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Sets and kits: how to classify a mixed delivery

Gift sets, tool kits and “all-in-one” boxes are a frequent headache in declaration. They are classified not by the number of items, but by their purpose.

The classification of sets is governed by rule 3 of the General Rules of Interpretation. In practice it all comes down to one question: what is the main item in the set.

Three conditions for a set

If at least one condition is not met, it is not a set: the components are declared on their own.

How the main character is determined

Criteria in descending order of importance
Role in use
main
Cost of the component
significant
Weight and volume
auxiliary
Number of units
weak
Example: a shaving set made of a razor, foam and a brush is classified by the razor — it defines the purpose of the set.
Be careful with documents Even if a set is classified under one code, the requirements of technical regulations apply to each component separately. Cosmetics inside a set remain cosmetics, an electrical appliance remains an electrical appliance.

When a set is not considered a set

The basic classification rules are explained in the article on the HS code (TN VED). How to check which regulations apply to the parts of a set — in the analysis of product lists.

Documents for a set: one or several

This is the main practical question. The answer depends on what you assembled and in what form it is sold.

SituationHow the documents work
A set of items, each with its own document, in its own packagingThe documents for each item apply; nothing additional is needed for the set
The whole set falls under one regulationOne document is issued for the set as for a product
The items of the set fall under different regulationsEach is covered by its own document, the set — by the combination
The product is repacked or poured into other containersThis is different packaging: confirmation is required for it
An item without documents is added to the setThe whole set cannot be put into circulation

The last row is the most frequent mistake of gift sets: an accessory with no documents is added as a “bonus” to cosmetics that are properly documented, and the problem becomes common to all.

Classification and conformity confirmation are different questions The rule that a set is classified by the good that gives it the main character works for the HS code (TN VED). It does not mean that a document is needed only for the “main” good: the requirements of technical regulations apply to each component that falls under them.

Labelling of a set

The consumer packaging of a set carries its own labelling, and it does not replace the labelling of the products inside.

The shelf life deserves a separate mention: a set lives by its shortest item. Putting a cream with a 36-month shelf life and a sample with a 6-month shelf life into a gift kit means a set with a 6-month shelf life, not 36.

Who becomes the manufacturer

The one who assembles the set takes on the duties of the manufacturer for the set: he is responsible for the labelling, the completeness and the conformity, not the manufacturers of the separate items.

Seasonal sets: how not to miss the deadline

Gift kits are a story with a hard deadline: in time for December or not. An order of work that saves you from a rush.

  1. Define the composition of the set before buying the packaging — both the labelling and the documents depend on it.
  2. Check whether all items have valid documents and whether they expire during the sales season.
  3. Check whether you repack anything: if so, it is separate work with separate terms.
  4. Calculate the shelf life of the set by the shortest item and make sure that it covers the sales period.
  5. Agree the layout of the set's labelling before printing the run.
  6. Allow time for replacing an item: if the documents for one of them are not ready in time, the set is reassembled.

How the HS code (TN VED) and the composition of a set are connected at import — in the article on classification.

Check your product Describe your product in plain words — the system will show the expected HS code (TN VED), the applicable regulations and the set of documents. Start the check.
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