FAQ - Tariff Classification, Customs Planning, Ireland

	My agent looks after customs matters so I have no issues.

While your agent no doubt acts in your best interest however it is you the importer or exporter who is legally responsible for the accuracy on any declarations made to customs. It is the ultimate responsibility of the importer or exporter to ensure that the tariff classification, value, origin and customs procedures are correctly declared to customs.

	Why is the Tariff Classification of my goods so important?

The Tariff Classification of goods determines the rate of duty that is paid on goods. Establishing to correct classification for your goods is one of the key elements of customs planning in that that classification helps determine what customs procedures or relief’s are available to a company.

	Our existing customs practices are fine, why should I consider changing them?

Successful companies are in a constant state of evolution, refining manufacturing processes, logistical process, introducing new products, quality improvement programs and cost reduction programs. Your customs practices must also evolve to meet these changing circumstances.

	We have somebody in house who looks after customs, why should I get external help?

Many companies assign responsibility for customs matters to the logistics or finance department, the role often been subsidiary to the appointee’s main responsibilities. In such circumstances customs matters are often managed on an ad-hoc basis, which invariably means customs procedures and opportunities are not working to optimum capacity.

The competition beat us on price. Our material sourcing, manufacturing and logistical process are comparable if not better than theirs. I don’t understand.

Have you considered customs planning?

My customer has asked me to provide the ECCN number for my product. What is the ECCN, where do I get it?

The ECCN is the Export Control Classification Number that is assigned to products that are subject to Export Controls. Your product may be subject to EU and/or US Export Controls and may require an Export Licence before you can ship it. You need to establish if in fact your product is subject to such controls and if so you must comply with the relevant regulations.

How do I determine if my product is subject to Export Controls?

Initially you need to establish the ECCN for the product, this is known as the Control List Number in the EU. To do this you need to consult the list of Dual-use items in the EU Regulation on the Control of Exports of Dual-use items or the Commerce Control List (CCL) of the US Export Administration Regulations (EAR). If you product matches one of the descriptions in these lists then it is subject to control. The level of control will depend on, what your product is, where it is going, who will use it and what it will be used for.

N.B. The links provided are for information purposes only. You must verify that you are using the most up to date lists when determining the classification of your product.

	My product is made in Ireland, why do you say that it may be subject to US Export Controls?

If the product that you make incorporates a US component (technology or software) and that component would normally be subject US controls, this may result in you product becoming subject to control. The basis is normally on the value of the component against the value of your finished product.