Classification starts with GRI 1, and GRI 1 is short: classify by the terms of the headings and any relative section or chapter notes. Only when GRI 1 cannot settle it do the later rules get a say. Most classification disputes are not fights about the later rules. They are fights about someone skipping the first one.
The terms of the headings come first
The headings are the legal text of the tariff schedule, and GRI 1 says they decide first. Read the heading language, not the section title, not the chapter title, and not the name your supplier put on the commercial invoice. Subheadings wait their turn: a product must fit the heading before anyone argues about which subheading inside it applies.
This is where most errors begin. An importer classifies by what the product looks like, or by the heading a competitor uses, and never reads the heading text itself. CBP reads it at liquidation, and the two readings often disagree.
The notes are law, not footnotes
Section and chapter notes carry the same legal force as the heading text. A note can define a term, set a threshold, or exclude a product from a heading outright. Chapter 85 notes, for example, decide what counts as a machine part and what does not, and that single note moves products between headings with very different rates.
Read the notes for the section and the chapter before you read anything else about the product. A classification that fits the heading text but violates a chapter note is wrong, and no later rule rescues it.
The mistake that costs real money
The expensive version of this error is trusting a supplier's HTS code. Suppliers classify for their own export, under their own incentives, and CBP is not bound by their choice. When CBP reclassifies at liquidation, the importer owes the difference plus interest, and the entry has already been sitting for months.
Entries liquidate on a 314-day clock, and a wrong classification discovered late is a bill, not a debate. The fix is a classification file: heading text, notes read, subheading chosen, and the reasoning written down while the shipment is still on the water.
A working order for your next classification
Start with the heading text and the section and chapter notes. Then check the subheadings inside the heading that fits. Then search the CROSS database for a ruling on a product like yours, because rulings back to 1989 cover most common goods. If the heading and notes settle it, stop there and document the call. If they do not, only then move to GRI 2 and GRI 3, in order, and write down why each step was needed.
Keep reading
Related guides on this site: the Section 232 full-value rule how related-party pricing changes the duty base recovering duty on reexported goods More from LandedWatch.
Frequently asked questions
What is GRI 1 in plain terms?
Classify by the terms of the headings and any relative section or chapter notes. It is the first rule of classification, and the later rules only apply when GRI 1 cannot settle the answer.
Do section and chapter notes really override the heading text?
They do not override it, they complete it. The notes have the same legal force as the headings, and a note can exclude a product from a heading that otherwise looks right. A classification that ignores the notes is incomplete.
When do I move past GRI 1 to the other rules?
Only when the terms of the headings and the notes do not settle the classification. GRI 2 covers incomplete and unassembled articles, GRI 3 covers mixtures and sets, and each applies in order, not by preference.
Can a supplier's HTS code be wrong?
Yes. Suppliers classify for their own export, and CBP is not bound by their choice. The importer of record owns the classification, so the code on the commercial invoice is a suggestion, not a defense.