions cover categories including certain industrial machinery parts, chemical intermediates, and specialist raw materials.
If you're importing goods that aren't manufactured in the UK and that face a meaningful duty rate, it's worth checking whether a tariff suspension applies to your specific commodity code. This is something our team at Epic Sourcing reviews for all new clients as part of the initial commercial scoping.
The UK's steel safeguard measures — which impose additional tariffs on steel imports above quota thresholds — have been reviewed and adjusted. UK businesses importing steel products (HS Chapters 72–73) or products with significant steel content need to monitor the Trade Remedies Authority decisions that directly affect their commodity codes. Safeguard duties can add a meaningful percentage above the base UKGT rate.
The Trade Remedies Authority continues to initiate and conclude investigations that can alter effective duty rates with relatively short notice. Recent and ongoing investigations in 2025–2026 have touched on categories including ceramic tiles, glass fibre fabrics, bicycles and e-bikes, and various chemical products. If your product category is under investigation or subject to an existing measure, you need to know — the additional duties can be substantial and are applied retroactively from the date of provisional measures.
Register on the Trade Remedies Authority's case management system at investigate.trade-remedies.service.gov.uk to receive notifications about investigations affecting your product categories. It's free and could save you from an unexpected duty bill.
The UK joined the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) with effect from December 2024. Whilst the immediate impact on China and Vietnam sourcing is limited — neither country is a CPTPP member — CPTPP membership signals the UK's direction of travel for trade policy and opens new preferential supply options from member countries including Malaysia, Vietnam (non-CPTPP route) via the UKVFTA, Japan, and others. For UK sourcing agents and importers thinking long term, understanding CPTPP will matter increasingly through 2026 and beyond.
This is one of the most significant commercial opportunities available to UK importers right now, and one that most businesses are not fully exploiting. The UK-Vietnam Free Trade Agreement (UKVFTA) came into force on 1 January 2021 and provides preferential (zero or reduced) duty rates on qualifying goods sourced from Vietnam.
Under the UKVFTA, approximately 65% of tariff lines were set at zero immediately upon entry into force. The remaining lines are being phased down over a period of up to 10 years, with the eventual coverage reaching 99.2% of tariff lines. For many of the product categories that UK businesses import from Asia — clothing, footwear, furniture, electronics — the UKVFTA offers meaningful duty savings compared to importing the same goods from China under the standard UKGT MFN (Most Favoured Nation) rate.
| Product Category | Typical HS Chapter | UK Duty from China (MFN) | UK Duty from Vietnam (UKVFTA) | Indicative Saving per £100k FOB |
|---|---|---|---|---|
| Cotton clothing | Ch. 61–62 | 10–12% | 0–4% (phased) | £6,000–£12,000 |
| Footwear (leather) | Ch. 64 | 8–17% | 0–6% (phased) | £8,000–£17,000 |
| Furniture | Ch. 94 | 0–5.6% | 0% | £0–£5,600 |
| Bags & leather goods | Ch. 42 | 2.7–3.7% | 0% | £2,700–£3,700 |
| Electronics assemblies | Ch. 85 | 0–3.7% | 0% | £0–£3,700 |
Indicative duty savings per £100,000 FOB value, based on approximate rate ranges. Always verify current rates on the UK Trade Tariff before making sourcing decisions.
To claim UKVFTA preferential duty rates, your goods must meet the Rules of Origin (RoO) requirements set out in the agreement. This means the goods must genuinely originate in Vietnam — not merely transit through Vietnam from China. The specific RoO requirement varies by product category but typically involves one of three tests: wholly obtained (for agricultural products), change in tariff heading (CTH), or value added (regional value content). For manufactured goods, the CTH test is most common.
In practice, this means that a product assembled in Vietnam from Chinese-origin components may or may not qualify, depending on whether the assembly process is substantial enough to achieve a change in tariff heading. This is a genuine compliance risk — if HMRC determines your goods don't meet RoO requirements, you'll owe the full MFN duty rate plus potential penalties.
To prove origin, you'll need either a EUR.1 movement certificate (issued by Vietnamese customs) or a REX (Registered Exporter) declaration from your Vietnamese supplier. Make sure your supplier can provide the correct documentation before you factor UKVFTA savings into your pricing model.
There is only one authoritative source for UK commodity codes: the UK Trade Tariff, available at gov.uk/trade-tariff. Everything else — broker rate cards, supplier-provided codes, online commodity code checkers — should be treated as a starting point for verification, not a definitive answer.
The tool has both a search function (enter a product description or keyword) and a browse function (navigate by HS chapter and heading). For new products, we recommend using both: start with the keyword search to find candidate codes, then navigate the chapter structure to confirm you've landed in the right place and understand the adjacent codes.
For each commodity code, the tool shows:
For high-value or high-volume imports where the classification is genuinely ambiguous, it's worth applying for a Binding Tariff Information (BTI) ruling from HMRC. A BTI is a legally binding decision on the correct commodity code for your product, valid for three years. It gives you certainty that HMRC won't challenge your classification during an audit. The application process involves submitting a product description, samples if relevant, and any technical specifications. HMRC aims to issue BTI rulings within 120 days.
Understanding commodity codes is only one part of customs compliance. The systems and registrations you need to actually import goods into the UK are equally important.
The Customs Declaration Service (CDS) is HMRC's digital platform for customs declarations. It replaced the old CHIEF (Customs Handling of Import and Export Freight) system. All import and export customs declarations for Great Britain must now be submitted through CDS — or via a licensed customs agent or broker acting on your behalf.
If you use a freight forwarder or customs broker (which we recommend for most SME importers), they will handle CDS declarations for you. However, you should understand what's being declared in your name, because legal responsibility for the accuracy of the declaration sits with the importer of record — you.
An Economic Operators Registration and Identification (EORI) number is mandatory for all UK businesses importing goods from outside the UK. If you don't have one, your goods will be held at the port — Felixstowe, Southampton, London Gateway — until the issue is resolved, and storage charges accumulate quickly.
Your UK EORI number starts with "GB" followed by your VAT registration number and three additional digits (e.g., GB123456789000). You can apply for an EORI number via the HMRC website and it's typically issued within five business days. If you're VAT-registered, the EORI is linked to your VAT number automatically.
HMRC can conduct post-import audits going back up to three years from the date of import. If an audit reveals systematic misclassification — particularly under-declaration of goods to a lower duty rate — the consequences include back-payment of all underpaid duty, a potential surcharge of up to 30% of the duty owed, and in serious cases, referral for criminal investigation. The burden of proof that a classification was made in good faith sits with the importer.
If you're uncertain about your commodity code, get professional advice before you import, not after.
UK import VAT (currently 20% for most goods) is charged on the customs value of the goods plus any duty paid. If your business is VAT-registered, you can reclaim import VAT on your VAT return using Postponed VAT Accounting (PVA) — a scheme introduced in January 2021 that allows you to account for import VAT on your VAT return rather than paying it upfront at the port. This is a meaningful cash flow benefit. Make sure your customs broker is declaring PVA on your import entries.
On a CDS import declaration, the commodity code is entered in Data Element 6/14. It must be the full 10-digit code. Your customs broker or freight forwarder should confirm this with you before submitting the entry — and if they're using a code you've provided, make sure you've verified it yourself via the UK Trade Tariff tool.
After years of supporting UK businesses with sourcing and importation, here are the classification errors we see most frequently.
Chinese and Vietnamese manufacturers often include an HS code on their commercial invoices and packing lists. This code is their export classification for Chinese customs purposes — it is not necessarily correct for UK import classification. The legal responsibility for the UK import declaration rests with the UK importer, not the overseas supplier. Always verify the code independently using the UK Trade Tariff tool.
A common error is to classify a product by what it's made of rather than what it is. The HS system is structured primarily by function and product type, with material as a secondary consideration. A plastic garden chair sits in Chapter 94 (furniture) under the relevant chair heading — not in Chapter 39 (plastics) just because it's made of plastic. The legal chapter notes clarify these distinctions, but they require careful reading.
If you import a range of products — say, a collection of homeware items including candles, picture frames, and storage baskets — each product category has its own correct code. Using one code across all of them because it's administratively convenient is misclassification. If the codes attract different duty rates, this matters commercially too.
If your product specification changes — new material, new function, different construction — the commodity code may need to change too. A product update that shifts from cotton to polyester, or adds a built-in battery, can change the applicable chapter entirely. Build a commodity code review into your product development process.
The UK Trade Remedies Authority has extended several anti-dumping measures that existed before Brexit and has added new ones. These are applied on top of the UKGT duty rate and are specific to origin country. A business importing from China at what they think is a 6% duty rate might actually owe 6% UKGT plus 48% anti-dumping duty — if the product falls within a TRA measure for that commodity code and origin. Always check the "measures" tab for your commodity code on the UK Trade Tariff tool.
Navigating commodity codes, tariff rates, UKVFTA eligibility, and UK customs compliance whilst running a product business is a significant administrative burden. At Epic Sourcing, we make sure this work is done correctly so you don't carry commercial or legal risk from misclassification.
Our team works with UK businesses across a wide range of product categories — clothing, homeware, electronics, pet products, health and beauty, sporting goods — sourcing from China and Vietnam. Here's how we support clients at different stages.
From £699
Perfect for businesses sourcing existing products. We find pre-made goods that match your spec, verify the supplier, and handle your import documentation — including commodity code verification and landed-cost modelling. Learn more →
From £1,899
For businesses developing their own branded products. We manage the full sourcing process from manufacturer identification to sample sign-off, and ensure your product's classification is correct before you commit to volume orders. Learn more →
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Full product development and sourcing — from concept to market-ready product, with exclusive supplier arrangements, NDA-backed confidentiality, and full compliance review including UKCA requirements, EORI setup support, and tariff optimisation. Learn more →
From £299
Already have a supplier but not sure if they can genuinely provide UKVFTA origin documentation? Our on-the-ground team in China and Vietnam can verify your supplier's manufacturing capability and compliance documentation. Learn more →
Book a free 30-minute consultation with the Epic Sourcing UK team. We'll review your current commodity codes, check whether UKVFTA applies to your products, and identify any quick wins on your landed cost.
Book Your Free ConsultationIn practice, the terms are used interchangeably by most UK importers, but there is a technical distinction. An HS code (Harmonised System code) refers specifically to the first 6 digits of the international classification — standardised across all WCO member countries. A UK commodity code is the full 10-digit code used in the UK Trade Tariff for import declarations. The 10-digit UK commodity code includes the HS code as its first six digits, with four additional digits that are UK-specific and determine the precise duty treatment. When your supplier in China quotes you an "HS code," they're usually giving you China's 10-digit export tariff code — which starts with the same 6-digit international HS as the UK code but differs in the final four digits.
Not quite. UK import declarations use the full 10-digit commodity code. UK export declarations use an 8-digit code — which is the first 8 digits of the import commodity code. So they're related, but not identical. If you're both importing finished goods and exporting them (for instance, selling to EU customers), you'll need both versions. Your customs broker or freight forwarder will manage this on your behalf, but it's worth understanding so you know what to check on their declarations.
There are two requirements. First, your specific commodity code must be eligible for a preferential duty rate under the UKVFTA — you can check this on the UK Trade Tariff tool by selecting "Vietnam" in the country preferences. Second, your goods must meet the Rules of Origin requirements: they must genuinely originate in Vietnam, as defined by the product-specific rule for your tariff heading. Your Vietnamese supplier must be able to provide either a EUR.1 certificate or a REX declaration as proof of origin. If both conditions are met, you can claim the preferential rate on your CDS import declaration. We strongly recommend verifying your supplier's origin documentation before making commercial decisions based on UKVFTA savings.
HMRC can issue a Post Clearance Demand Note (C18) requiring you to pay any underpaid duty, plus interest. They can also issue a penalty depending on whether the misclassification was deliberate, careless, or a genuine mistake made in good faith with reasonable care. If you applied for a Binding Tariff Information (BTI) ruling and classified in accordance with it, you have a strong defence. If you used a code provided by your supplier or guessed without professional review, your defence is much weaker. The best approach is to get your classification right from the start — or to seek a BTI if you're uncertain — rather than relying on HMRC not noticing.
Legally, no — an EORI-registered business can submit its own CDS declarations. In practice, yes — unless you have a specialist in-house customs team, the complexity of CDS declarations, commodity code verification, duty calculation, and customs procedure codes makes using a licensed customs broker essential. Errors on customs declarations can result in goods being held, delays at Felixstowe or Southampton, and post-import audit liabilities. A good UK customs broker will charge £30–£80 per import entry on straightforward shipments — modest relative to the risks of getting it wrong. Epic Sourcing works with trusted UK customs brokers who specialise in China and Vietnam origin shipments and can recommend a partner for your business.
Whether you're setting up your first import or reviewing your landed-cost model, Epic Sourcing's UK team can help you get your commodity codes right, your supplier verified, and your tariff strategy optimised.
We're based in London (71–75 Shelton St, WC2H 9JQ) and work with UK brands at every stage — from first-time importers to established businesses scaling their supply chain.
