Combined Nomenclature (CN) – How It Works and Why It’s Key
What is Combined Nomenclature (CN)? Definition and Basic Purpose
Combined Nomenclature (CN) is the official eight-digit classification and coding system of the European Union that enables detailed classification and identification of goods for customs and statistical purposes. It was created as part of the harmonization of customs regulations and represents the backbone of customs and trade law in the EU and for countries trading with EU member states.
Main purposes of CN:
- Ensuring a uniform EU customs tariff (Common Customs Tariff): Every imported or exported product must be classified under a specific CN code, which determines the level of duty and any other trade policy measures.
- Statistical record and trade analysis: CN is the only binding classification for detailed data collection on international and intra-EU movement of goods (INTRASTAT, EXTRASTAT).
- Basic tool for calculating VAT and excise taxes: Many types of goods have special regimes according to CN (alcohol, tobacco, fuels, etc.).
The legal basis for CN is Council Regulation (EEC) No. 2658/87, which establishes not only its structure but also mandatory annual updates and alignment with the international Harmonized System (HS).
Relationship to world trade:
CN is a direct extension of the Harmonized System of Description and Coding of Goods (HS), which is managed by the World Customs Organization (WCO). The first six digits of the code are identical in countries using HS (more than 200 countries). CN adds two more digits for more detailed classification needed in the EU.
Why is Combined Nomenclature Key? Significance for Trade, Companies and Public Administration
Combined Nomenclature is absolutely crucial for the correct, efficient and legal functioning of international and intra-EU trade. Correct classification of goods according to CN has direct impacts on:
Calculation of duties and taxes
- Duty rate: Each CN code is assigned a specific duty rate that applies when goods are imported from non-EU countries into the EU.
- VAT and excise taxes: For many commodities (fuels, alcohol, cigarettes), CN determines whether and what rate of excise tax or VAT applies.
- Incorrect classification: Causes not only financial losses (payment of higher duties, fines, additional assessments) but also the risk of goods seizure or delays in customs proceedings.
Application of trade policy measures
The CN code is essential for identifying goods subject to special measures:
- Anti-dumping and countervailing duties: Specific only to certain CN codes.
- Customs quotas and ceilings: For example, for agricultural products, steel, textiles.
- Embargoes and sanctions: EU political measures (e.g., ban on imports of Russian oil, coal, steel, dual-use goods) are clearly defined using CN codes.
- CBAM (carbon tax): The newly introduced carbon border adjustment mechanism is applied only to products defined by specific CN codes.
Compliance with regulations
- Permits, licenses: For example, for imports of medicines, chemicals, weapons and ammunition, endangered species, goods subject to veterinary or phytosanitary inspection.
- Basis for quality control: The exact CN code determines whether certain certificates, documents, tests, etc. need to be submitted.
Collection and analysis of trade data
- Public administration and EU: Monitors trade balance, evaluates policy effectiveness, plans strategy.
- Companies: Identify market opportunities, analyze competition and trends based on statistical data collected at the level of CN codes.
How Does Combined Nomenclature Work? Structure, Hierarchy and Relationships to Other Systems
Structure of CN code
Combined Nomenclature is formed by a strictly hierarchical eight-digit code:
| Level | Number of digits | Example | Description |
|---|---|---|---|
| HS Chapter | 2 | 84 | Machinery and mechanical appliances |
| HS Item | 4 | 8408 | Piston engines, compression-ignition |
| HS Subheading | 6 | 8408 10 | Engines for vehicles |
| CN Subheading | 8 | 8408 10 90 | Other engines for vehicles |
- First 6 digits = Harmonized System (HS) – globally valid.
- 7th and 8th digits = European distinction for more detailed statistics and customs measures.
Relationship to classification systems
- HS (Harmonized System): The basis of all customs nomenclatures in the world, 6 digits, managed by WCO.
- CN (Combined Nomenclature): 8 digits, extension of HS for EU needs.
- TARIC (Integrated EU Tariff): 10 or more digits, additionally contains special trade policy measures (anti-dumping, quotas, duty suspensions, import bans, etc.).
- National codes: Some member states add additional digits for purely domestic purposes.
Legal framework of CN
- Council Regulation (EEC) No. 2658/87 – the basic European legal act for CN.
- Commission Implementing Regulations – annually issued updates to the nomenclature (effective always from January 1).
Rules for Classification of Goods: General Rules and Explanatory Notes
Correct classification into CN is governed by:
General Rules for Interpretation (GRI)
These rules (contained in Annex I to Regulation 2658/87) determine:
- Classification of incomplete or disassembled products
- Classification of mixtures and sets
- Determination of the essential character of goods
- Precedence of the article over the material
If a product can be classified into multiple items, the rule of “main purpose” or “essential character” applies (e.g., for multifunctional devices).
Explanatory Notes
- Explanatory Notes to HS (HSEN): WCO issues detailed descriptions of HS items.
- Explanatory Notes to CN (CNEN): The European Commission supplements HSEN with European specifics and examples.
- Notes to chapters and classes: Legally binding additions and notes in the nomenclature itself.
Explanatory Notes are not legally binding but are considered very authoritative interpretive aids. Customs authorities commonly follow them.
Tools for Correct Classification: TARIC, ECIT, Binding Information (ZISZ/BTI)
TARIC (Integrated EU Tariff)
- Official electronic database with daily updated information on all current customs and trade policy measures.
- For companies and customs declarants, a key source for finding current duties, quotas, bans, permits, etc.
- Czech version: ECIT (Electronic Czech Integrated Tariff) – supplements TARIC with national measures (e.g., VAT, excise tax, veterinary regulations).
Binding Information on Tariff Classification of Goods (ZISZ, BTI)
- Legally binding decision of the customs authority on the correct classification of a specific product.
- Valid for 3 years in all EU member states.
- Protects the company against retroactive duty assessments, fines, etc.
Annual Updates and Legislative Changes
Why and how does CN change?
- Technological progress: The emergence of new products (3D printers, drones, new materials) requires adjustments to the nomenclature.
- International changes in HS: HS changes approximately every 5 years. CN follows these changes.
- EU trade policy: New quotas, embargoes, anti-dumping measures.
- Statistical requirements: Need for more detailed data in some sectors.
Update procedure
- The European Commission issues Commission Implementing Regulations with an updated Annex I (full text of CN) every year in October.
- The new version is effective from January 1 of the following year.
Important: Companies must verify every year whether the codes of their products have not changed!
Practical Examples and Complexities in Classification
Examples from practice
- Steel sheets vs. automobile body: Steel sheets (CN 7208) are subject to CBAM, car bodies (CN 8707) are not. The final state of goods upon import is decisive.
- Gift sets: A basket containing wine, cheese and biscuits. It is classified according to the component that gives it essential character (probably wine).
- Multifunctional devices (smartwatches): Classification according to main function (watch vs. data processing device).
- New technologies: Drones, 3D printers – requires interpretation and often individual binding information.
Challenges
- Subjectivity: Different opinions between customs authorities and experts.
- Constant changes: New products, materials, trade measures.
- International differences: HS is global, but CN and TARIC are specific to the EU.
Glossary and Useful Terms
| Term | Meaning |
|---|---|
| HS (Harmonized System) | International standard of 6-digit commodity codes (WCO) |
| CN (Combined Nomenclature) | 8-digit EU code, extension of HS |
| TARIC | Integrated EU Tariff, 10+ digit, online database of trade measures |
| ECIT | Electronic Czech Integrated Tariff, Czech version of TARIC |
| ZISZ / BTI | Binding Information on Tariff Classification of Goods |
| Commission Implementing Regulation | Annual update of CN text |
| Explanatory Notes to CN | Detailed informal descriptions and examples of CN items, issued by the European Commission |
Česká Lípa, Czech Republic 
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