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Let’s look at how to do HS classification for hand sanitizers. For this case study, we shall make a few assumptions such as:
- The product is manufactured in Singapore
- The product is packaged in a small bottle and can be placed at entrances to buildings on in offices for staff to use
- The product is in the form of a gel
- The product’s main active ingredient is ethyl alcohol, although there are other chemicals in the mixture as well
Having understood the product, we can consider classifying the product as:
- Ethyl alcohol
- Sanitation product
- Generic chemical product
Before proceeding further, we should also look at any information we can find in the news about the HS classification for this product.
A quick search on the internet reveals that the WCO has issued guidelines on the classification of hand sanitizers, and considers them to be correctly classified under HS3808. However, it is also apparent that US rulings seem to consider these correctly classified under HS3824 instead.
We search the Singapore Customs website and do not find any information relating to the classification of hand sanitizers.
Check the Section & Heading Notes
We need to apply the General Interpretative Rules for the classification of the product, however, we are unclear as to how the product should be considered or described in the first place. This creates something akin to a “chicken and egg” problem!
But this may be clarified when we refer to the tariff notes for the Section and Headings. After reviewing the Section notes for Section 06, we see that the Notes require the product to be classified under Heading 3808 if it is in retail packaging. We go back to the supplier for information and let’s now assume that the supplier confirms that the product is in retail packaging.
Finalize the Sub-Headings and complete HS code determination for hand sanitizers
Finally, we can now confirm that the appropriate HS classification for the product in Singapore is 38089490. Of course, we should always review these classifications on a periodic basis to ensure that new rulings or new interpretations of the tariff are not adopted by local Customs authorities.