HTS vs TARIC: One T-Shirt, Two 10-Digit Tariff Codes

HTS vs TARIC is a question every exporter to both the United States and the European Union runs into: the same product needs two different 10-digit codes. The first six digits usually match, because both schedules are built on the Harmonized System. The last four do not, and neither do the duty, the units or the rules behind them. This article walks one product through both schedules and explains each difference.

It is written for importers, brokers and e-commerce sellers who classify for both markets. Both code paths were verified in October 2026: the US against the USITC's HTS 2026 Revision 20, and the EU against the CN 2026 and the TARIC data.

The product

A men's crew-neck T-shirt, knitted, 100% cotton, white with a coloured printed logo, not underwear. The print matters, as you will see.

The US path: 6109.10.00.12

In the Harmonized Tariff Schedule of the United States (HTSUS), the path reads:

At 6109.10.00, the HTS shows a general rate of 16.5%, a special rate of Free for a list of partner programmes and agreements, and a Column 2 rate of 90%. The unit of quantity is dozens, with kilograms also reported. The number in brackets, 338, is a US textile category.

Why not 6109.10.00.04? That line covers T-shirts that are all white, with short hemmed sleeves, a hemmed bottom, a crew, round or mitered V neckline, and without pockets, trim or embroidery. A coloured printed logo means our shirt is no longer all white, so it falls under "Other T-shirts".

The EU path: 6109 10 00 10

In the EU Combined Nomenclature and TARIC, the same shirt reads:

The CN 2026 shows a conventional duty of 12% for 6109 10 00 and a supplementary unit of pieces. The TARIC line 6109 10 00 90 covers the other garments of the subheading, such as singlets and vests. There is no split by gender or by colour.

Side by side

What the differences mean in practice

The shared six digits are real, but they are only a start

Both markets apply the Harmonized System, which the World Customs Organization says is used by more than 200 countries and economies. That is why both codes start with 6109.10. It is also why a good HS-level analysis travels well between markets. The differences between HS, HTS and other national codes are covered in the companion guide on HS vs HTS vs Schedule B.

The national digits answer different questions

The US uses its 9th and 10th digits mainly for statistics. The USITC states that the legal text of the HTS includes the general rules of interpretation, the notes and the terms of the headings and subheadings, while statistical reporting numbers "are not legal but are important in gathering trade data". The suffixes, the statistical-level descriptions and the units of quantity are adopted administratively. The 10-digit number must still be used on entries, so the suffix has to be right.

The EU uses its 7th and 8th digits for the CN, set by regulation, and its 9th and 10th digits only where a measure needs them. A TARIC subdivision often exists because of an anti-dumping duty, a quota or a control, so a wrong TARIC digit can trigger or miss a measure. See what the EU TARIC code is.

Facts that matter in one market can be irrelevant in the other

For this shirt, gender and the all-white plain style change the US code but not the EU code. For other goods, the reverse happens. Collect the facts both schedules need before you classify, not after.

Duty is never only the rate on the line

The 16.5% and 12% rates are starting points. In the EU, preferences and trade defence measures depend on origin; see EU import duty and TARIC measures. In the US, preference programmes, and additional duties in Chapter 99 that depend on origin, can change the total. Always check the current position for your origin and date in each market.

Rulings do not cross the Atlantic

A CBP ruling does not bind EU customs, and an EU Binding Tariff Information decision does not bind CBP. Both are still useful evidence of how an authority reasoned about a product. Search CROSS and EBTI separately, and record which you relied on.

A workflow for classifying in both markets

1. Write one complete product description covering material and percentages, construction, gender, style details, use and presentation.
2. Decide the HS subheading once, using the General Rules of Interpretation, the legal notes and the WCO explanatory notes.
3. Classify separately in each schedule from that subheading down, using the current version of each.
4. Check measures per market for origin and date.
5. Record each decision separately, with the version, the sources and the reasoning, so an audit in one market does not depend on the other. Our classification audit trail guide lists what to keep.

Questions to ask the supplier before classifying for both markets

For apparel like this T-shirt, a single specification sheet can serve both schedules if it answers these questions:

• Construction: is the fabric knitted or woven? This decides between Chapter 61 and Chapter 62 in both markets.
• Fibre content: what is the percentage of each fibre by weight? "Of cotton" and "of man-made fibres" are separate subheadings in both.
• Intended wearer: men, women, boys, girls or unisex? The US statistical lines depend on it; the EU line for T-shirts does not, but other EU apparel headings do.
• Style details: colour, sleeves, neckline, pockets, trim, embroidery and print. These decide some US statistical lines.
• Function: is it sold as outerwear or as underwear? The US separates underwear at the statistical level.
• Presentation: is it sold alone, in a multipack or as part of a set with other garments?

Asking once, in writing, avoids two rounds of questions and gives you evidence for both files.

How HTS Pilot handles two markets

HTS Pilot covers both the US HTS and the EU CN/TARIC. Each lookup uses one market and one tariff version only; markets are never mixed in a conclusion. A US lookup shows codes US-style (6109.10.00.12) with USITC sources, and an EU lookup shows them EU-style (6109 10 00 10) with links to the TARIC consultation. The T-shirt above is the worked example used across the site, labelled as an example rather than a live result. All proposals are suggestions for reference, not official classification decisions; see how a lookup works.

Key takeaways

• A men's printed knitted cotton T-shirt is 6109.10.00.12 in the US HTS and 6109 10 00 10 in the EU TARIC, verified in October 2026.
• The first six digits match because both schedules build on the Harmonized System; the last four are national.
• US digits 9-10 are statistical suffixes; EU digits 9-10 are TARIC subdivisions for measures.
• The 8-digit duty differs: 16.5% in the US and 12% in the EU for this garment, before preferences and additional duties.
• Facts such as gender or colour can matter in one schedule and not the other.
• Rulings and BTI decisions do not bind across markets; classify and document each market separately.

Frequently asked questions

Can I use my US HTS code to import into the EU?

No. The first six digits are often the same, because both schedules build on the Harmonized System, but the last four digits are national and mean different things. A US statistical suffix is not a valid TARIC subdivision. Classify the goods again under the CN and TARIC, and check whether a TARIC subdivision or additional code applies.

Why is the duty different for the same product?

Each market sets its own rates on its own national lines. In the 2026 schedules we checked, men's knitted cotton T-shirts carry a 16.5% general duty in the US HTS and a 12% conventional duty in the EU CN. Preferences, trade defence measures and, in the US, Chapter 99 additional duties can change the amount actually paid.

Are the last two digits of a US HTS code legally binding?

No. The USITC states that statistical reporting numbers are not legal: the statistical suffixes, the statistical-level descriptions and the units of quantity are adopted administratively rather than enacted. The full 10-digit number, meaning the 8-digit subheading plus the suffix, must still be used on entries, so the last two digits have to be right even though the duty rate is set at the 8-digit subheading.

Do the EU and US always agree at six digits?

Usually, but not always. Both apply the same Harmonized System nomenclature and General Rules of Interpretation, yet customs authorities can reach different conclusions on borderline products, and rulings in one market do not bind the other. When the stakes are high, check CBP rulings in CROSS and EU decisions in the EBTI database separately.

Sources

The official texts and pages this article relies on. Check them for the current version before you act.

1. USITC: Harmonized Tariff Schedule of the United States, heading 6109 (2026 Revision 20) hts.usitc.gov
2. USITC: What is the legal HTS and why does it matter? usitc.gov
3. Commission Implementing Regulation (EU) 2025/1926, Combined Nomenclature 2026 (EUR-Lex) eur-lex.europa.eu
4. European Commission: TARIC consultation ec.europa.eu
5. U.S. Customs and Border Protection: Customs Rulings Online Search System (CROSS) rulings.cbp.gov
6. World Customs Organization: What is the Harmonized System? wcoomd.org

This article is general information, not legal advice and not a classification decision. Tariff texts, rates and rulings change: check the current official sources, and ask the customs authority for a binding ruling where the answer matters.