Despite common perceptions that the Harmonized System is all about numbers, it is all about words and phrases.  But these usually need punctuation when put together to ensure that they are unambiguous, especially in legal texts like the HS.  “Let’s eat Dad” instead of “Let’s eat, Dad” may be funny in English class, but not as a legal direction!

The big four for the HS are commas, semi-colons, colons and periods. As we don’t normally get to use colours in writing the HS, we will use them to accentuate this article.

Commas are used to separate items within a list or series: “07.03 - Onions, shallots, garlic, leeks …”.  They also group conditions to avoid ambiguity.  For example, in Chapter 75 Note 1(c), wire is “Rolled, extruded or drawn product, in coils, which have …”: so wire is always presented as a coiled product.  Without the ‘in coils’ commas, “Rolled, extruded or drawn product in coils which have …”, it could be argued that only drawn wire must be presented in coils.  Commas construct clarity.

Semi-colons separate independent clauses.  What does this mean?  Take “84.21 ‑ Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus for liquids or gases” as an example.  The heading covers two different groups: centrifuges and filtering/purifying devices.  These are read independently, which means that the centrifuges and centrifugal driers do not have to be for liquids or gases; you can have centrifuges for solids.  Which is just as well given that this heading covers “8421.12 ‑ ‑ Clothes‑dryers” and not everyone would want gaseous clothes.

Unlike the independent semi-colons, colons say related information follows: in the HS subheadings, further subdivisions. So, if you have already worked out that your fabric is woven, containing less than 85 % by weight of cotton, mixed mainly or solely with man-made fibres, weighing not more than 200 g/m2 (so heading 52.10) and is unbleached, you get to subheading 5210.1 which reads “‑ Unbleached :”. The colon says that you haven’t finished answering questions – there are following subheadings which, in this case, are going to ask about the type of weave.

Periods “.”, or ‘full stops’ occur at the very end of heading texts.  As sub-headings are not relevant when classifying to the heading level, anything below the heading shouldn’t be considered until the heading is found.  The HS’s colons tell us to keep going, but periods, or ‘full stops’, are simply saying ‘The End’.