G/RO/W/146  
 
19 February 2014  
(14-1032)  Page: 1/12  
Committee on Rules of Origin  Original: English  
 
TRANSPOSITION OF DRAFT CONSOLIDATED TEXT ON NON-PREFERENTIAL RULES OF 
ORIGIN UNDER THE WTO AGREEMENT ON RULES OF ORIGIN 
(Item V (a) on the Agenda) 
The following submission, dated 11 February 2014, is being circulated at the request of the World 
Customs Organization. 
_______________ 
 
By letter dated 13 June 2012 the CRO has requested the advice of the WCO Technical 
Committee on Rules of Origin (TCRO) concerning the transposition of the draft text of non-preferential rules of origin, contained in document G/RO/W/111/Rev.6, to a newer version of 
the HS nomenclature, taking into account the technicality of the undertaking and the TCRO's high 
capability to assist such work. 
The WCO Secretariat and the TCRO have welc omed the opportunity for a review of the 
transposed text by the experts of the TCRO as th is technical review of the transposed rules will 
ensure that the final agreement is simplified and, hence, facilitate its implementation by Customs 
administrations and the business community. 
While a large portion of the HS amendments has little or no impact on the rules of origin, 
the transposed rules may become overly complex in certain cases if the transposition was only carried out mechanically without any logical simplification.  Therefore it is extremely important for Customs as well as the traders to ensure that th e transposed rules are simple and clear, so that 
the rules are fully effective and implementable. 
The WCO Secretariat had prepared a document  to be examined by the TCRO at its 31
st 
session in January 2013 focussing on the examination of those possible complex cases for the 
transpositions into HS versions 2002 and 2007.  The document has been forwarded to the CRO 
Chair as WCO Secretariat recommendations in March 2013. 
For the transposition into HS 2012, the WCO Secretariat had prepared a similar document 
for examination by the TCRO at its 32nd session in January 2014.  During the discussions Members 
made a couple of suggestions for further simplificati on of the rules of origin.  The TCRO then took 
note of the document and of various comment s made by delegations and agreed that the 
document be sent to the CRO as WCO Secretariat recommendations and technical advice. 
According to the TCRO decision I am pleased to enclose the document trusting that it 
provides reasonable options to the CRO for consideration. 
 
_______________ 
  G/RO/W/146 
 
- 2 - 
 
  1. Since the beginning of the negotiations of the Harmonization Work Programme (HWP) the 
WCO Council has adopted several recommendations to amend the Harmonized System (HS).  These HS amendments came into effect internationally on 1 January 2002, 2007 and 2012.  
2. The Technical Committee on Rules of Origin (TCRO) has agreed in the past that 
synchronized application of the Harmonized System and the Harmonized Rules of Origin is 
essential.  A technical rectification of the Agreement on Origin will therefore be needed. 
3. At its meeting on 27 October 2011, the Commi ttee on Rules of Origin (CRO) agreed to 
initiate the transposition of the draft consolidated text of Non-Preferential Rules of Origin into more 
recent versions of the HS nomenclature.  The WTO Secretariat has been mandated to conduct this work with a view to concluding it as soon as possible.  The transposition exercise would be conducted on a step-by-step basis as to gradually  conduct a technical rectification from HS 1996 
to HS 2012. 
4. At its meeting on 7 June 2012 the CRO agreed  to invite comments from the TCRO on 
documents prepared by the WTO Secretariat concerning the transposition exercise.  To that effect, 
the Chairperson of the CRO addressed a letter to the Chairperson of the TCRO on 13 June 2012. 
5. On 29 June the Chairperson of the TCRO welc omed this opportunity for a review of the 
transposed text by the experts of the TCRO adding  that a technical review of the transposed rules 
would ensure that the final agreement is simplified  and, hence, facilitates its implementation by 
Customs administrations and the business community.  The TCRO would provide the CRO with relevant advice to improve the quality of the transposition work. 
6. On 22 March 2013 the Director of Tariff and Trade Affairs addressed a letter to the 
Chairperson of the CRO stating that: 
"While a large portion of the HS amendments has little or no impact on the rules of origin, 
the transposed rules may become overly complex in certain cases if the transposition was 
only carried out mechanically without any logical simplification. Therefore it is extremely 
important for Customs as well as the traders to ensure that the transposed rules are simple and clear, so that the rules are fully effective and implementable. 
The WCO Secretariat had prepared a document to  be examined by the TCRO focusing on the 
examination of those possible complex cases.  The document has been examined by the TCRO at its 31
st session in January 2013. 
The TCRO expressed general appreciation for th e work carried out by both Secretariats and 
stressed the need for harmonized, simple and transparent rules.  The technical rectification 
should be merely at technical issue and should not lead to changes in the so far agreed rules. On the other hand, the transposition leads to complexity in some cases and these 
cases should be looked at." 
7. The WCO Secretariat has analysed the transposition documents received from the WTO.  
The WCO Secretariat revised the HS Transposition from 1996 to 2002 and from 2002 to 2007 in 
Document OC0168E1a.  As indicated above this was published for the 31
st Session of the TCRO.  
The present document addresses the HS Transposition from 2007 to 2012. 
8. The result of the TCRO’s discussions will be  forwarded to the CRO as WCO Secretariat 
recommendations to be duly utilized for the CRO’s consideration. 
CONCLUSION 
9. The Committee is invited to discuss the transposed  rules of origin compiled in the Annex to 
the present document in order to provide the CRO with relevant advice to improve the quality of 
the transposition work undertaken by the WTO Secretariat. 
_______________ 
 G/RO/W/146 
 
- 3 - 
 
  TRANSPOSITION EXERCISE 
HS 2007 TO HS 2012 
1. Heading 03.08. 
(a)  Recommendation by the Secretariat: 
HS2012 Description Rule 
03.08 Aquatic invertebrates other than crustaceans 
and molluscs, live, fresh, chilled, frozen, dried, 
salted or in brine; smoked aquatic invertebrates other than crustaceans and molluscs, whether or not cooked before or during the smoking process; flours, meals and pellets of aquatic 
invertebrates other than crustaceans and molluscs, fit for human consumption. As specified for split headings 
ex03.08(a) - Dried CTHS, except from split heading 
ex03.07(a) 
ex03.08(b) - Flours CTHS except from split heading ex03.07(c) 
and ex03.08(c) 
ex03.08(c) - Meals and pellets CTHS except from sp lit heading ex03.07(b) 
and ex03.08(b) 
ex03.08(d) - Smoked CTHS, except from heading 16.05 
ex03.08(e) - Other The origin shall be the country where the 
animals have been captured or gathered. 
  
Comment:  Heading 03.08 has been created to provide separately for aquatic invertebrates other 
than crustaceans and molluscs.  The Secretariat recommends to delete the exceptions from ex03.07(a), ex03.07(b) and ex03.07(c)  as the description of heading 03.08 
already clarifies that molluscs do not fall within the scope of heading 03.08. Deleting 
the exception from 16.05 is explained under heading 16.05.   
2. Heading 16.05. (a)  Recommendation by the Secretariat: 
HS2012 Description Rule 
16.05 Crustaceans, molluscs and other aquatic 
invertebrates, prepared or preserved. As specified for subheadings  
1605.10 - Crab [CTH, except from split heading 03.06(d)] 
 - Shrimps and prawns:  
1605.21 --  Not in airtight container [CTH, except from split heading 03.06(d)] 
1605.29 --  Other [CTH, except from split heading 03.06(d)]  
1605.30 - Lobster [CTH, except from split heading 03.06(d)] 
1605.40 - Other crustaceans [CTH, except from split heading 03.06(d)] 
 - Molluscs:  
1605.51 --  Oysters [CTH, except from split heading 03.07(d)] 
1605.52 --  Scallops, including queen scallops [CTH, except from split heading 03.07(d)] 
1605.53 --  Mussels [CTH, except from split heading 03.07(d)] 
1605.54 --  Cuttle fish and squid [CTH, except from split heading 03.07(d)] 
1605.55 --  Octopus [CTH, except from split heading 03.07(d)] 
1605.56 --  Clams, cockles and arkshells [CTH, except from split heading 03.07(d)] 
1605.57 --  Abalone [CTH, except from split heading 03.07(d)] 
1605.58 --  Snails, other than sea snails [CTH, except from split heading 03.07(d)] 
1605.59 --  Other [CTH, except from split heading 03.07(d)] 
 - Other aquatic invertebrates:  
1605.61 --  Sea cucumbers [CTH, except from split heading 03.08(d)] 
1605.62 --  Sea urchins [CTH, except from split heading 03.08(d)] 
1605.63 --  Jellyfish [CTH, except from split heading 03.08(d)] 
1605.64 --  Other [CTH, except from split heading 03.08(d)] 
 
Comment:  Smoked crustaceans, molluscs, and other aquatic invertebrates were classified in 
HS2007 heading 16.05. They have been transferred to HS2012 headings 03.06, 
03.07, and 03.08 respectively.  However, the Secretariat is of the view that the exceptions from Chapter 3 are not necessary under heading 16.05 as Harmonized 
System Note 1 to Chapter 16 specifies that Chapter 16 does not cover meat, meat G/RO/W/146 
 
- 4 - 
 
  offal, fish, crustaceans, molluscs or other aquatic invertebrates, prepared or preserved 
by the processes specified in Chapter 2 or 3 or heading 05.04.  
Therefore, also exceptions of heading 16.05 in headings 03.06, 03.07, and 03.08 can be deleted. 3. Chapters 28 and 29. 
In view of the Chapter Primary Rules for Chapters  28 and 29 which provide for a chemical reaction 
as well as mixing and blending as origin conferring processes, the WCO 
Secretariat recommends a simple CTSH rule for the following headings: 
- 28.30, 28.35, 28.42, 28.49, 29.03, 29.08, 29.12, 29.14, 29.16, 29.32, 29.33, 29.34, 29.37, 
29.39. 
For headings 28.48, 28.50 and 29.31 the WCO Secretariat recommends keeping the simple CTH 
rule. 
4. Heading 28.52. 
(a) Recommendation by the Secretariat: 
HS2012 Description Rule 
28.52 Compounds, inorganic or organic, of mercury, excluding 
amalgams. As specified for split 
headings 
ex28.52(a) - Of mercury oxides or hydroxide CTHS, except from 
subheading 2825.90. 
ex28.52(b) - Of mercury chlorides CTHS, except from split 
subheading ex2827.39(e) 
ex28.52(c) - Of mercury chloride oxides and chloride hydroxides CTHS, except from 
subheading 2827.49 
ex28.52(d) - Of mercury iodides and mercury iodides oxides  CTHS, except from 
subheading 2827.60 
ex28.52(e) - Of mercury sulphides; mercury polysulphides CTHS, except from split 
subheading ex2830.90(c) 
ex28.52(f) - Of mercury sulphates CTHS, except from split 
subheading ex2833.29(c) 
ex28.52(g) -Of mercury nitrates CTHS, except from split 
subheading ex2834.29(b). 
ex28.52(h) - Of mercury polyphosphates CTHS, except from 
subheading 2835.39  
ex28.52(i) - Of mercury cyanides and oxycyanide CTHS, except from 
subheading 2837.19 
ex28.52(j) - Of mercury complex cyanides CTHS, except from 
subheading 2837.20 
ex28.52(k) - Of mercury fulminates, cyanates and thyocyanates CTHS, except from split 
subheading ex2842.90(a) 
ex28.52(l) - Of mercury chromates, dichromates and peroxochromates CTHS, except from split 
subheading ex2841.50(c) 
ex28.52(m) - Of mercury double or complex silicates, including 
aluminosilicicates CTHS, except split  
subheadings ex2842.10(a) 
or ex2842.10(b) 
ex28.52(n) - Of other salts of inorganic acids or peroxoacids of mercury CTHS, except subheading 
2842.90 
ex28.52(o) - Of inorganic and organic compounds of precious metals with 
Mercury CTHS, except from 
subheading 2843.90. 
ex28.52(p) - Of mercury phosphides CTHS, except from heading 
28.48 
ex28.52(q) - Of carbides of mercury CTHS, except from 
subheading 2849.90 
ex28.52(r) - Of mercury hydrides, nitrides, azides, silicides and borides CTHS, except from heading 
28.50 
ex28.52(s) - Of other inorganic compounds of mercury CTHS, except from heading 
28.53 
ex28.52(t) - Of mercury lactic acid, its salts and esters CTHS, except from 
subheading 2918.11 G/RO/W/146 
 
- 5 - 
 
  HS2012 Description Rule 
ex28.52(u) - Of other mercury organo-inorganic compounds CTHS, except from heading 
29.31 
ex28.52(v) - Of mercury heterocyclic compounds with oxygen hetero-
atom(s) only. CTHS, except from 
subheading 2932.99 
ex28.52(w) Of other mercury Heterocyclic compounds with nitrogen hetero-
atom(s) only CTHS, except from 
subheading 2934.99 
ex28.52(x) - Of other Mercury tanning extracts of vegetable origin; tannins 
and their salts, ethers, aste rs and other derivatives.  CTHS, except from 
subheading 3201.90 
ex28.52(y) - Of inorganic Mercury products of a kind used as luminophores CTHS, except from 
subheading 3206.50 
ex28.52(z) Of mercury Albumins (inclu ding concentrates of two or more 
whey proteins, containing by weight more than 80% whey proteins, calculated on the dry matter), albuminates and other albumin derivatives. CTHS, except from 
subheading 3502.90 
ex28.52(zi) Of mercury Peptones and thei r derivatives; other protein 
substances and their derivatives, not elsewhere specified or 
included; hide powder, whether or not chromed. CTHS, except from 
subheading 3504.00 
ex28.52(zii) Of other Mercury Chemical preparations for photographic uses 
(other than varnishes, glues, adhesives and similar preparations); unmixed products for photographic uses, put up in measured portions or put up for retail sale in a form ready for use. CTHS, except from 
subheading 3707.90 
ex28.52(ziii) Of mercury Diagnostic or laboratory reagents on a backing, 
prepared diagnostic or laboratory reagents whether or not on a 
backing, other than those of heading 30.02 or 30.06; certified 
reference materials. CTHS, except from 
subheading 3822.00 
ex28.52(ziv) Of other casein glues CTHS, except from split 
subheading ex3501.90(b) 
ex28.52(zv) Of other Prepared culture media for the development or 
maintenance of micro-organisms (including viruses and the like) 
or of plant, human or animal cells CTHS, except from split 
subheading ex3824.90(b) 
 
Comment:  As indicated by the WTO Secretariat in HS2012, the amendment to the nomenclature 
occurs at subheading level and does not alter the scope of the rule as rectified in HS2007 version.  The 2007 rule can he transposed directly.  The WCO Secretariat 
recommends removing the exceptions and keeping a simple CTHS rule for split 
headings under 28.52 or just a simple CTSH rule for heading 28.52. 
5. Heading 30.02. 
(a) Recommendation by the Secretariat: 
HS2012 Description Rule 
30.02 Human blood; animal blood prepared for therapeutic, 
prophylactic or diagnostic us es; antisera and other blood 
fractions and modified immunological products, whether or not obtained by means of biotechnological processes; 
vaccines, toxins, cultures of micro-organisms (excluding 
yeasts) and similar products. As specified for subheading 
3002.10 - Antisera and other blood fractions and modified 
immunological products, whether or not obtained by means 
of biotechnological processes CTSH, except from subheadings 
2933.29, 2934.99, 3002.20, 
3002.90, 3907.20,3913.90, split 
subheadings ex2937.90(g) or 
ex3006.92(d) 
3002.20 - Vaccines for human medicine CTSH, except from split 
subheading ex3006.92(e) 
3002.30 - Vaccines for veterinary medicine CTSH, except from split 
subheading ex3006.80(f) 
3002.90 - Other CTSH, except from subheading 
2933.29, 3002.10 or from split subheading ex3006.92(g) 
 
Comment:  A technical rectification was necessary in the HS2012.  As part of the products 
classified in S2012 subheading 3002.10 and 3002.90 were previously classified in 
HS2007 subheadings 2933.29, 2934.99, 3002.10, 3002.20, 3002.90, 3907.20 and 
3913.90, the rule can be transposed by including an exception.  It should also be G/RO/W/146 
 
- 6 - 
 
  noted that split subheadings ex3006.80(a) onwards (in the exceptions) have been 
renumbered ex3006.92 from the HS2007.  The WCO Secretariat recommends as a simplification to keep CTSH as the origin criterion for the whole heading. 
6. Heading 38.24. 
(a) Recommendation by the Secretariat: 
HS 2012 Description Rule 
38.24 Prepared binders for foundry moulds or cores; 
chemical products and preparations of the chemical or allied industries (including those 
consisting of mixtures of  natural products), not 
elsewhere specified or included. As specified for subheading  
3824.10 - Prepared binders for foundry moulds or cores CTSH 
3824.30 - Non-agglomerated metal carbides mixed 
together or with metallic binders CTSH 
3824.40 - Prepared additives fo r cements, mortars or 
concretes CTSH 
3824.50 - Non-refractory mortars and concretes CTSH 
3824.60 - Sorbitol other than that of subheading 2905.44 CTSH 
 - Mixtures containing halogenated derivatives of 
methane, ethane or propane:  
3824.71 -- Containing chlorofluorocarbons (CFCs), whether 
or not containing hydrochlorofluorocarbons 
(HCFCs), perfluorocarbons (PFCs) or 
hydrofluorocarbons (HFCs) CTSH, except from split subheading 
3824.90(b) or ex3825.41(a) 
(perhalogenated waste organic 
solvents) 
3824.72 -- Containing bromochlorodifluoromethane, 
bromotrifluoromethane or dibromotetrafluoroethanes CTSH, except from subheading 
3824.71, 3824.73, 3824.74, 3824.75, 3824.76, 3824.77, 3824.78, 3824.79, 3824.81, 3824.82, 3824.83 or split subheading 3824.90(b) 
3824.73 -- Containing hydrobromofluorocarbons (HBFCs) CTSH, except from subheading 
3824.71, 3824.72, 3824.74, 3824.75, 
3824.76, 3824.77, 3824.78, 3824.79, 
3824.81, 3824.82, 3824.83  or split 
subheading 3824.90(b) 
3824.74 -- Containing hydrochlorofluorocarbons (HCFCs), 
whether or not containing perfluorocarbons (PFCs) or hydrofluorocarbons (HFCs), but not containing chlorofluorocarbons (CFCs) CTSH, except from subheading 
3824.71, 3824.72, 3824.73, 3824.75, 3824.76, 3824.77, 3824.78 3824.79, 3824.81, 3824.82, 3824.83  or split subheading 3824.90(b) 
3824.75 -- Containing carbon tetrachloride CTSH, except from subheading 
3824.71, 3824.72, 3824.73, 3824.74, 
3824.76, 3824.77, 3824.78 3824.79, 
3824.81, 3824.82, 3824.83  or split 
subheading 3824.90(b) 
3824.76 -- Containing 1,1,1-trichloroethane (methyl 
chloroform) CTSH, except from subheading 
3824.71, 3824.72, 3824.73, 3824.74, 3824.75, 3824.77, 3824.78 3824.79, 3824.81, 3824.82, 3824.83  or split subheading 3824.90(b) 
3824.77 -- Containing bromomethane (methyl bromide) or 
bromochloromethane CTSH, except from subheading 
3824.71, 3824.72, 3824.73, 3824.74, 
3824.75, 3824.76, 3824.78 3824.79, 
3824.81, 3824.82, 3824.83  or split 
subheading 3824.90(b) 
3824.78 -- Containing perfluorocarbons (PFCs) or 
hydrofluorocarbons (HFC s), but not containing 
chlorofluorocarbons (CFCs) or hydrochlorofluorocarbons (HCFCs) CTSH, except from subheading 
3824.71, 3824.72, 3824.73, 3824.74, 3824.75, 3824.76, 3824.77 3824.79, 3824.81, 3824.82, 3824.83  or split subheading 3824.90(b) 
3824.79 -- Other CTSH, except from  subheadings 
3824.71, 3824.72, 3824.73, 3824.74, 
3824.75, 3824.76, 3824.77 3824.78, 
3824.81, 3824.82, 3824.83 or split 
subheading 3824.90(b)or 
ex3825.41(a) (perhalogenated waste 
organic solvents) G/RO/W/146 
 
- 7 - 
 
  HS 2012 Description Rule 
 - Mixtures and preparat ions containing oxirane 
(ethylene oxide), polybrominated biphenyls (PBBs), polychlorinated biphenyls (PCBs), polychlorinated terphenyls (PCTs) or tris(2,3-dibromopropyl) phosphate:  
3824.81 -- Containing oxirane (ethylene oxide) CTSH, except from subheading 
3824.71, 3824.72, 3824.73, 3824.74, 
3824.75, 3824.76, 3824.77 3824.78, 
3824.79, 3824.82, 3824.83 or split 
subheading ex3824.90(b) 
3824.82 -- Containing polychlorinated biphenyls (PCBs), 
polychlorinated terphenyls (PCTs) or polybrominated biphenyls (PBBs) CTSH, except from subheading 
3824.71, 3824.72, 3824.73, 3824.74, 3824.75, 3824.76, 3824.77 3824.78, 3824.79, 3824.81, 3824.83 or split subheading ex3824.90(b) 
3824.83 -- Containing tris(2,3-dibromopropyl) phosphate CTSH, except from subheading 
3824.71, 3824.72, 3824.73, 3824.74, 
3824.75, 3824.76, 3824.77 3824.78, 
3824.79, 3824.81, 3824.82 or split 
subheading ex3824.90(b) 
3824.90 - Other As specified for split subheading 
ex3824.90(a) -- Naphthenic acids, their water-insoluble salts and 
their esters CTSHS 
ex3824.90(b) -- Other CTSHS, except from heading 38.26, 
subheading,  3006.70, 3824.71, 3824.72, 3824.73, 3824.74, 3824.75, 3824.76, 3824.77, 3824.78, 3824.79, 3824.81, 3824.82, 3824.83, 3825.10, 3825.20, 3825.49, 3825.50, 3825.61, 3825.69 or 3825.90 or split heading 28.52(zv), split subheading ex2842.10(a), ex3006.92(l), 3825.30(a) or ex3825.41(b) (other than perhalogenated waste organic solvents) 
 
Comment:  The HS 1996-2002 and HS 2002-2007 transposition Document OC0168E1a refers to 
heading 38.24.  If heading 38.24 is solved for the transposition exercise 1996-2002, 
this will in principle also solve the challenges for the 2002-2007 and 2007-2012 
transposition exercise, as the WTO Secretariat for the 2002-2007 and 2007-2012 rectification worked on a non-simplified version of the HS 2002 and HS 2007.  
The WCO Secretariat recommends as a simp lification to keep CTSH without the 
exceptions as the origin criterion. 
7. Heading 48.08. (a) Recommendation by the Secretariat: 
HS2012 Description Rule 
48.08 Paper and paperboard, corrugate d (with or without glued flat 
surface sheets), creped, crinkled , embossed or perforated, in 
rolls or sheets, othe r than paper of the kind described in 
heading No. 48.03. As specified for subheadings  
4808.10 -  Corrugated paper and paperboard, whether or not 
perforated CTH, except from split heading 
ex48.23(e) 
4808.40 -  Kraft paper, creped or crinkled, whether or not embossed 
or perforated CTH, except from split heading 
ex48.23(e) 
4808.90 -  Other CC, except from split heading 
ex48.23(e) 
 
Comment:  A simplification of heading 48.08 was al so recommended in the previous transposition 
Document OC0168E1a.  At HS 2012 level subheadings 4808.20 and 4808.30 have 
been merged into new subheading 4808.40 because of the low volume of trade.  The WCO Secretariat suggests deleting the remaining exceptions. G/RO/W/146 
 
- 8 - 
 
  8. Heading 74.18. 
(a)  Recommendation by the Secretariat: 
HS2012 Description Rule 
74.18 Table, kitchen or other household articl es and parts 
thereof, of copper; pot scour ers and scouring or polishing 
pads, gloves and the like, of copper; sanitary ware and parts thereof, of copper. As specified for split heading 
ex74.18(a) - Cooking or heating apparatus of a kind used for domestic 
purposes, non-electric, and parts thereof, of copper. CTHS, except from split 
subheading ex7419.99(c) 
ex74.18(b) - Other CTHS 
 
Comment:  In HS2012, the amendment to the nomenclature occurs at subheading level and does 
not alter the scope of the rule, which is set at split heading level.  Therefore, no modification is needed; the rule can be transposed directly.  However, as noted in JOB/RO/3/Rev.1, the Secretariat is of the view that the change from split heading 
ex74.18(a) to ex74.18(b) is unfeasible.  Th erefore, the rule for heading 74.18 could 
be "CTH". 
9. Heading 84.52. 
(a)  Recommendation by the Secretariat: 
HS2012 Description Rule 
84.52 Sewing machines, other than book-sewing machines of 
heading No. 84.40; furniture, bases and covers specially designed for sewing machines; sewing machine needles. As specified for 
subheadings  CTH; or 35% 
value-added rule 
8452.10 - Sewing machines of the household type CTSH  
 - Other sewing machines:   
8452.21 --   Automatic units CTSH  
8452.29 --   Other CTSH  
8452.30 - Sewing machine needles CTSH  
8452.90 - Furniture, bases and covers for sewing machines and 
parts thereof; other parts of sewing machines: As specified for 
split subheading   
ex.8452.90(a) -- Furniture, bases and covers for sewing machines 
and parts thereof CTSHS  
ex.8452.90(b) -- Other parts of sewing machines CTH  
  
Comment:  In HS2012, furniture, bases and covers for sewing machines and parts thereof 
(HS2007 subheading 8452.40) are now classified with subheading 8452.90, together with other parts of sewing machines.  Therefore, technically and to keep the same outcome of the matrix as in the Consolidated Text, a rule set  at split subheading level 
maybe needed.   However, on the one hand, it seems unfeasible a change to 
"furniture, bases and covers…and parts thereof"
1 from products classified in other 
subheadings of heading 84.52. The chan ge could be possible by means of 
disassembly, but primary chapter rules/notes for Chapters 84-90 specify that "the 
disassembly of goods shall not be considered  as the change required by the rule set 
forth in the matrix" .  On the other hand, change to other subheadings of heading 
84.52 from "furniture, bases…and parts thereo f" seem unlikely to happen.  Therefore 
the Secretariat is of the view that a "C TH" rule could be kept for the whole HS2012 
subheading 8452.90. 
The WCO supports the comment made by the WTO Secretariat in Document JOB/RO/4 underlining 
that this comment refers to the first column of the two origin rules for heading 84.52.  
The comment does not refer to eliminating the alternative in the second column of the rule.  
                                               
1 The HS2012 Explanatory Notes read as follows rega rding furniture, bases and covers for sewing 
machines: "B) Furniture, bases and covers specially desi gned for sewing machines.  For example, stands which 
can be used as tables or cabinets, and parts of such  furniture (drawers, extensio n boards, etc.), bases and 
covers are classified in this heading, even if presen ted separately. Separate case s mainly for protection or 
carrying purposes, if presented separately, are classified in their respective headings". G/RO/W/146 
 
- 9 - 
 
  10. Heading 84.56. 
(a) Recommendation by the Secretariat: 
HS2012 Description Rule 
84.56 Machine-tools for working any material 
by removal of material, by laser or 
other light or photon beam, ultrasonic, electro-discharge, electro-chemical, electron beam, ionic-beam or plasma arc processes; water-jet cutting machines. As specified for split headings CTH, except from 
heading 84.66; or 
35% value-added rule 
ex84.56(a) - Water-jet cutting machines CTSH, except from subheadings 
8479.89, 8479.71, 8479.79, 
split subheadings ex8486.10(h), 
ex8486.20(n), ex8486.30(k), 
ex8486.40(h),  or subheadings 
8508.19, 8508.60.  
ex84.56(b) - Other CTH, except from split 
subheadings ex8486.10(c), ex8486.10(d), ex8486.20(d), ex8486.20(e), ex8486.30(c), ex8486.30(d), ex8486.30(e),  ex8486.30(f) or ex8486.40(c).  
 
Comment:  Water-jet cutting machines, classified in HS2007 as part of subheading ex8479.89 
have been transferred to HS2012 heading ex 84.56.  The mechanical transposition of 
the rule requires that in HS2012, the rule be set at split heading level to provide for a 
different RoO for water-jet cutting machines, and for machine-tools of heading 84.56 (carrying over the exceptions which resulted from the HS2002-HS2007 transposition exercise).  The creation of exceptions to the rules may be necessary to prevent 
widening the scope of the RoO.  However, th e Secretariat is of the view that a "CTSH" 
for split heading ex84.56(a) and a "CTH" for split heading ex84.56(b) would be enough for heading 84.56 and would suggest deleting the newly created exceptions. 
The WCO Secretariat supports deleting the exceptions in the first column of the rule. 
This comment does not refer to eliminating the alternative in the second column of the rule. A simplification of heading 84.56 was also recomm ended in the previous transposition Document 
OC0168E1a. 
11. Heading 84.66. (a)  Recommendation by the Secretariat  
HS2012 Description Rule 
84.66 Parts and accessories suitable for use solely or 
principally with the mach ines of headings 84.56 
to 84.65, including work or tool holders, self-opening dieheads, dividing heads and other special attachments for machine-tools; tool holders for any type of tool for working in the hand. As specified for split headings CTH 
ex84.66(a) - Parts of water-jet cutting machines CTHS, except from heading 84.79, 
split subheading ex8486.90(m) or 
subheading 8508.70.  
ex84.66(b) - Other CTH, except from split subheadings 
ex8486.90 (e) to (k).  
  
Comment:  Parts of water-jet cutting machines, classified in HS2007 as part of subheading 
ex8479.90 have been transferred to HS2012 heading ex84.66.  The mechanical 
transposition of the rule requires that in HS2012, the rule be set at split heading level 
to provide for a RoO for water-jet cutting machines parts, and another for other parts G/RO/W/146 
 
- 10 - 
 
  of heading 84.66 (carrying over the exceptions which resulted from the HS2002-
HS2007 transposition exercise).2  
However, since "CTH "is the RoO used across chapter 84, for "parts and chapter primary rules 
stipulate that disassembly is not an origin conferri ng process, the Secretariat is of the view that a 
"CTH" would be enough for heading 84.66. 
A simplification of heading 84.66 was also recommended in the previous transposition 
Document OC0168E1a.  This comment does not refer to eliminating the alternative in the second 
column of the rule. 
12. Heading 84.79. (a) Recommendation by the Secretariat: 
HS2012 Description Rule 
84.79 Machines and mechanical appliances having 
individual functions, not specified or included elsewhere in this Chapter. As specified for 
subheadings CTH; or 35% 
value-added rule 
8479.10 - Machinery for public works, building or the like CTSH  
8479.20 - Machinery for the extraction or preparation of 
animal or fixed vegetable fats or oils CTSH  
8479.30 - Presses for the manufacture of particle board or 
fibre building board of wood or other ligneous 
materials and other machinery for treating wood 
or cork CTSH  
8479.40 - Rope or cable-making machines CTSH  
8479.50 - Industrial robots, not elsewhere specified or 
included CTSH, except from split 
subheading 
ex8486.30(j)  
8479.60 - Evaporative air coolers CTSH  
 - Passenger boarding bridges:   
8479.71 -- Of a kind used in airports CTSH, except from split 
heading ex84.56(a), subheadings 8479.79, 8479.89, split subheadings ex8486.10(h), ex8486.20(n), ex8486.30(k), ex8486.40(h), or subheadings 8508.19, 8508.60  
8479.79 -- Other CTSH, except from split 
heading ex84.56(a),   
subheadings 8479.71 or 
8479.89, or split 
subheadings 
ex8486.10(h), 
ex8486.20(n), 
ex8486.30(k), 
ex8486.40(h), or 
subheadings 8508.19, 
8508.60  
 - Other machines and mechanical appliances:   
8479.81 -- For treating metal, including electric wire coil-
winders CTSH  
8479.82 -- Mixing, kneading, crushing, grinding, 
screening, sifting, homogenising, emulsifying or stirring machines CTSH  
                                               
2 Note that in JOB/RO/3/Rev.1 the Secretariat stated that, in its view, "CTH" was enough for the 
HS2007 transposed rules for heading 84.66 and subheading 8479.90. G/RO/W/146 
 
- 11 - 
 
  HS2012 Description Rule 
8479.89 -- Other CTSH, split heading 
ex84.56(a), subheadings 
8479.71, 8479.79,split 
subheadings 
ex8486.10(h), 
ex8486.20(n), 
ex8486.30(k), 
ex8486.40(h), or 
subheadings 8508.19, 
8508.60  
8479.90 - Parts CTH, except from split 
headings ex84.66(a), split subheading ex8486.90(m), or subheading 8508.70.  
 
Comment:  Water-jet cutting machines (ex8479.89) and parts thereof (ex8479.90) were 
transferred to HS2012 headings ex84.56 and ex84.66, respectively. Therefore, new 
exceptions were created in the mechanically rectified rule for subheadings 8479.89 
and 8479.90.  In addition, "CTSH" rule, with some exceptions was set for the newly created subheadings 8479.71 and 8479.79 for passenger boarding bridges (previously 
classified in subheading ex8479.89). 
The WCO Secretariat recommends deleting the exceptions in heading 84.79.  A simplification of 
heading 84.79 was also recommended in the previous transposition Document OC0168E1a.  
This comment does not refer to eliminating the alternative in the second column of the rule. 
13. Heading 85.07. (a) Recommendation by the Secretariat: 
HS2012 Description Rule 
85.07 Electric accumulators, including separators 
therefor, whether or  not rectangular 
(including square). As specified for subheadings CTH; or 35% 
value added rule 
8507.10 - Lead-acid, of a kind used for starting piston 
engines CTSH  
8507.20 - Other lead-acid accumulators CTSH  
8507.30 - Nickel-cadmium CTSH  
8507.40 - Nickel-iron CTSH  
8507.50 - Nickel-metal hydride CTSH, except from 
subheadings 8507.60 or 
8507.80.  
8507.60 - Lithium-ion CTSH, except from 
subheadings 8507.50 or 8507.80.  
8507.80 - Other accumulators CTSH, except from 
subheadings 8507.50 or 
8507.60.  
8507.90 - Parts CTH  
 
Comment:  Electric accumulators for nickel-metal hydride and lithium-ion were classified in 
HS2007 together with other accumulators (ex.8507.80).  In HS2012, new subheadings have been created for these two products (8507.50 and 8507.60).  The CTSH rule was kept in the new subheadings and some exceptions were created to prevent widening the scope of the RoO.  The WCO Secretariat is of the view that these 
exceptions are not necessary as in practice the change between these three headings 
is not likely to occur and a simple CTSH rule could be kept for 8507.50; 8507.60 and 8507.80.  This comment does not refer to eliminating the alternative in the second 
column of the rule. G/RO/W/146 
 
- 12 - 
 
  14. Heading 96.19. 
(a) Recommendation by the Secretariat: 
HS2012 Description Rule 
96.19 Sanitary towels (pads) and tampons, 
napkins and napkin liners for babies and 
similar articles, of any material. As specified for split headings 
 - Of plastic and other materials of 
headings Nos. 39.01 to 39.14:   
ex96.19(a) -- Napkins and napkin liners for babies 
and similar articles [CTHS, except from heading 39.26, provided that 
the goods are assembled in a single country in accordance with the Note of Chapters 61 or 62.] 
ex96.19(b) -- Other [CTHS, except from heading 39.26, subheading  
3006.91 or subheading 8536.70] 
ex96.19(c) - Of paper pulp, paper, cellulose wadding 
or webs of cellulose fibres. CTHS, except from heading 48.18. 
ex96.19(d) - Of wadding of textile materials CTSH  
 -  Knitted or crocheted:  
ex96.19(e)  -- Knitted or crocheted to shape The origin shall be the country where the goods 
of this split heading have been knitted or 
crocheted to shape.  
ex96.19(f) -- Assembled from parts knitted or 
crocheted to shape [The origin shall be the country where the parts 
of the goods of this split heading have been knitted or crocheted to shape.]  
ex96.19(g) -- Assembled from parts cut to shape [Change to goods of this split heading provided that 
the goods are assembled in a single country.] 
 -Not knitted or crocheted:  
ex96.19(h) -- Assembled from parts, other than 
diapers of heading 62.09 [Change to goods of this split heading provided 
that the goods are assembled in a single country 
in accordance with note of Chapter 62.] 
ex96.19(i) -- Diapers CTHS except from Chapter 62, or except by 
cutting and/or hemming only.  
ex96.19(j) - Other [CTHS except from heading 63.07, provided the 
starting material is pre-bleached or unbleached 
fabric.]  
 
Comment:  In HS2012, new heading 96.19 was created to group sanitary towels (pads) and 
tampons, napkins and napkin liners for ba bies and similar articles classified in 
different chapters of the HS nomenclature  (ex39, ex61, ex62, and ex63).  For the 
mechanical transposition of the rule, split headings were created in order to respect the outcome of the original rule of each category of goods.  
The CRO could consider one rule for the whole heading. 
 
__________