The World Health Organization(WHO) and the World Customs Organization (WCO) have jointly published a reference document listing the HS classification of medical equipment being heavily traded in response to the Covid-19 pandemic. Items in the publication span several categories such as protective garments (i.e. face masks), disinfectants (i.e. hand sanitizers), medical devices (i.e. ventilators), and medical consumables (i.e. test kits). The document provides an indicative standard reference to Customs authorities all over the world, although it does NOT have legal status in any country. All HS codes provided are based on the HS 2017 nomenclature.

View our case studies to better understand how to use WCO memos to avoid costly Customs compliance issues.

Nonetheless, WCO’s position on the HS classification of these items allows governments to quickly implement any temporary tariff and/or non-tariff barriers or facilitations as deemed required. Also, this publication can be a useful reference to traders moving these products across borders.

Several questions have been raised with respect to HS codes in the WCO publication and we attempt to answer them here.

What is the HS Code of Surgical Masks?

The publication lists 3 different HS codes: 4818.50, 9020.00 and 6307.90. Importers should note that surgical face masks made of textiles and N95 particle respirators are classified under 6307.90. Paper masks however, are classified under 4818.50. If there is any confusion about what kind of mask you are trying to ship, it is best to get in touch with the supplier for clarifications or review the packaging box for information. Typically, paper masks are used in the food and beverage industry (i.e. to keep saliva from the food server from reaching the food) while surgical masks are used in laboratories and hospitals, to prevent contamination both ways.

What is In Vitro Diagnostics?

In vitro diagnostics refers to any test done on tissue or blood that has already been removed from the patient. Such a test is typically done in a laboratory.

What do Infusion Pumps have 2 HS codes?

The publication does not have legal status, although both the WCO & WHO can assume to have shared the most accurate information to the best of their knowledge. The correct HS classification of infusion pumps may be debatable as different Customs authorities have different views. Also, different pumps may be put under different HS codes. Moreover, there may already exist conflicting views in different countries and hence it is advisable to reach out to Customs authorities to confirm the correct HS code for this type of product.

What about the HS code for disinfectants or hand sanitizers that are not based on Ethyl alcohol?

Be aware that some disinfectants may come under HS codes that are not mentioned in the WCO publication. For example, disinfectants that are based on isopropyl alcohol may be classified under HS290512, if they meet the certain conditions such as being shipped in bulk quantities instead of being individually packed. The rules of HS classification still apply regardless of how you interpret the WCO document.

A final word…

When referring to the publication, traders should keep in mind that this is not a legal document, while local Customs regulations are. If in doubt, traders should reach out to authorities for clarification where possible.

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