GRI 3(a), 3(b), and 3(c): How to Classify Composite Goods and Mixed Materials Without Guesswork
November 24, 2025

GRI 3(a), 3(b), and 3(c): How to Classify Composite Goods and Mixed Materials Without Guesswork

Composite goods, mixed materials, and multipurpose kits often create some of the most difficult HTS decisions. These products do not fit neatly into a single heading based on their description alone. They may combine materials with different tariff treatments, include multiple functions, or arrive as sets packaged together for a specific activity. General Rules of Interpretation 3(a), 3(b), and 3(c) provide the legal framework that resolves these situations. When applied correctly and in order, these rules eliminate guesswork and lead to clear, defensible outcomes.

GRI 3 applies only when GRI 1 and GRI 2 do not fully determine the classification. Once the relevant headings and notes have been reviewed and more than one heading still appears to apply, GRI 3 establishes the sequence for choosing the correct one.

When GRI 3 Becomes Necessary

Not every product requires GRI 3. It applies only when:

  • Two or more headings appear to cover the merchandise
  • The headings refer to different components or different aspects of the product
  • Essential character is unclear under earlier rules
  • The goods form a composite product, a mixed material item, or a set

When these conditions are met, GRI 3(a), 3(b), and 3(c) must be applied in strict sequence. Only when one rule fails should the classifier move to the next.

GRI 3(a): The Most Specific Heading Prevails

GRI 3(a) directs the classifier to choose the heading that provides the most specific description. A heading is considered more specific when it clearly describes the product’s core nature or primary component instead of providing a broad or general coverage.

Examples:

  • A heading describing “electronic calculators” is more specific than one describing “electrical machines”.
  • A heading naming “plastic tableware” is more specific than a heading covering “plastic articles”.

GRI 3(a) does not allow subjective reasoning. The determination must be based strictly on the legal text. If none of the competing headings can be considered more specific than the others, the classifier moves to GRI 3(b).

GRI 3(b): Essential Character for Composite Goods and Sets

GRI 3(b) is the rule most often used for:

  • Composite goods made of different materials
  • Composite goods composed of different components
  • Sets packaged together for retail sale

Under this rule, goods are classified according to the component or material that gives the product its essential character. Essential character reflects the part that defines the product’s identity, function, or role within the set.

Examples:

  • A kitchen tool made of plastic with a stainless steel cutting edge obtains its essential character from the steel component.
  • A tool kit packaged as a single retail unit is classified according to the tool that defines the purpose of the kit.
  • A composite good combining electronic and mechanical elements is classified based on the component that drives its principal function.

Essential character must be determined using objective analysis. If no component clearly defines the identity of the good, or if the components contribute equally, GRI 3(b) cannot resolve the classification. In that case, the classifier must use GRI 3(c).

GRI 3(c): The Heading That Appears Last in Numerical Order

GRI 3(c) is the final fallback rule. It applies only when:

  • The competing headings are equally specific under GRI 3(a)
  • No essential character can be identified under GRI 3(b)

When both earlier rules fail, the good is classified under the heading that appears last in numerical order among the headings that equally merit consideration.

This rule does not rely on function or material. It is a purely procedural mechanism that ensures classification can always be completed even when essential character cannot be determined.

Why Sequence Matters

GRI 3 must always be applied in strict order:

  1. Try to determine the most specific heading under GRI 3(a).
  2. If that fails, determine essential character under GRI 3(b).
  3. If that also fails, classify under the heading that appears last numerically under GRI 3(c).

Skipping steps introduces legal risk and can lead to inconsistent outcomes across products or audit findings.

Documentation Requirements for GRI 3 Decisions

Accurate and complete product information is essential to apply GRI 3 correctly. Teams must understand:

  • All materials used
  • All functional components
  • How the components contribute to the identity of the good
  • Whether the product is marketed or sold as a set
  • Whether the components serve a unified purpose

The classifier must have enough detail to evaluate essential character objectively.

Building a Consistent Logic for Composite Goods

Products that trigger GRI 3 often appear throughout large catalogs. Without a structured approach, teams may classify similar items differently. A deterministic process that evaluates specificity, essential character, and fallback logic ensures that these decisions remain consistent even when multiple analysts are involved.

A legal rules engine that applies GRI 3 uniformly can manage the complexity of composite goods at scale, eliminating subjective interpretation and supporting audit ready classification.

GRI 3 resolves classification when products combine materials, functions, or components that could fall under different headings. By applying GRI 3(a), 3(b), and 3(c) in the correct order, organizations can classify composite goods and mixed materials without relying on guesswork or subjective reasoning.

See how composite goods and multipurpose kits are classified using structured legal logic. Run a live classification workflow in Trade Insight AI to evaluate GRI 3 scenarios with full determinism.

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