HS code: cost of mistakes in customs clearance
Wrong code = duty re-assessment + fine. How we pick the code and what to do if FCS disagrees.
April 28, 2026
Every imported or exported product is classified by a 10-digit HS code (TN VED in EAEU). The code defines the duty rate, certification requirements and applicable non-tariff measures. A wrong code is a real risk.
What a wrong code costs
- Duty and VAT reassessment for the entire understatement period.
- Fine of 50–200% of the underpayment (Russian Administrative Code, Article 16.2).
- Cargo delay until corrected paperwork is issued.
- In some cases — cargo seizure.
How we pick the code
- We study the technical specifications and composition.
- We apply the HS interpretation rules (GIR 1–6).
- We check FCS clarifications, EEC opinions and case law.
- For disputed cases — we request a Preliminary Classification Decision (PCD) in advance.
What to do if FCS disagrees
The inspector can issue a classification decision (KTT) with a different code. The procedure:
- We request the basis: which acts and expert opinions led to the decision.
- We prepare objections with an independent expert organisation.
- If still disputed — appeal to the higher customs authority or court.