I went to the shops…. An International Trade Advisor's Festive Shopping Spree

BY:

Lucille Roche
12 December 2025

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As a Customs and International Trade advisor, I need to know a lot about the importation process and understand how goods make their way onto supermarket shelves. This includes all the regulatory requirements they must meet to achieve this. Importantly, I need to understand Tariff Classification, how to determine which certificates are required for importing goods, which legislation applies, and whether the product is a food product or a composite good. 

If all that wasn’t enough, I also need to understand the Rules of Origin and the distinction between where a product is made and where it meets the Origin rules in trade agreements.


While walking around the supermarket, I considered the above information regarding specific products. I first looked at a fresh pasta salad containing prawns, cooked pasta, and vegetables, dressed with a mayonnaise-style sauce. What Commodity Code did this come under? Would the prawns, the pasta, or the vegetables determine the code?


I wondered if this product would be imported from the EU and which risk category it would come under, as outlined in the Border Target Operating Model (BTOM). Would this pasta salad require a Health Certificate, and would it be classified as a composite product? If the prawns were wild caught, a ‘Catch Certificate’ would be necessary to import them. If the same type of product were imported, but instead of being chilled, it was shelf-stable and ambient, would different regulations apply? Would a shelf-stable pasta salad be exempt from the requirement for a health certificate, given its ingredients and processing, and would a Catch Certificate still be required?


I wandered into the clothing section, where a lovely Christmas outfit for a baby caught my eye. It consisted of a Babygro, a bib, mittens, a hat, and a little tutu. Would that be classified as a set, or would each garment have to be classified individually? I’d have to check the legislation, section, and chapter notes, and consult official guidance here to determine the correct code to proceed.


So, on to the bakery aisle. The meat and vegan sausage rolls and pasties caught my eye here... What did I need to think about to classify these? With meat products, is the meat the essential characteristic that determines the code? It would be vital to know the type of meat (e.g., a mix of different meats) and the percentage of meat in the product. In vegan products, will it be the pastry or the filling that determines their essential characteristics? What health certification will apply when importing these from a third country outside the EU? Is there a trade agreement between the UK and the supplying country, and could I claim a preferential duty rate?


I then reached the cleaning products aisle. This was interesting - how would I classify 3-in-1 dishwasher tablets that contain dishwasher salt, detergent, and a rinse aid? Does one element give an essential characteristic, or will each element be equally important? As I progressed, I wondered which General Rule of Interpretation (GRI) I would need to apply to classify the dishwasher tablets.


Finally, I arrived at the Christmas aisle, where an array of gift sets awaited me. In one gift set, there was a combination of a razor and shaving foam. I considered how best to classify two distinct products bundled together. Did one item possess the essential characteristics of the gift set, or would they be classified separately under different Tariff codes, even though they shared the same retail pack? Then I’d have to establish the Origin for the goods - again, one Origin, or two? That would depend on whether I could use one Commodity Code. Next, what about the Product Specific Rules (PSR) of any Trade Agreement that may be in place between the supply country and the UK?


A further look around brought a pretty gift set of mixed peppers in olive oil in a fancy bottle to my attention. Would the peppers meet the ‘wholly obtained’ Origin rule, or would there be an ingredient from another country, which might disqualify the product from meeting the Product Specific Rules of a Trade Agreement, that needs to be considered? The fruit in brandy brought the rules relating to Alcoholic Ingredients Relief to mind, and at that point, I decided to go home!


I was exhausted after my shopping trip, so I settled down in front of the 8525600000 for the evening, with a meal of a product classified under Commodity Code 1902201099, washed down with a glass of 2204218290. Cheers!


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