Key Classifications Explained for exporting CBD oils and other CBD related products

Trading CBD products across EU borders? You’ll need to wrap your head around customs classification. Which HS Codes Apply to CBD Products in the EU? Most CBD products in the EU use HS code 1302.19.70.00 for natural CBD extracts (as plant extracts) and 3307.9000 for cosmetic CBD products. Let’s be honest, the EU’s customs rules can feel like a maze—especially if you’re new to the CBD market. The EU’s Combined Nomenclature system asks for specific codes for different hemp and CBD products. Each code means different tariffs, rules, and headaches (or not, if you get it right). This guide tries to break down the main headaches businesses face when importing or exporting CBD. We’ll look at how your product’s type, intended use, and formulation all affect which code you actually need.

CBD Product Type	HS/Commodity Code
CBD Isolate oils	13021970
CBD Broad spectrum oils	13021970
CBD Full spectrum oils	13021970
CBD containing balms	330499
CBD Lip balm	330410
CBD Cream, Gel, Lotions	330499
CBD soft gels/capsules to UK	2106909869
CBD soft gels/capsules to CH	2106 90 98
Gummies UK	2106909869
Gummies CH	21.069.098

Key Takeaways

• Specific CBD product types need specific HS codes. Extracts? Usually 1302.19.70.00. Cosmetics? 3307.9000.
• Classification depends on your product’s use, ingredients, and formulation.
• Getting the code right keeps you compliant and helps you dodge costly delays or penalties.

Understanding HS Codes and Commodity Codes for CBD Products

The Harmonised System gives us a global, standardised way to classify traded products. The commodity code system just adds a few more digits for extra detail, especially in the EU. These codes help customs folks everywhere identify CBD products and process them properly.

The Purpose of HS Codes in International Trade

HS codes are basically the backbone of international trade classification. The World Customs Organisation came up with this system so we all speak the same language when goods cross borders. Customs authorities use these codes to figure out duties and taxes. Governments also rely on them to track trade stats and enforce rules. For CBD, the HS code you use decides what import requirements you’ll face. Different codes can trigger different permits, checks, or even bans. What do these codes actually do?

• Calculate duty and tax
• Compile trade stats
• Verify regulatory compliance
• Identify products across countries

With these codes, a CBD oil shipment gets the same label whether it’s headed for Germany, France, or Italy. That kind of consistency cuts down on confusion and holds up at customs.

Commodity Codes Versus HS Codes: Key Distinctions

HS codes are six digits and work worldwide. The EU tacks on two more digits to make an eight-digit commodity code for stuff exported out of the EU. The six-digit HS code is the global baseline. The extra digits just get more specific for EU trade. Quick breakdown:

• HS Code: 123456 (universal)
• EU Commodity Code: 12345678 (EU-specific)

Commodity codes let you get more granular when classifying CBD products. They can even separate different CBD strengths or forms that share the same base HS code. If you’re exporting CBD out of the EU, you need the full eight-digit code. Imports into the EU usually start with the six-digit one.

Structure and Composition of the HS Code System

The HS system sorts goods to a standard six-digit level using a kind of step-by-step hierarchy. Each pair of digits narrows things down a bit more, which is honestly pretty logical. The first two digits? That’s the chapter—broad stuff. Chapters 1-24 are for agricultural products, which is where most CBD stuff lands. Digits three and four? They’re the heading, so they narrow down the category a lot. HS code breakdown:

• Digits 1-2: Chapter (big category)
• Digits 3-4: Heading (product group)
• Digits 5-6: Subheading (specific product)

The last two digits make up the subheading, which sorts out similar products with small differences. For CBD, codes vary depending on whether it’s raw hemp, CBD oil, or edibles. You’ve got to look at the main features and intended use of your product to get it right.

Primary HS Codes for CBD Products in the European Union

The EU customs tariff system (TARIC) uses specific codes for CBD products based on their form, strength, and use. These codes decide your duties, VAT, and what hoops you’ll jump through at the border.

CBD Oil and Preparations: Main HS Classifications

Most CBD oils use HS code 1302.19.70.00. That covers vegetable saps and extracts not listed elsewhere. CBD oil importers usually pick 1302.19.70.00. It comes with a 20% import VAT and, good news, no extra duties. This code works for:

• CBD tinctures and drops
• Oil-based CBD blends
• Liquid CBD extracts
• Hemp oil concentrates

Pharma-grade CBD might need a different code, depending on the formulation. Pure CBD isolate powder? That’s a whole other story with its own code. Things like CBD strength and what other cannabinoids are in there can change which code you use. It’s smart to check with customs if your product is a bit unusual.

Industrial Hemp and Raw Materials: Relevant Codes

Raw hemp and industrial hemp stuff have their own HS codes, not the same as processed CBD. These are for the unprocessed, agricultural side of things. Hemp fibres? Usually under the 5302 series. Hemp seeds and hemp seed oil? You’re looking at 1207 and 1515 series, respectively. The EU’s Common Agricultural Policy keeps tabs on hemp imports and exports. Industrial hemp has to stay below 0.3% THC on dry weight, or you’re out of luck. Raw hemp biomass for CBD extraction might use 1211 series codes for medicinal plants. The exact code depends on whether it’s fresh, dried, or otherwise processed—so, yeah, details matter.

Cosmetics Containing CBD

CBD cosmetics and topicals have their own set of codes, different from stuff you eat or drink. These fall under cosmetic-specific codes. Skincare with CBD? That’s usually the 3304 series, covering:

• CBD face creams and lotions
• CBD serums and treatments
• Anti-ageing CBD products
• Moisturisers with CBD

Hair care with CBD fits the 3305 series. Body care lines up with 3307 for personal care products. The percentage of CBD in your product can change what’s required. If you’re marketing it for how it looks or feels (not as medicine), you’ll probably stick with the standard cosmetic HS codes. Don’t forget: your CBD cosmetics need to pass EU cosmetic rules, not just customs. Some new CBD blends might need extra approval, too.

Finished Goods and Edibles Containing CBD

CBD edibles and food products? That’s a tricky area, mostly because EU countries can’t agree on CBD as a novel food ingredient. CBD candy often uses the 1704 series for sugar confectionery. CBD drinks? Depends on the base—so you’ll have to dig into beverage codes. CBD product codes will change depending on whether it’s raw hemp, oil, or something edible. Each type needs its own code. Supplements with CBD usually fall under 2106 for food preps not elsewhere specified. But honestly, the rules for CBD as a food ingredient are still up in the air in a lot of EU countries. Check the latest on novel food rules before you bring in CBD edibles. Some countries are way stricter than others, and you don’t want your shipment stuck at the border.

Classification Challenges and Interpretation Issues

Classifying CBD products isn’t straightforward. You’ve got unclear lines between hemp and cannabis, shifting THC limits, and customs authorities who don’t always agree from one EU country to the next.

Ambiguities Between Hemp and Marijuana Derivatives

The big headache? Hemp and marijuana both come from Cannabis sativa. You can’t tell them apart by looking—lab tests are the only way. Customs usually want to see:

• Proof of plant origin
• How it was extracted
• What’s actually in the final product
• What you say the product is for

We’ve seen customs officers ask for detailed lab reports to prove the source. Hemp-based CBD usually gets a different code than marijuana-based stuff. The baffeling naming conventions don’t help. Two products can look the same but end up with different codes just because of plant origin. And honestly, documentation requests change from port to port. Some customs want a simple supplier note, but others insist on third-party lab proof. Expect surprises.

CBD Product Type	HS Code
CBD Isolate oils	13021970
CBD Broad spectrum oils	13021970
CBD Full spectrum oils	13021970
CBD containing balms	330499
CBD Lip balm	330410
CBD Cream, Gel, Lotions	330499
CBD soft gels/capsules to UK	2106909869
CBD soft gels/capsules to CH	2106 90 98
Gummies UK	2106909869
Gummies CH	21.069.098

THC Content Impact on Code Assignment

THC concentration shapes which HS code you’ll need and what kind of duty rates you’re looking at. If a product has more than 0.2% THC, you’re in for tougher classification rules and, honestly, higher tariffs. THC threshold impacts:

• Below 0.2%: Usually gets industrial hemp classification
• 0.2-1.0%: Falls into a tricky, restricted middle ground
• Above 1.0%: You’re dealing with controlled substance rules

We’ve noticed that classification differences mostly come from how each country interprets THC limits. Some go for zero tolerance, while others allow tiny traces. Testing methods add to the confusion. Depending on the lab or the method, the same sample might show different THC levels. That’s frustrating, right? And here’s the kicker: Customs can retest your shipment after it arrives. If they find more THC than you declared, they’ll reclassify it, hit you with back duties, and maybe even penalties.

EU Member State Variations in Interpretation

Even though HS codes are supposed to be harmonized, EU member states still interpret CBD product codes differently. Each national customs office basically gets the final say. Some common differences:

• Germany: Really strict about THC testing
• Netherlands: Focuses on the product’s intended use
• France: Wants detailed extraction method documents

We’ve seen the same product get different HS codes at different EU ports. That’s a headache for distributors trying to cover the whole EU. HS codes update every five years, but in between, each country can issue its own guidance. Some jump ahead with clarifications, others just wait for international updates. Shipping across EU borders sometimes sparks reclassification disputes, especially if your goods enter through different countries.

Regulatory and Customs Considerations for CBD Import and Export

If you want your CBD products to clear customs without drama, you need proper documentation and labels that actually comply. Recent rule changes mean more paperwork and new hoops to jump through at EU borders.

Documentation and Labelling Requirements

When importing or exporting CBD, you’ve got to gather all the right documents to meet customs standards. That includes a certificate of analysis proving your cannabinoid profile and that THC is under the legal limit. Here’s what you’ll need for imports:

• Certificate of Analysis (COA) from a third-party lab
• Product safety data sheets
• Import declarations filed with customs
• Proof that your hemp strain is approved

For exports, you’ll need invoices that show exactly how much CBD is in your products. Export declarations have to spell out cannabinoid profiles or you risk delays or even seizures. Labels must list cannabinoid content, THC levels, and batch numbers. And you’d better make sure they fit both where you’re shipping from and where you’re shipping to. Certificates of origin help prove your product’s compliance with trade agreements. It’s your proof that the hemp source checks out with the rules.

Recent Changes in EU CBD Product Regulations

Now, most CBD products for people to consume fall under Novel Food regulations. So, you’ve got to check if your product already has authorization or at least started the process before importing. Brexit really made UK-EU CBD trade more complicated. There are new customs steps and tariffs, and you’ll need extra paperwork for shipments that used to be a breeze. Each member state interprets CBD rules a bit differently. Some are super strict on THC, others care more about which product category you’re in. What’s changed lately?

• Novel Food rules now enforced more strictly
• Customs classification codes updated
• Lab testing requirements got tougher
• New product registration steps

It’s honestly hard to keep up, but you have to. International CBD trade rules keep shifting, and enforcement is only getting tighter.

Compliance Strategies and Practical Tips for Businesses

Getting CBD classification right isn’t just paperwork—it can save you time, money, and a lot of stress. Having customs pros on your side is a game-changer for meeting EU requirements and keeping things moving.

Ensuring Accurate Product Classification

Start with detailed documentation. You’ll want full ingredient lists, up-to-date THC certificates, and clear manufacturing process descriptions for every product. Don’t skip these docs:

• Lab test results with exact THC numbers
• Breakdown of what’s in the product (by percent)
• How it’s made, step by step
• Statement of what the product is for

CBD oils, cosmetics, and supplements often fall under different codes. Double-check if your products count as pharmaceuticals, cosmetics, or something else based on what’s in them and how they’re used. Getting the code right keeps you compliant. It’s smart to review your specs against the latest HS code definitions regularly—misclassification can sneak up on you. Keep records that tie each product version to its HS code, and track any formula tweaks that might change the code you need.

Collaborating with Customs and Trade Advisors

Honestly, working with experienced customs brokers and trade specialists makes a huge difference. They know the finer points of CBD classification in EU law and can help you avoid mistakes. Why bring in the pros?

• They’re on top of regulatory changes
• They interpret the tricky stuff
• You’ll have fewer customs hold-ups
• They help with duty and VAT calculations

Trade compliance experts guide you through the maze of international rules. They can even request binding tariff info so you know your classification is correct before shipping. It’s worth building relationships with advisors who know pharmaceutical or cosmetic codes inside out. Their input can be a lifesaver, especially with new or borderline products. Set up regular check-ins with your advisors to stay on top of new CBD rules in different EU countries.

Frequently Asked Questions

Coding CBD products under the Harmonised System isn’t always straightforward. The codes change depending on what’s in the product and how you use it. Regulatory updates can throw curveballs too.

How can one classify cannabidiol-based products under the Harmonised System in the European Union?

We start by looking at the main ingredients and the product’s form. CBD oils usually go under HS code 1302.19.70.00 as plant extracts. Pure CBD distillate is a different story. Bulk CBD powder uses 2907.29.9000 for phenolic compounds. Whether there are other active ingredients matters. If it’s a mix, you might need a different code based on what the product’s mainly for.

What steps are required to determine the appropriate HS code for a CBD product intended for import into the EU?

First, check the product’s main makeup and how concentrated it is. The physical form points you to the starting category. Think about how it’s marketed—is it a cosmetic, supplement, or medicine? Each one follows a different coding path. Go through the full ingredient list. Sometimes, even a tiny addition can push the product into a more specific code. Document the manufacturing process. The HS code you pick affects your duties, so you really want to get it right.

Are there different HS codes for CBD products depending on their use or composition in the EU?

Definitely. Codes change with both what’s in the product and how you use it. Pure CBD and blends get separate codes. Cosmetics with CBD land in Chapter 33. Food supplements go to Chapter 21. Medicines? They’re in Chapter 30. The THC level can also send hemp-based products into a different code than synthetic CBD. You might end up with higher VAT or duties if your product’s code changes based on its specific makeup.

What are the common challenges when coding CBD products for customs purposes in the EU market?

It’s easy to get stuck between categories. For example, is a topical CBD cream a cosmetic or a medicine? Sometimes it’s not obvious. New product types make things messy. If you’ve got a unique delivery method or formula, there might not be a perfect code yet. Paperwork requirements can shift from country to country. Even with harmonized codes, local customs might see your product differently. Small changes in CBD content can mean a totally different code—and different duty rates. That’s a real challenge for manufacturers.

How do changes to EU regulations affect the classification of CBD products under the HS coding system?

We keep an eye on rule changes because they can flip your classification overnight. Novel Food rules, for instance, have changed how we treat CBD edibles and supplements. When THC limits shift, hemp products might need new codes. What was once industrial hemp could suddenly be a pharmaceutical if the rules change. New safety or testing requirements sometimes move products to more specific or stricter codes. What used to be a plant extract might now count as a medicine. The EU uses 8-digit codes on top of the usual 6-digit HS codes, so as rules evolve, the codes get even more specific.

Product Type	HS Code
CBD Isolate oils	13021970
CBD Broad spectrum oils	13021970
CBD Full spectrum oils	13021970
CBD containing balms	330499
CBD Lip balm	330410
CBD Cream, Gel, Lotions	330499
CBD soft gels/capsules to UK	2106909869
CBD soft gels/capsules to CH	2106 90 98
Gummies UK	2106909869
Gummies CH	21.069.098

Can you provide guidance on differentiating HS codes for pure CBD and CBD-containing products in the European Union?

When it comes to pure CBD, we usually look at its chemical form and just how pure it is. If you’re dealing with cannabidiol distillate products, those are concentrated and come with their own quirks for classification. It’s not always straightforward, honestly. For products that contain CBD, you really need to take a close look at all the active ingredients. The main component tends to call the shots for classification, but sometimes those secondary ingredients throw a curveball and need extra attention. Concentration matters—a lot. If the CBD content is high, you’re probably looking at pharmaceutical or chemical codes. But if it’s on the lower side, it might just slip into a plant extract category instead. It’s not always black and white. And then there’s the carrier. If you’ve got a mix—say, oil-based, water-based, or maybe something solid—each one wants its own approach under the harmonised system. It’s a bit of a puzzle, and honestly, there’s no one-size-fits-all answer. Disclaimer: The information provided in this article is for general informational purposes only and does not constitute legal, tax, or customs advice. While we strive to ensure the accuracy and timeliness of the content, regulations and tariff classifications (including HS codes) for CBD products may change and can vary between countries and jurisdictions. Readers are strongly advised to consult with a qualified customs broker, legal advisor, or relevant authorities for specific guidance regarding the classification, import, or export of CBD products in their country. Candropharm and the authors of this article accept no liability for any actions taken or not taken based on the information provided herein.