Certificate of origin and HS code mistakes on food shipments

Last updated: 17 October 2026. Codes and origin rules differ by country and trade agreement. Confirm each point with your customs broker.

The HS code says what the goods are. The proof of origin says where they come from. Duty, licences, certificates and quotas depend on these two facts, so customs authorities can compare them across your documents. This guide lists the mistakes to check for.

How HS codes work.

• The Harmonized System is the international product classification. Each country applies it through its own tariff and may add digits. In the US, the USITC publishes the Harmonized Tariff Schedule (HTS), which is searchable online and revised during the year.
• The US importer of record must use "reasonable care" when making entry, which includes the declared value, the classification and the rate of duty (19 U.S.C. 1484). The statute does not define reasonable care.
• Importers can ask CBP for a binding ruling on classification before importing. Under 19 CFR Part 177, the requester needs a direct and demonstrable interest and must describe the transaction fully. Classification requests go to the National Commodity Specialist Division in New York. A ruling is binding on CBP personnel until modified or revoked, and other parties should not rely on a ruling for a different transaction.
• CBP's CROSS database of published rulings is free to search.
• In the EU, a Binding Tariff Information (BTI) decision binds all customs administrations and the holder. It is generally valid for three years, applies across the EU and is published in the EBTI database. The application needs an EORI number and covers one type of goods.
• In Great Britain, HMRC issues Advance Tariff Rulings. You must apply before customs procedures are complete. The ruling is non-transferable, and its reference goes in Box 44 of the declaration. For Northern Ireland and the EU, you apply for a BTI decision instead.

How proof of origin works.

The European Commission distinguishes two kinds of origin. Preferential origin applies under EU trade agreements and gives reduced or nil duty, and each agreement has its own rules of origin. Non-preferential origin shows that goods do not qualify for preferential treatment. For EU imports, the proofs include:

• Preferential certificates, issued by the exporting country's customs authorities. The form depends on the agreement: Form A, EUR MED, or EUR 1.
• Non-preferential certificates, normally issued by chambers of commerce.
• Invoice declarations. For consignments up to EUR 6,000, any exporter may issue one. Above that, only an approved exporter may.
• REX statements by a registered exporter on a commercial document. Registration is not required for consignments under EUR 6,000. REX is still being phased in, so it does not apply to every country or agreement.
• Binding Origin Information, issued by designated EU customs authorities, normally valid for three years if the goods and circumstances are identical.

Rules differ by agreement, and a rule for one partner does not carry over to another. Proof is presented at customs clearance. See also our guides to EU import documents and US label requirements, where the label must also show the country of origin.

Mistakes to look for.

1. The code differs between documents. The invoice, packing list, certificate, bill of lading and customs declaration show different codes.
2. The wrong digit level. A 6-digit code is used where the destination needs its national digits, or a code from another country's tariff is copied.
3. A description that does not support the code. For example, the invoice describes the product as raw, cooked, frozen or packed in a way that does not match the code's heading.
4. The origin differs between documents. The country on the certificate differs from the invoice, label or bill of lading.
5. The wrong form or issuer. The form does not match the agreement, or it comes from a body that does not issue that proof.
6. An invoice declaration above the threshold. The exporter is not approved or registered where the consignment value requires it.
7. The proof is missing or late. It is not available when the goods are presented for clearance.
8. The exporter differs. The name or address on the proof differs from the invoice.

Checks to run before you ship.

1. Compare the HS code across the invoice, packing list, certificates, bill of lading and customs declaration.
2. Check the destination's tariff for the national digits and for any licence, quota or certificate the code triggers.
3. Check that the product description on every document supports the code, including its state, such as raw, cooked, frozen or packed.
4. Check that the country of origin is the same on the invoice, certificates, label and bill of lading.
5. Check that the proof of origin matches the trade agreement, the issuing body and the consignment value.
6. Check that the exporter's name and address on the proof match the invoice.
7. Agree with your broker who presents the proof, and when.
8. If you are unsure of a code, ask the customs authority for a binding ruling where one is available. Keep a dated record of every check.

Common questions.

What is an HS code?

An international product code. The first six digits are the same in every country that uses the Harmonized System, and each country adds its own digits for tariff and statistics.

Who is responsible for the HS code on a US import?

The importer of record must use reasonable care when making entry, which includes the declared classification, value and rate of duty (19 U.S.C. 1484). A binding ruling from CBP can give certainty before you import.

Which proof of origin do I need?

It depends on the trade agreement and the destination. For EU imports, preferential proofs include Form A, EUR MED and EUR 1 certificates, invoice declarations and REX statements, and non-preferential certificates normally come from chambers of commerce. Check the agreement's rules for your product.

Sources.

• US Code, 19 U.S.C. 1484, entry of merchandise
• eCFR, 19 CFR Part 177, administrative rulings
• CBP, Rulings and legal decisions, including CROSS
• USITC, Harmonized Tariff Schedule of the United States
• European Commission, European Binding Tariff Information (EBTI)
• GOV.UK, Apply for an Advance Tariff Ruling
• European Commission, Access2Markets: rules of origin
• European Commission, Access2Markets: customs clearance documents and procedures

This guide is information, not legal advice. Ask your customs broker and the authority at the destination for the rules that apply to your product.