Product codes matched to the actual goods
The product code describes the article far more precisely than the tariff code does. Choose it carelessly and you have told FDA the shipment is something it is not.
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An FDA product code is a structured code identifying an imported article by industry, class, subclass, process and product. It is transmitted with the entry and determines how FDA assesses the shipment. A code that does not match the goods as presented is among the most frequent causes of a hold, and it is entirely avoidable.
Key takeaways
- The product code is more granular than the tariff classification and serves a different purpose.
- Codes describe process and presentation, not just the commodity.
- A near-enough code invites review the accurate one would not attract.
- Affirmations of compliance accompany the code and must be appropriate to the product.
- Consistency across repeat shipments matters as much as accuracy on the first.
Why the code is harder than it looks
Two products that look identical on an invoice can carry different codes depending on how they were processed, how they are packaged, or what they will be used for. A dried herb sold as a seasoning and the same herb sold as a supplement ingredient are not the same article to FDA.
The temptation is to pick something close and transmit. That works until the shipment is reviewed against a code that does not describe it.
Affirmations of compliance
Affirmations accompany the product code and assert specific things about the article — that it meets a particular standard, that a required registration exists, that a process was followed. Applying an affirmation that is not accurate is worse than omitting one, because it is a positive statement rather than a gap.
How it works
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01
Product examined
Specifications, composition, processing and packaging — not just the invoice description.
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02
Candidate codes identified
Usually more than one could arguably apply.
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03
Code selected and reasoned
With the rationale recorded, so a query two years later has a file behind it.
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04
Affirmations matched
Only those genuinely applicable to the article.
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05
Applied consistently
The same product is coded the same way on every subsequent entry.
Common mistakes
- Copying the code from a previous shipment. Products change, and similar is not the same.
- Using the supplier's suggestion unchecked. They are describing it for their market, not for U.S. entry.
- Ignoring how the product is presented. Retail packaging and bulk ingredient can code differently.
- Adding affirmations that sound right. An inaccurate affirmation is an affirmative misstatement.
- Coding inconsistently across entries. Three codes for one product in a year draws attention.
Questions
What is an FDA product code?
A structured code identifying an imported article by industry, class, subclass, process and product. It is more specific than the tariff classification and is used by FDA to assess the shipment at entry.
How is it different from the HTS code?
The HTS code determines duty and is a customs classification. The product code describes the article to FDA and influences how it is reviewed. They serve different agencies and different purposes, and both must be right.
What happens if the code is wrong?
At best the shipment is reviewed and released more slowly. At worst it is held while the discrepancy between the declared code and the actual goods is resolved, with storage accruing throughout.
Can a product have more than one valid code?
Sometimes more than one could arguably apply, which is why the reasoning matters. We record why a code was chosen so the position is defensible later.
Related
Tell us what you're importing.
Commodity, origin, port and arrival date is enough to start.