Classifying herbal medicines, supplements and tonics for import and export
- HM Revenue & Customs
- Part of:
- Classification of goods and International freight industry and businesses making customs declarations
- First published:
- 3 August 2012
- Last updated:
- 27 October 2015, see all updates
Tariff classification of measured dose herbal medicines, vitamins, food and dietary supplements and tonics.
This guidance covers a range of products that may be referred to as:
- herbal medicines or medicaments
- homoeopathic and herbal remedies
- supplements (food and dietary)
These products are classified according to:
- their purpose - whether they’re medicinal or for general health and well-being
- their contents and additives
- the way in which they’re made up, eg for retail sale or in measured doses for a specific use
Generally these products are covered in one of the following chapters of the Tariff:
- chapter 21 - for food preparations like herbal teas or dietary supplements
- chapter 22 - for drinks with added ingredients like vitamins, eg fortified tonic wines
- chapter 29 - for vitamins and similar organic compounds that are separately defined - see the guide on classifying organic chemicals
- chapter 30 - for herbal medicinal preparations for both humans and animals - read the guide on classifying pharmaceutical products
- chapter 23 - for animal feed supplements
This guide can be used in conjunction with the online Trade Tariff tool, where you will find the full commodity codes for these goods.
Quick reference table of heading codes
The following list isn’t exhaustive, but it will help you to check quickly where a particular item is likely to be classified.
|Body building preparations based on milk powders and whey||1901|
|Dietary supplements 2106|
|Dietetic, diabetic and fortified foods||2106|
|Fodder supplements for animals (containing vitamins and other ingredients)||2309|
|Ginseng ‘tea’ or drink||2106|
|Herbal ‘tea’ or infusion||2106|
|Herbal medicinal preparations||3003|
|Herbal medicinal preparations (in measured doses or packaged for retail sale)||3004|
|Liquid herbal remedies with a basis of distilled alcohol||2208|
|Provitamins (general rather than specific use)||2936|
|Tonic drinks (non alcoholic)||2202|
|Tonic wines fortified with herbal extracts and/or vitamins||2208|
|Vitamins (general rather than specific use)||2936|
Find the full commodity codes and other measures applying to imports and exports by accessing the online UK Trade Tariff tool.
Defining herbal medicines, supplements and tonics
When you’re classifying medicinal preparations for the purposes of the Tariff, in particular chapter 30, you may come across certain terms and abbreviations. Some examples are listed below.
Terms used when referring to medicaments
- active substance - a chemically defined substance, a chemically defined group of substances, such as alkaloids, polyphenols or anthocyanins, or a plant extract - active substances must have medicinal properties to prevent or treat specific diseases and ailments, or their symptoms
- excipient - a non-nutritional substance (like magnesium stearate) added during the production of tablets
- herbal medicinal preparations - these are preparations based on one or more active substances (see above), these are obtained from a plant, or parts of a plant, by a process such as drying, crushing, extraction or purification
- homeopathic medicinal preparations - these are prepared from products, substances or compositions called ‘homeopathic stocks’ or ‘mother tinctures’, these mother tinctures are diluted - for example in alcohol or water. The degree of dilution must be shown (for example D6)
- Provitamin - a vitamin precursor that’s converted by the body into active form as a vitamin
- Recommended Daily Allowance (RDA) - the recommended daily allowance of a vitamin or mineral
- vitamins or mineral preparations - these are preparations based on vitamins that are covered under heading code 2936, or based on minerals, including trace elements, and mixtures of minerals, they’re used to treat or prevent specific diseases or ailments, or their symptoms - this type of preparation contains a much higher amount of vitamins or minerals, generally at least 3 times higher than the RDA
Classifying miscellaneous food preparations
Products that don’t treat, cure or prevent diseases or ailments are generally classified under heading code 2106 as food preparations not elsewhere specified or included.
Many items are classified under this heading code, including:
- mixtures of plants, or parts of plants, with other ingredients, like plant extracts; these mixtures are not consumed in this form, but are used to make herbal teas and infusions; they may have a particular purpose, for example to be used as a laxative, purgative or diuretic, or to relieve flatulence; others claim to provide relief from ailments or to promote general health or well-being
- mixtures of ginseng extract with other ingredients to make ginseng tea or drink
- food or dietary supplements that are based on substances like plant extracts, fruit concentrates, honey or fructose and that contain added vitamins; the packaging of these preparations often indicates that they’re beneficial in maintaining general health or well-being
Although many products like vitamins are usually classified under this heading, it’s important to take into account:
- the actual contents of the product
- how the product is made up, presented or labelled
These may mean that a product is classified under a different heading. For example, vitamins that are mixed with water and other ingredients and are ready for immediate consumption as drinks or tonics are not covered under heading code 2106. Instead they’re covered in chapter 22.
Classifying tonics and liquid food supplements
Chapter 22 covers tonics and liquid food supplements that are meant for immediate consumption. These preparations contain added vitamins or iron compounds and are designed to maintain general health or well-being. This type of product is generally covered under one of the following heading codes:
- heading code 2202 - non-alcoholic beverages
- heading code 2205 - aromatised wines
- heading code 2206 - mixtures of fermented beverages, mixtures of fermented beverages with non-alcoholic beverages and other fermented beverages
- heading code 2208 - spirituous beverages; this includes products like tonic wine fortified with herbal extracts and/or vitamins, and liquid herbal remedies with a basis of distilled alcohol - these are included under this heading even if they’re meant to be taken in very small quantities
Classifying provitamins and vitamins (chapter 29)
Separately defined organic compounds, like vitamins, are covered in chapter 29. But to be covered in this chapter they must comply with strict conditions that specify the additives that are allowed. These compounds can be dissolved in water or in some other solvent, but the solution must be used only because it’s required for safety reasons or for transport purposes. Stabilisers, such as anti-caking agents, can also be added, but only to preserve the compound or for transport purposes.
So if, for example, an essential trace element like chromium picolinate is prepared as a dietary supplement in the form of tablets or capsules, it would not be covered in this chapter. This is because the added ingredients, like binder, the capsule shell and excipients, haven’t been added just for the purposes of preservation or transport. This type of product is covered in chapter 21 under heading 2106.
Heading 2936 specifically covers:
- derivatives used mainly as vitamins
- mixtures of provitamins, vitamins and vitamin derivatives
Certain specified additives, such as antioxidants, are allowed provided that the amount added is just enough for the vitamins to be preserved or transported.
For classification purposes it’s very important that anything added to a compound doesn’t make the resulting product particularly suitable for a specific use rather than for general use. For example if vitamins are prepared as food supplements in the form of tablets, capsules or caplets then they’re not classified under heading code 2936. Because of the way they’re presented, with an intended daily dosage, they’re considered to be suitable for a specific use. They’re also excluded from this heading code because the purpose of the additives is for more than just preserving or transporting the vitamins. The additives are there to give the product a convenient and easy to use form.
Classifying herbal medicinal preparations
Herbal medicinal preparations, or medicaments, are covered in chapter 30 under heading codes 3003 and 3004. These include preparations used (either internally or externally) to treat or prevent human or animal diseases or ailments. Products that maintain general health and well-being are specifically excluded from this chapter.
If a medicinal preparation is made up into measured doses, like ampoules, syringes or capsules, then these must be classified under heading code 3004.
This heading code also specifically covers the retail sale of:
- herbal and homoeopathic medicinal preparations
- certain preparations containing vitamins, minerals, essential amino acids or fatty acids
These products must include certain information for consumers on their labels or packaging, or on the accompanying user directions. This information must show:
- the specific diseases, ailments or deficiencies (or their symptoms) for which the product is to be used
- the concentration of the active substances that the product is based on
- the dosage
- mode of application
The level of vitamins and minerals in these products must be much higher than the RDA of these substances for just maintaining general health or well-being.
Specific exclusions from chapter 29
Heading code 2936 covers provitamins and vitamins, to which certain permitted substances can be added, for example stabilisers. The following products are specifically excluded from this heading code:
Products that are particularly suitable for specific use, for example vitamins that are made up as food supplements in the form of capsules, tablets, caplets and so on which have a recommended daily dosage. These are considered to be suitable for specific use and so are covered elsewhere.
Products that contain more ingredients than just the additives that are permitted for preserving or transporting the compound, for example, vitamins that have been mixed with other organic chemicals, minerals, herbs, other parts of plants, food ingredients and similar substances.
Animal feed supplements
Feed supplements for animals that contain vitamins and other ingredients, such as cereals and proteins are covered in chapter 23 under heading code 2309. But this heading code specifically excludes vitamins that just have permitted substances such as stabilisers added to them and which are meant for general rather than specific use. These are covered in chapter 29 under heading code 2936.
An RDA is set for certain vitamins and minerals. The RDA is the minimum amount needed by the body to remain healthy. The following table from the Annex to Council Directive 90/496/EEC (amended by Directive 2008/100/EC), on nutrition labelling of foodstuffs sets out the RDA for a range of vitamins and minerals. However a transition period will apply for the new RDAs until 31 October 2012.
RDA for vitamins
|Vitamin A||800 micrograms|
|Vitamin D||5 micrograms|
|Vitamin E||12 milligrams|
|Vitamin K||75 micrograms|
|Vitamin C||80 milligrams|
|Vitamin B6||1.4 milligrams|
|Folic Acid||200 micrograms|
|Vitamin B12||2.5 micrograms|
|Pantothenic Acid||6 milligrams|
RDA for minerals
The free on-line UK Trade Tariff on the GOV.UK website is available for your use to look up classification codes. This offers easy access to tariff information by providing commodity code and duty rate listings together with a search engine to facilitate enquiries and allow self-service to commodity code information.
However if after visiting this site you are unable to self-assess your products, you can request additional support by sending a request by email to firstname.lastname@example.org.
Please ensure that one item only is detailed per email and that the request includes the following type of information, so that we can deal with your enquiry efficiently:
- what the product is
- what it is made of, if made or more than one material please explain the breakdown of the materials
- what it is used for
- how the product works/functions
- how it is presented/packaged
Additionally detailed below is some additional information that is required on certain products:
- footwear: please include the type (shoe, boot, slipper etc.), upper material details, outer sole material details, the heel height and the purpose for men or woman
- food: please include precise composition details by percentage weight of all the ingredients to 100% and the method of manufacture or process undergone eg fresh, frozen, dried, further prepared / preserved etc
- chemicals: please include the Chemical Abstracts Service Registry Number, whether the product is a liquid / powder / solid and include the % ingredients
- textiles: please include the material composition, how it is constructed (knitted / woven) and the name of fabric
- vehicles: please include the age, the engine type (petrol or diesel), the engine size, whether the vehicle is new or used, whether the vehicle is over 30 years old and whether it is in its original condition, is the vehicle going to be for everyday use
A classification officer will then email a response back to you providing you with non-legally binding classification advice based on the information you have supplied.
Harmonised System Explanatory Notes (HSENs)
HSENs give useful guidance on the scope of Tariff chapters, headings and sub-headings. When you’re classifying herbal medicines and similar products the following are particularly helpful:
HSENs to heading code 2309 HSENs to heading code 2936 HSENs to heading code 3003 HSENs to heading code 3004
Published: 3 August 2012
Updated: 27 October 2015
- Change of service contact details, as of the 1 September 2015 the tariff classification helpline is changing from telephone contact to email.
- First published.
From: HM Revenue & Customs