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Sets, kits and bundles: how to classify and declare them

When a gift box or kit can share one HS code under Rule 3(b), when each item needs its own, and how that changes the declaration and the EU's €3 duty.

Updated · 6 official sources

A box of different products gets one HS code only when it's a retail set under Rule 3(b), when a heading names it, or when it's a kit of parts for one article; anything else in the box is classified item by item. A retail set has at least two different articles from different headings, put together for one need or activity and packed for sale to the end user without repacking.

Rules as of 30 October 2026.

What counts as a set for retail sale?#

A set for retail sale, as the WCO's Explanatory Notes to Rule 3(b) define it, meets three conditions together. It holds at least two different articles that would fall under different headings. They're put up together to meet a particular need or carry out a specific activity. And they're packed for sale to users without repacking.

Each condition rules things out. Six identical forks aren't a set, because they're one article in one heading. Unrelated products packed together aren't a set either: the Explanatory Notes classify a bottle of spirits packed with a bottle of wine item by item, and the same goes for instant coffee sold with a cup and saucer. Goods packed for someone else to repack aren't retail sets.

Box Retail set? Why
Cheese board, two cheese knives and a stoneware dip bowl in a gift box Yes Different headings, one activity (serving cheese), ready for sale
Scented candle and ceramic mug in a gift box No No shared need; each item stands alone
Six identical steak knives in a box No One article, one heading
Hair clipper, comb, scissors and brush in a case Yes Different headings, one activity (cutting hair)

How is a retail set classified?#

A retail set is classified as if it consisted only of the item that gives it its essential character, and that one code covers the whole set. Customs weighs the nature of each item, its bulk, quantity, weight or value, and its role in how the set is used. No single factor always wins; it's decided case by case.

In the cheese board set, the wooden board is the bulk of the set and most of its value, so the set would usually take the board's heading, 44.19, wooden tableware and kitchenware. If no item could be said to give the set its essential character, Rule 3(c) would put the set in whichever candidate heading comes last in numerical order: here 82.11 for the knives, which comes after 69.12 for a stoneware bowl and 44.19 for the board. The full order of the rules is in the General Rules of Interpretation.

Which headings already name sets?#

Some headings name sets in their own wording, and then Rule 1 decides the code without any essential character test. The HS has headings or subheadings for first-aid kits, needlework sets, tool sets, manicure sets, cutlery sets and travel sets for personal toilet or sewing, and the apparel chapters define suits and ensembles in their notes.

Heading or subheading What it covers
3006.50 First-aid boxes and kits
63.08 Sets of woven fabric and yarn for making rugs, tapestries, embroidered table cloths or similar articles, put up for retail sale
82.06 Tools of two or more of headings 82.02 to 82.05, put up in sets for retail sale
82.14 Includes manicure and pedicure sets
8215.10 and 8215.20 Sets of assorted spoons, forks and similar tableware
96.05 Travel sets for personal toilet, sewing or shoe or clothes cleaning
61.03, 61.04, 62.03, 62.04 Suits and ensembles, as defined in the chapter notes

Toys have a rule of their own. Note 4 to Chapter 95 lets heading 95.03 cover toys combined with other items that wouldn't count as a set under Rule 3(b), as long as they're put up together for retail sale and the combination has the essential character of a toy. A doll sold with a hairbrush and clips stays a toy.

What about kits of parts?#

A kit that contains the parts of one article isn't a set at all: Rule 2(a) classifies it as the finished article. A flat-pack bookcase, a bicycle shipped in pieces or a model aircraft kit takes the code of the assembled product, because a heading for an article also covers it unassembled or incomplete, with its essential character.

That makes a kit simple to declare: one line, the finished product's code, and the kit's price as its value. Extras that aren't part of the finished article are looked at on their own.

What about bundles of unrelated items?#

A bundle of items that don't serve one need is classified item by item, even when it's sold as one product at one price. Declare each item on its own line with its own HS code, quantity, origin and value, with line values that add up to the price paid. Customs, not the listing, decides what's a set.

Keep a note of how you split the price, because the value per line drives the duty per line. The commercial invoice generator lists each item with its own code, and the product descriptions guide covers what to write on each line.

How does a set change the EU's €3 duty?#

The EU's temporary €3 customs duty on parcels worth up to €150 counts tariff classifications, not items, so how a box is classified changes the bill. Between 1 July 2026 and 1 July 2028, a retail set under one code pays €3, while a bundle of three items under three codes pays €9. Import VAT comes on top.

Parcel to a buyer in the EU, worth under €150 Tariff classifications Customs duty
Cheese board set (board, two knives, dip bowl) 1, as a retail set €3
Gift box with a scented candle and a stoneware mug 2 (34.06 and 69.12) €6
Five identical cotton T-shirts 1 €3

The European Commission's own examples follow the same logic: five T-shirts pay €3 and three T-shirts with a watch pay €6. Declaring a bundle under one code to pay less isn't an option, because the code has to be the correct one. We explain the rule in full in the EU's €3 customs duty, and the de minimis guide covers low-value rules in other countries.

Common questions#

Can I use one HS code for a gift box?#

Only if the box is a retail set under Rule 3(b), a heading names it as a set, or it's a kit of parts for one article. Otherwise each item needs its own code.

Which item's code does a set use?#

The code of the item that gives the set its essential character, judged on its nature, bulk, quantity, weight, value and role in use. If none does, the heading that comes last in numerical order among the candidates applies.

Is a kit the same as a set?#

No. A kit of parts for one finished product is classified as that product under Rule 2(a). A set is two or more different articles brought together for one activity.

Sources#