Imported snacks are direct-to-consumer products that are closely related to the daily life of the general public. In order to meet the upgrading of domestic consumption demand, in recent years, China has frequently introduced tax reduction and consumption promotion policies such as the adjustment of comprehensive cross-border e-commerce tax and tentative tax rates. In view of the above background, the common error-prone problems of snack classification in the actual import business are analyzed to reduce enterprises' unnecessary customs clearance costs caused by classification errors.

Coffee and Tea Concentrated Extract Products

The concentrated extract (taking coffee as an example) is in powder or liquid using roasted and ground coffee as raw material, and the active ingredients of coffee are extracted into water under a certain temperature and pressure. The aqueous solution is concentrated in low temperature vacuum, and finally the finished product is obtained by spray drying or vacuum freeze-drying. The added substances such as white granulated sugar and glucose syrup, which are mostly used to improve the taste, are all carbohydrates.

In the actual classification work, the improper understanding of the two factors—processing degree and raw material component ratio will lead to classification errors. On one hand, granulated or powdered products using roasted coffee and fermented roasted tea as raw materials, which are only mashed or ground, shall be classified to item 09.01, 09.02 or 09.03; on the other hand, for the "products of basic ingredients" in the Notes on Import and Export Tariff Commodities and Items (hereinafter referred to as the Tariff Notes), they cannot be understood as products of main ingredients. The concentrated extract is the key ingredient that determines the basic characteristics of the product, while starch or other carbohydrate only plays the role of filling or improving the taste, so as long as the basic raw material is the concentrated extract, even if it contains a large amount of white granulated sugar, glucose syrup, starch and other added substances, it shall be classified to item 21.01.

Example: 3-in-1 Instant Coffee

Basic description of the product: retail package, 18g/pack, brown powder, mainly used for brewing in cafe or at home; ingredients: white granulated sugar 41.3%, glucose syrup 30.7%, vegetable oil 19.2%, instant coffee 7%, stable agent 0.2%, emulsifier 0.4%, anti-caking agent 0.1% and pigment 0.3%.

Classification opinion: the product is mainly used for brewing in cafe or at home, which is a product based on coffee concentrate, and the added white sugar, glucose syrup and vegetable oil are mainly used to adjust the taste. According to the general classification rules 1, it should be classified to the tariff line 2101.1200.

Tips：Item 21.01 Tariff Notes (excerpt)

The item includes: "... 3. Products based on the coffee, tea or Mate Tea extracts or concentrates mentioned in above 1 and 2. They are products based on the extracts or concentrates of coffee, tea and Mate Tea (rather than coffee, tea and Mate Tea themselves), including extracts with starch or other carbohydrates added.

Source: China Customs Magazine

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