
The Full GRI Decision Tree: How Professionals Navigate Step by Step
Accurate HTS classification is not a guess. It follows a fixed legal sequence defined by the General Rules of Interpretation. When professionals treat GRI as a decision tree, classification becomes structured, repeatable, and defensible. When they do not, similar products can end up with different codes, creating audit risk and inconsistent duty treatment.
The full GRI decision tree provides a roadmap from the first reading of the legal text to the final subheading. Each step has a clear purpose and must be applied in order before moving to the next.
Step 1: Start With GRI 1 and the Legal Text
The decision tree always begins with GRI 1. The question is simple:
Can this product be classified based solely on the terms of the headings and the relevant Section and Chapter Notes?
If the answer is yes, the classifier does not need to move further down the tree. GRI 1 and the Notes are sufficient to reach the correct heading. Many products are resolved at this step when legal text and notes are read carefully.
If the answer is no because the goods are incomplete, unassembled, or do not fit clearly into a single heading, the tree continues to GRI 2.
Step 2: Apply GRI 2 for Incomplete or Unassembled Goods
At this branch, the classifier asks:
Is the product incomplete, unfinished, or unassembled, and does it have the essential character of the finished good?
If the product is incomplete or unassembled but clearly recognizable as the finished article, GRI 2(a) directs that it be classified as the complete good. If it is presented as unassembled or disassembled components that form a full product when put together, it is also classified as the complete article.
If GRI 2 does not resolve the classification and more than one heading still appears to apply, the decision tree moves to GRI 3.
Step 3: Use GRI 3 for Composite Goods, Mixed Materials, and Sets
GRI 3 is used when several headings seem to cover the product. The decision tree here has three internal branches that must be followed in order.
Step 3.1: GRI 3(a) Most Specific Heading
Question:
Is one heading more specific than the others based on the legal text?
If one heading provides a more precise description of the goods, it prevails. If not, the tree passes to GRI 3(b).
Step 3.2: GRI 3(b) Essential Character
Question:
Does one component or material give the product its essential character?
For composite goods, sets, or mixed materials, the classifier evaluates which component defines the identity and main function of the product. If essential character can be identified, the good is classified by that component.
If essential character cannot be determined or several components contribute equally, the decision tree proceeds to GRI 3(c).
Step 3.3: GRI 3(c) Last Heading in Numerical Order
Question:
If the headings are equally specific and no essential character can be identified, which heading appears last in numerical order?
GRI 3(c) provides a procedural fallback. The product is classified under the heading that appears last numerically among those that equally merit consideration.
If GRI 3 still does not resolve the issue because no heading is truly applicable, the tree moves to GRI 4.
Step 4: GRI 4 Most Similar Goods as a Last Resort
At this point the classifier asks:
If no heading directly covers the goods, which existing goods are most similar in terms of material, function, and use?
GRI 4 is used only when earlier rules cannot classify the product. The decision is based on similarity to other goods already covered by the tariff. This is a last resort branch in the decision tree and must be well documented.
Once the product is assigned to a heading, either under GRI 1 through 3 or through GRI 4, the tree continues to packaging questions under GRI 5.
Step 5: GRI 5 Packaging, Cases, and Containers
Here the classifier evaluates:
Is the packaging a specialized case or an ordinary container?
Under GRI 5(a), specially shaped or fitted cases designed for long term use and imported with the product are classified with the goods they hold. Under GRI 5(b), ordinary packing materials and containers normally follow the classification of the goods and are not classified separately, unless they are clearly reusable or have independent commercial value.
This step ensures that packaging is treated consistently and only separated from the product when legally required.
Step 6: GRI 6 Subheading Logic and Final Code Selection
Once the correct heading is determined and packaging issues are resolved, the decision tree reaches the final stage:
Within this heading, which subheading applies based on the legal text, notes, and structure?
GRI 6 requires that the same logic used to choose the heading be applied at the subheading level. The classifier:
- Reviews the one dash subheadings
- Moves down the hierarchy to more detailed two dash and further subheadings
- Applies any relevant Subheading Notes
- Compares only subheadings at the same level within the same branch
This final step produces the complete HTS code that will be used for duty calculation and any Rules of Origin analysis.
Why a Decision Tree Approach Reduces Risk
Treating GRI as a decision tree prevents shortcuts such as:
- Jumping directly to composite rules without fully applying GRI 1
- Using similarity analysis before exhausting heading possibilities
- Skipping essential character analysis
- Choosing subheadings based on commercial descriptions instead of legal text
A structured decision tree offers:
- Consistent outcomes across different teams
- Clear documentation for each branch of the analysis
- Better training for new classification staff
- Stronger support for internal controls and audits
The Bottom Line
The full GRI decision tree is a practical way to visualize and enforce the legal sequence that underpins HTS classification. By moving step by step from GRI 1 through GRI 6, professionals ensure that every code is based on legal text, notes, and structured logic rather than intuition or habit. This approach builds a stable, scalable foundation for compliance across entire product catalogs.
Explore how a rules based engine applies this GRI decision tree across thousands of SKUs in Trade Insight AI.
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