EUDR and the importance of HS and TARIC codes - What companies need to know now

Executive Summary

The HS Code is a six-digit, globally recognized system for classifying goods in international trade. The EUDR integrates it to identify affected goods and their due diligence requirements. The TARIC code is an EU-specific extension of the HS code with up to ten digits, which maps additional EU measures such as customs duties and import restrictions. The EUDR uses TARICs to determine which goods are subject to due diligence.

The connection between the two codes is central: their combination ensures that goods are correctly classified, subjected to a due diligence check and identified as deforestation-free.

Companies can find the relevant HS codes via EZT-Online (German customs platform) and TARIC codes in the European Commission's EU customs tariff database. In addition, the EUDR Regulation itself contains information on the codes concerned.

Difference between HS codes and TARIC codes

The HS Code, or Harmonized Commodity Description and Coding System, forms the basis for international trade classification. This six-digit code is used worldwide to systematically classify goods and facilitate trade between different countries. The structure of the HS Code follows an internationally recognized scheme, which enables a standardized classification and thus ensures transparency and uniformity in global trade. Exports require an extension to eight digits (combined nomenclature), while imports require up to ten or sometimes eleven digits (customs tariff numbers and national characteristics).

It can be summarized that within the EU, the HS code is supplemented by two digits for the nomenclature. The additional digits in the ninth and tenth positions indicate the TARIC. It provides information on EU measures such as additional customs duties, while the eleventh digit describes national regulations such as bans or restrictions.

TARIC codes: A comprehensive overview

The legal basis of TARIC is Regulation (EEC) No. 2658/87 of July 23, 1987, which regulates the tariff nomenclature and the Common Customs Tariff of the EU.

TARIC harmonizes EU-specific requirements in trade and comprises two main categories of measures:

• Tariff measures regulate tariff rates and preferences vis-à-vis third countries, tariff quotas and temporary tariff suspensions. In the agricultural sector, there are also specific regulations on additional duties and price fixing.
• Non-tariff measures include trade policy instruments such as anti-dumping and countervailing duties, import and export bans for certain countries or goods and the control of sensitive goods. These include CITES goods, dual-use goods and luxury goods. Veterinary and phytosanitary controls also ensure compliance with safety standards.

Overall, TARIC ensures that all import and export processes comply with EU directives and that integrity and sustainability in international trade are guaranteed.

The structure of HS and TARIC codes using the example of hangers

A comparison using the example of wooden clothes hangers illustrates the practical use of these codes. The HS code for your product can provide general information about the product group, while the TARIC code provides specific customs duties or trade-related requirements for imports into the EU. Together, these codes act as a comprehensive system to increase efficiency and regulate international trade activities.

Determination of HS and TARIC codes in the EUDR

The Harmonized System Codes (HS codes) and the TARIC (Integrated Tariff of the European Communities) play a decisive role in the implementation of the EU Regulation on the prevention of deforestation (EUDR). These codes serve as a basis for the clear identification of product groups that could be affected by the regulation.

The C-codes relate to the declaration on the fulfillment of due diligence obligations

However, when products covered by the EUDR are imported or exported, it is not immediately possible to determine whether or not they are covered by a due diligence declaration using the existing TARIC alone. For this reason, the EU Commission has published new TARICs in connection with the EUDR, which enable customs to quickly identify whether a relevant product meets the requirements of the EUDR or not.

TARIC code C716

The TARIC document code C716 is important. This indicates that a due diligence declaration is available and that the product may be put into circulation. In practice, this means that if a due diligence declaration is available for the goods in question, the TARIC code C716 must also be indicated on the customs declaration in addition to the full customs tariff number from the date of application of the regulation. When creating the customs declaration, specific entry fields are provided for each of this information, including any additional information such as the description of the goods.

TARIC code C717

Furthermore, a new TARIC code C717 is introduced, which is relevant for SME market participants that are exempt from due diligence under Article 4(8) EUDR. In other words, affected SMEs do not have to assume due diligence obligations for already declared relevant products that already comply with the due diligence obligation and for which a due diligence declaration is available. This code must be provided to customs if companies are not required to carry out due diligence on products that are already subject to declaration and for which a due diligence declaration is available. C717 serves as a reference number for the previously submitted due diligence declaration.

The logic after the simplifications at the end of 2025 is important here. The responsibility for the formal DDS generally lies with the first distributor, and the obligation to collect and retain reference numbers primarily affects the first downstream operator in the chain. This reduces duplication of work without the quality of the upstream checks losing any of its importance.

The Y-codes refer to specific exceptions

Y-codes provide specific information on exemptions that are particularly important for small and medium-sized enterprises (SMEs). They also include relevant regulations for goods manufactured from materials whose life cycle is already complete.

A new TARIC code Y129 has been introduced for the "ex" codes in Annex I of the EUDR. The code refers to the declaration of goods that do not fall within the scope of the Regulation, so-called "ex" products. Here it is necessary for the declarant to be able to indicate that the Regulation does not apply to the import, even if the declared product is assigned to a nomenclature code covered by the EUDR.

The TARIC code Y132 refers specifically to Art. 1 para. 2 EUDR. It states that the provisions of the EUDR do not apply to the relevant products listed in Annex I if they were manufactured before the date specified in Art. 38 (1) EUDR, i.e. before the period of validity of the EUDR.

TARIC code Y133 defines an exemption in accordance with the second paragraph of Annex I of the EUDR, according to which the Regulation does not apply to goods made entirely of materials whose life cycle has been completed. These products are considered recycled.

The TARIC code Y141 is used to indicate the transitional arrangement in accordance with Article 38(3) of the EUDR in the customs declaration. This applies to market participants who are considered natural persons or micro or small enterprises and already existed in this form on December 31, 2024. For this group, the application of the central EUDR obligations will be postponed to June 30, 2027. This is relevant because it also postpones the question of when EUDR-specific evidence and references are expected in the customs process. At the same time, this simplification does not apply in all constellations, as different rules may apply to certain timber and timber products that were already subject to the previous EU timber trade logic. It is therefore always worth checking Y141 in the context of the specific product, your own role and the current TARIC status.

In addition, the TARIC code Y142 was introduced, which applies to customs declarations in connection with non-commercial activities. In this respect, this code refers to the definitions mentioned in Art. 2 No. 15, 17, 18 EUDR.

The Combined Nomenclature (CN) and TARIC are seamlessly integrated into the EUDR to ensure a clear classification of products that may contribute to deforestation. This codification not only facilitates the administrative process, but is also an indispensable tool for companies engaged in international trade. With its help, companies can precisely determine whether their goods meet the requirements of the regulation and what regulatory steps are required to ensure compliance.

These codes play a central role in risk analysis and the preparation of due diligence declarations. By precisely categorizing products, companies are able to more effectively identify potential risks in their supply chains and implement appropriate risk mitigation measures. The ability to successfully identify and apply the relevant codes for their products is therefore an essential part of the strategic planning and implementation of EUDR compliance.

Obligation to declare raw materials and end products - What applies when?

The obligation to notify raw materials and end products is a crucial aspect of the EUDR. Above all, the question arises: if a raw material is affected by regulation, does this automatically apply to the resulting end product? The answer is complex and depends on various factors. The obligation to collect and hold reference numbers practically only applies to the first downstream actor, as the transfer along the entire chain was explicitly defused at the end of 2025.

An end product becomes EUDR-relevant if it fulfills certain criteria. These include the CN heading, the level of processing and the ex designation of the product. The CN heading, also known as the Combined Nomenclature, is an important factor as it regulates the classification of goods in international trade and helps to determine the regulatory requirements. The level of processing and the ex designation also provide information on the extent to which a product is affected by regulation.

Examples of product classifications are helpful to illustrate this.

Practical implementation for companies

Companies involved in international trade face the challenge of using correct and up-to-date HS (Harmonized System) and TARIC (Integrated Tariff of the European Communities) codes. Accurate classification of goods is essential to fulfill customs obligations and avoid potential legal risks. Regularly checking and updating these codes within the company is therefore of great importance.

Cooperation between the customs department, purchasing and product management plays a central role here. An effective internal exchange ensures that all relevant departments are always up to date and work together on the correct classification of goods. This not only prevents delays in the operational process, but also promotes compliance with legal regulations.

In order to manage the complexity of tariff classification effectively, companies should ensure that their goods are classified correctly. The use of practical instructions and digital aids such as the EU customs tariff database (TARIC) and EZT-Online is recommended for this purpose. These tools enable precise and efficient classification and help companies to achieve their compliance goals in the long term.

Conclusion

Commodity codes are the basis for EUDR-compliant, transparent supply chains and compliance with legal requirements. Incorrect classification can result in significant regulatory risks, such as import and export bans.

Companies should therefore establish a structured process for regularly reviewing and updating their HS and TARIC codes. All changes should be fully documented to facilitate internal audits and transparent reporting.