St David's Day classification special: commodity codes for classic Welsh exports

Wed 1 Mar 2023
Posted by: William Barns-Graham
Features

Welsh products, including Daffodils and Welsh cakes as part of a tea set with flag of Wales in background

Dydd Gŵyl Dewi Hapus! Or happy St David’s Day to our non-Welsh readers.

St David was a renowned preacher who founded monastic settlements and churches throughout Wales. According to Visit Wales, he “made a pilgrimage to Jerusalem, from which he brought back a stone that now sits in an altar at St Davids Cathedral, built on the site of his original monastery.”

Daffodils and leeks have since become symbols of both the saint and the country of Wales, but the country is also well known for Welsh cakes, Glamorgan sausages and lamb, among other things.

However, since Brexit, Welsh businesses have had to comply with new customs obligations to export such products to ‘Cambrophiles’ (or people who love Wales) abroad. This includes the requirement to correctly identify the commodity codes for your products, as we noted in our previous Valentine’s Day feature.

So what are the commodity codes you need to know if exporting classic Welsh products this St David’s Day?

Daffodils and leeks

Many a Welsh person will be wearing a daffodil in honour of St David, but searching for the flower on the UK Integrated Tariff tool online doesn’t come up with any immediate results.

Lyn Dewsbury, a customs and trade specialist at the Institute of Export & International Trade,  suggests looking up cut flowers instead.

Details of commodity code of Daffodils

“The section you could find daffodils in may actually be ‘vegetable products’,” she explains.

“If you go to chapter 6 and under heading 03, you’ll see there’s a section of the Tariff called ‘Cut flowers and flower buds of a kind suitable for bouquets or for ornamental purposes’ and this includes fresh flowers in sub-heading 11.

“Daffodils won’t come under the roses, carnations, orchids, chrysanthemums, lilies, gladioli or ranunculi sections, so you’re best bet is to go down to the second ‘Other’ code, which gives you the code 06031970.

“Remember that export codes are, at the moment at least, usually just eight digits long, particularly for trade with the EU.”

If you select Austria from the dropdown for countries you wish to export to, within the integrated tariff, you’ll see that the preferential duty rate for this commodity code is 0%, while an 8.5% duty rate may apply for other countries with which the EU sets Most Favoured Nation rates (eg those the bloc does not have a trade deal with).

Finding the commodity code for leeks is much easier as typing it into the search bar comes up with the suggested commodity code of 07039000. This falls under the ‘edible vegetables’ heading in the ‘vegetable products’ section of the Tariff. If you click through to see what rules apply for exporting it to another EU country, say Belgium, you’ll see that the preferential duty rate is again 0%, with an MFN rate of 10.4%.

Other classic Welsh foods

Leek is a delicious and versatile vegetable (at least among adults) which goes with several of the delectable meat products Wales is also well known for. For instance, Glamorgan sausages and Welsh lamb shanks. Let’s look at what duties may apply if you’re looking to send these products to the same Belgian importer.

For Glamorgan sausages, Dewsbury suggests the code 16010099, which has the catchy heading of ‘sausages and similar products, of meat, meat offal, blood or insects; food preparations based on these products’.

For Welsh lamb shanks, the suggested code is 02042250, which gets you to the ‘legs’ part under the ‘meat of sheep or goats, fresh, chilled or frozen’ heading.

For the lamb there is again a preferential tariff of 0% but there are certification requirements listed within the tariff tool. There is also a 0% preferential duty rate for the Glamorgan sausages.

Further good news for the lamb shanks exporters is the recent news that the government has lifted restrictions on Welsh lamb in the US market. 

“We identify the blockers faced by UK businesses in getting their goods and services into other countries, and we get rid of them,” said trade and business secretary Kemi Badenoch last night. “That’s meant, for example, getting Welsh lamb back on US dining tables for the first time in 20 years.”

However, a slight caveat for Welsh meat exporters is that St David was apparently a teetotal vegetarian, according to Visit Wales.

Welsh cakes

Welsh cakes are also one of the best-loved Welsh culinary products out there, but aren’t as readily available overseas as they are in Cardiff. So how would a hypothetical company called Dewi Sant’s Bakery go about classifying a ‘bake your own Welsh cakes’ kit for sale in Germany?

The kit contains the following ingredients, alongside instructions for making the cakes:

  • 8oz of flour
  • 2oz of caster sugar
  • 2oz of sultanas

Purchasers of the kit are asked to buy two eggs and four ounces of margarine independently of the other ingredients. Dewsbury suggests the following commodity codes for each of the ingredients, noting the preferential duty rates and other conditions indicated on the tariff tool for export to Germany:

However, Dewsbury notes that within the World Customs Organization’s set of General Rules of Interpretation (GIRs) there is the recommendation to classify the kit using one commodity code – that of the product that gives the kit its ‘essential character’.

“Under GIR3b, you could classify the whole kit under the component that gives it its essential character,” she says. “This could, for example, be the flour, which would allow you to classify the kit under 11051000.”

She adds that there other rules that could impact the correct classification including GIR 3c.

“This rule is used when 3a or 3b cannot be used,” says Dewsbury. “With this rule, the kit would be classified under the commodity code which occurs in last numerical order among those component parts which merit equal consideration. If all the ingredients are viewed as being equally important to the recipe, then the latest commodity code you would use, under this rule, would be 17019990 for caster sugar.”

She adds that in such instances, getting expert advice is recommended and that you may want to consider applying for an Advanced Tariff Ruling (ATR) for British exports or a Binding Tariff Information (BTI) for Northern Irish exports.

“Commodity classification can be a difficult task for new exporters and expert advice is definitely recommended,” she says.

Learn about classification

It’s for this reason that the IOE&IT runs multiple training courses covering customs classification.

This includes the bespoke ‘How to classify your goods’ course, which looks at the principles and rules of classification in depth, and ‘Customs procedures and documentation’, which covers classification within the wider context of the various skills and expertise needed to comply with customs requirements.

For more information about the IOE&IT’s suite of training courses, visit https://www.export.org.uk/page/training

This article is for educational and entertainment purposes only. It does not constitute legal advice on any of the commodities included.