For Those Who Ship Craft Materials Overseas

The HS Code I Looked Up Myself Was Wrong

This article is written for people who send craft materials or tools to customers abroad. It is not about weaving or making. It is about what happens when the things you make, or the things you stock, have to cross a border.

An order arrived from overseas. From France.

Up to the point of packing the box, nothing differs from a domestic shipment. What stopped me came afterward. On the screen where you prepare the EMS label, there are fields called "contents" and "HS code".

Let me give the conclusion first. The number I entered that day was wrong. I went on using it for a while without noticing.

I will go through it in order, including why I got it wrong. I suspect quite a few people stumble in the same place.

Handwriting Is No Longer an Option

There is something you should know before anything else. EMS labels and invoices cannot be filled in by hand.

Information about the contents now has to be transmitted electronically in advance. The days of writing out a form at the post office counter are over. If you walk in relying on old memories or an outdated guide, that is where you will get stuck.

What you use instead is Japan Post's International Mail My Page Service. It is free. You register the delivery address, fill in the required details, and it prints the waybill and the customs declaration as a set.

More trouble, it might seem, but not entirely bad news. You can prepare everything calmly at home, and both addresses and content records are saved, so next time you simply select them. It is far easier on the nerves than writing out a foreign address in a hurry at the counter.

And somewhere on that screen, you will stop. It is the contents declaration.

A Number Called the HS Code

The customs declaration asks for the name of the contents in English, along with a number called the HS code. This is an internationally shared classification number, and the customs authority on the receiving end uses it to decide duties.

The trouble is that "PP band" is not a phrase you will find in any dictionary of goods. Is it a packing band? A craft material? Plastic, or textile? You have to decide for yourself which shelf your product belongs on.

I opened the classification tables and worked it out as best I could.

The Number I Chose First

What I arrived at was 3923.29.

Looking back, the reason is obvious. PP band began life as a packing band. So I searched under "packing". Heading 3923 covers articles for the conveyance or packing of goods, and within it I picked the line for articles of plastics other than polyethylene.

As a chain of words, there is nothing strange about it. A band for packing, therefore the packing heading. If anything, it was a straightforward way to look.

But it was wrong.

Where I Went Wrong: Searching by Purpose Misses

Chapter 39, which covers plastics and articles of plastics, is divided not by purpose but by the physical form of the thing.

The same resin lands in different places depending on its shape. Left as pellets, it sits around heading 3901. Extruded into rods or profiles, 3916. Made into sheet or strip, 3920. Moulded into a bottle or a bag, 3923. Change the form and the number jumps.

So heading 3923 is the place for finished containers and packing articles. Bags, boxes, bottles, caps. Things that already have the shape of a container.

What my shop sells, on the other hand, is a coiled band. It is not wrapping anything. It has the form of a material waiting to become something. So not a bag or a box, but heading 3920, which covers plates, sheets, film, foil and strip. Being polypropylene, that makes it 3920.20.

The words "packing band" were attached to the product's name and had nothing to do with the form of the thing I was about to ship. Being pulled along by a word about purpose was my mistake.

The Other Fork in the Road Was Width

Incidentally, not every plastic band falls under Chapter 39. Strip with an apparent width of 5 mm or less is treated as belonging with textiles, in Chapter 54.

My PP band comes in 6 mm, 15 mm and 21 mm, all above 5 mm. On this point there was no problem: Chapter 39 was correct.

One millimetre and it moves to a different shelf. For a field where you write a single number, it took a remarkable amount of time to decide.

If You Process Before Selling, Where Is the Country of Origin

The contents declaration also has a country of origin field. Here too I stopped.

This field is not for the country you are shipping from. It is for the country where the goods were made. Sending from Japan does not make it Japanese.

So what about a shop like mine, which buys imported material and processes it to length and width before selling it? Since work has clearly been done, it feels as though it might qualify as made in Japan.

Looking into it, the origin only moves if the processing amounts to a substantial transformation of the goods. Simple cutting, sorting, repacking, relabelling and similar operations are not treated as meeting that bar. One common yardstick is the HS code itself: you compare the number before processing with the number after.

In my case, it was polypropylene band before and polypropylene band after, and the number stayed at 3920.20. If the number does not move, the origin does not move either. Cutting it and trimming it to width does not make it Japanese. That was the natural reading.

This may feel counterintuitive. The operations that feel most like real work are often exactly the ones customs classifies as minimal. Put the other way round: whether the origin becomes Japan depends not on how hard you worked, but on whether the nature of the goods themselves changed.

One more thing worth stating plainly. The HS code and the country of origin are two independent fields. A change of origin does not change the number. I confused these two myself at one point, so I mention it here.

When You Ship a Finished Piece, the Number Changes Again

There is one more important point.

PP band as a material and a finished piece woven from it do not share an HS code.

A finished basket or bag is no longer a strip of plastic. It is an article made by interlacing bands, so it leaves the plastics chapter altogether and moves toward Chapter 46, which covers basketwork and articles of plaiting materials.

What makes it more awkward is that among finished pieces, items shaped as bags can fall into a grey area with Chapter 42, which covers luggage and handbags. At that point we are well past what an amateur can settle by staring at classification tables.

A different number when you sell the material, another when you sell the finished piece. The same substance leaving the same workshop lands on a different shelf. You would never guess it without being told. If you are considering shipping finished work abroad, look into this before you need it.

If You Want Certainty, You Can Ask Customs

Having written all of the above, I should say plainly that I am not a customs specialist. What is recorded here is the conclusion I reached about my own products, and the fact that I got it wrong once along the way.

If you want certainty, Japan Customs offers an advance ruling system. You submit information about the goods and receive a written answer telling you which number applies. There is no charge.

I wish I had used it from the start. Researching it myself was not wasted effort. Because I researched it, I understand why I went wrong. But one confirmation at the end would have spared me from using an incorrect number at all.

Asking before you write is far quicker than writing a number you are unsure of.

Once You Decide, Save It

The My Page service has a contents master where you can register product names in English, unit prices, country of origin and HS codes in advance.

Register once and you simply select it next time. I registered mine by width. Overseas orders do not come often, and the version of me six months from now will certainly have forgotten. Leaving a record on the assumption that you will forget applies to almost everything done single handed, not only to customs.

Prices and Consumption Tax

For the value of the contents, write the price you actually sold at. Understating it reduces the duty at the other end, but that is a false declaration.

Note also that Japanese consumption tax does not apply to sales to overseas customers. In this case the goods came to 7,000 yen, and that became the price for export as it stood.

The Shipping Costs More Than the Goods

And here is the most honest part of shipping abroad.

France falls in EMS zone 3, and the postage on this shipment was 61.10 euros. The goods came to 43.20 euros. The shipping cost more than the contents. The total was 104.30 euros.

The customer ordered knowing this, for which I am grateful. Even so, when someone asks us about a bulk purchase, depending on the quantity we sometimes tell them honestly that importing directly themselves would work out cheaper. Because of how postage scales, that really is the case sometimes.

If the seller stays quiet about it, the first thing the customer feels on opening the box is not delight but arithmetic. I would rather avoid that.

In Closing

Publishing a mistake is not a comfortable thing, but in this case it seemed worth writing down.

"It is a packing band, so it goes in the packing heading" is not a thought unique to me. Someone will come in through the same door and arrive at the same shelf. If that person pauses somewhere in this article, writing it will have been worthwhile.

The first time, you never know where to begin. I hope this record can be that first handhold.