Which HS code applies to retail-ready private label goods?
Confidence 4/5 Established practice
HS classification for retail-ready private label goods:
Follows the product, not the brand. A private-label item is classified exactly as the unbranded equivalent.
Sources
- Private label and OEM practice — Industry practice; consistent with supplier-quoted minimums
- Country of origin marking requirements — US Customs and Border Protection
- EU product labelling and responsible person requirements — European Commission
What goes wrong with retail-ready private label goods
- Printing the packaging before confirming the destination labelling requirement, then paying for a reprint.
- Assuming the factory will generate the barcode. GS1 registration is the brand owner's job.
- Buying a "custom" product that is actually a stock item with a sticker on it — sometimes fine, but you should know which you bought.
- Forgetting the responsible-person address required for EU sales.
- Not checking that the factory will not also supply your design to someone else; exclusivity has to be negotiated and paid for.
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