Introduction: Why This Matters for Your Business
If you're an Indian exporter shipping goods to the European Union, you've likely encountered a bewildering array of customs codes: HS, HSN, CN, and TARIC. With the EU's Carbon Border Adjustment Mechanism (CBAM) now in effect, understanding these codes isn't just about customs clearance—it's about determining whether your products fall under CBAM regulations and what compliance obligations you face.
The confusion is real and widespread. Many Indian exporters are asking:
- "I know my HSN code from Indian customs. Is that the same as the EU's CN code?"
- "Does CBAM use HS codes or CN codes?"
- "What's the difference between CN and TARIC codes?"
- "How do I know if CBAM applies to my specific product?"
This guide answers all these questions and more. By the end, you'll have crystal-clear understanding of each code system and exactly how to determine CBAM applicability for your products.
The Root of the Confusion
Why Indian Exporters Are Confused
The confusion stems from the fact that all four code systems share the same first 6 digits but diverge after that. Indian exporters are familiar with HSN codes from domestic operations, but EU CBAM regulations reference CN codes. This creates uncertainty about whether products are covered under CBAM.
Key insight: The first 6 digits are identical across all systems, allowing you to cross-reference between them. The additional digits provide region-specific classifications.
HS Code: The Global Foundation
What is an HS Code?
The Harmonized System (HS) code is the international standard for classifying traded products. Developed and maintained by the World Customs Organization (WCO), it's used by over 200 countries worldwide.
Key Characteristics:
- Length: 6 digits
- Issuing Body: World Customs Organization (WCO)
- Scope: Global standard used by all countries
- Purpose: Universal product classification for international trade
- Updates: Revised every 5 years by WCO
Example: Cotton jacket = 610120
Why HS Codes Matter
HS codes form the foundation of all other classification systems. The first 6 digits of HSN, CN, and TARIC codes are always identical to the HS code. This means if you know your product's HS code, you've already got the first 6 digits of all other codes.
HSN Code: India's Classification System
What is an HSN Code?
HSN (Harmonized System of Nomenclature) is India's extension of the global HS code system. It's used by Indian Customs and for GST (Goods and Services Tax) purposes.
Key Characteristics:
- Length: 8 digits (can extend to 10 for some products)
- Issuing Body: Indian Customs / Central Board of Indirect Taxes and Customs (CBIC)
- Scope: India-specific classification
- Purpose: Indian customs tariff, GST classification, and trade statistics
- Structure: First 6 digits = HS code + 2 India-specific digits
Example: If HS code for cotton jacket is 610120, the HSN might be
61012010 (with India-specific subcategory)
Important for Indian Exporters
You're already familiar with HSN codes from your Indian customs documentation and GST filings. However, HSN codes are NOT used for EU CBAM compliance. You need to map your HSN to the corresponding EU CN code.
CN Code: EU's Export & Trade Classification
What is a CN Code?
CN (Combined Nomenclature) is the European Union's 8-digit extension of the HS code system. It's the primary classification used for EU trade statistics and exports.
Key Characteristics:
- Length: 8 digits
- Issuing Body: European Commission
- Scope: EU-specific classification
- Purpose: EU exports, Intrastat (intra-EU trade), and CBAM compliance
- Structure: First 6 digits = HS code + 2 EU-specific digits
- Updates: Revised annually by the EU via Combined Nomenclature Regulation
Example: Cotton jacket = 61012010 (EU classification)
Critical for CBAM Compliance
CN codes are what CBAM regulations use to define covered products. When the EU CBAM regulation lists products in Annex I, it uses 8-digit CN codes (or sometimes 4-digit HS headings that encompass multiple CN codes).
To determine if your product is covered by CBAM, you must identify its CN code and check it against the CBAM product list.
TARIC Code: EU's Import Classification
What is a TARIC Code?
TARIC (Integrated Tariff of the European Union) is the EU's most detailed classification system, extending CN codes to 10 digits for import purposes.
Key Characteristics:
- Length: 10 digits (sometimes 12 with additional national subcodes)
- Issuing Body: European Commission
- Scope: EU imports only
- Purpose: EU import declarations, duties, VAT, and regulatory measures (including CBAM)
- Structure: First 8 digits = CN code + 2 additional EU measure digits
- Coverage: Includes all EU import duties, taxes, quotas, and special measures
Example: Cotton jacket = 6101201000 (full TARIC for EU import)
When You Need TARIC Codes
TARIC codes are required for:
- EU customs import declarations (Union Customs Code Article 201)
- Calculating import duties and VAT
- Identifying applicable trade measures and restrictions
- CBAM import declarations (10-digit TARIC required from January 1, 2026)
Note: Your EU importer typically handles TARIC classification, but as an exporter, knowing the TARIC code helps ensure smooth customs clearance.
Side-by-Side Comparison: All Four Codes
| Feature | HS Code | HSN Code (India) | CN Code (EU) | TARIC Code (EU) |
|---|---|---|---|---|
| Digits | 6 | 8 (or 10) | 8 | 10 (or 12) |
| Issuing Body | WCO (Global) | Indian Customs | European Commission | European Commission |
| Geographic Scope | Worldwide | India only | EU only | EU only |
| Primary Use | Global classification | Indian customs & GST | EU exports & Intrastat | EU imports |
| CBAM Relevance | Foundation (first 6 digits) | Not directly used | Primary CBAM reference | Required for import declarations |
| Update Frequency | Every 5 years | As per Indian regulations | Annually | Continuously updated |
| Example (Cotton Jacket) | 610120 | 61012010 | 61012010 | 6101201000 |
Understanding CBAM Applicability
Which Code Does CBAM Use?
The EU CBAM regulation (Regulation 2023/956) defines covered products using 8-digit CN codes listed in Annex I. However, there's an important nuance:
- Specific CN codes: Some products are listed with their full 8-digit CN code
- HS headings: Some products are listed by their 4-digit HS heading, which means ALL CN codes under that heading are covered
Critical CBAM Rule
CBAM applies to the imported good's CN code at EU customs entry, not to its components or origin processing.
Example: Aluminium sheets (CBAM-covered CN code) used to manufacture car doors (non-covered CN code) are only covered by CBAM if imported as sheets. Once manufactured into car doors, they're no longer covered.
CBAM Covered Sectors (2026 onwards)
CBAM currently covers the following sectors with specific CN codes:
| Sector | Example CN Codes / HS Headings | Products Covered |
|---|---|---|
| Cement | 2507 00 80, 2523 10 00, 2523 21 00, 2523 29 00 | Clinkers, Portland cement, aluminous cement, hydraulic cement |
| Iron & Steel | 7205, 7208, 7224, 7308, 7309, 7310 | Granules, flat-rolled products, structures, tanks, containers |
| Aluminium | 7601, 7611 00 00, 7612 | Unwrought aluminium, reservoirs, casks, drums |
| Fertilizers | 3105 00 00 | Mineral/chemical fertilizers with N, P, K |
| Electricity | 2716 00 00 | Electrical energy |
| Hydrogen | 2804 10 00 | Hydrogen gas |
Note: The EU is proposing to expand CBAM to cover 180 additional steel and aluminium product lines from 2028, pending approval.
Practical Guide for Indian Exporters
Step-by-Step: From HSN to CBAM Compliance
Your CBAM Code Journey
- Start with your HSN code (from Indian customs/GST documents)
- Extract the first 6 digits (this is your HS code)
- Find the corresponding EU CN code using EU TARIC database
- Check CBAM Annex I to see if your CN code is listed
- If covered: Prepare for CBAM compliance (emissions reporting, authorization, etc.)
Mapping HSN to CN Codes
Since both HSN and CN codes share the same first 6 digits (the HS code), mapping between them is straightforward:
Example Mapping:
- Indian HSN: 72083600 (Flat-rolled iron/steel, painted)
- First 6 digits (HS): 720836
- EU CN code: 72083600 (likely the same, but verify in TARIC)
- CBAM Status: Check if 72083600 or heading 7208 is in CBAM Annex I
Free Tools for Code Lookup
Official EU Resources:
- EU TARIC Database - Official CN/TARIC lookup
- EU Customs Tariff - Complete tariff information
- WCO HS Database - Global HS code lookup
Third-Party Tools:
- CarbonChain CBAM Guide - CBAM-specific CN code checker
- CBAM Checker - Quick CBAM applicability check
Practical Steps for CBAM Compliance
For Indian Exporters Shipping to EU
CBAM Compliance Checklist
-
Identify Your Product's CN Code
- Use your HSN code as starting point
- Verify exact CN code in EU TARIC database
- Document the CN code for all products exported to EU
-
Check CBAM Coverage
- Review CBAM Annex I for your CN code
- Check if your 4-digit HS heading is listed
- Confirm with EU importer if uncertain
-
If CBAM Applies (from Jan 1, 2026):
- Calculate embedded emissions for your products
- Obtain CBAM authorization (or work with authorized EU importer)
- Report emissions quarterly using CN/TARIC codes
- Maintain documentation for verification
-
Coordinate with EU Importer
- Share CN code and emissions data
- Ensure they have correct TARIC code for customs
- Align on CBAM reporting responsibilities
Common Scenarios for Indian Exporters
Scenario 1: Steel Products
- Your HSN: 72084090 (Flat-rolled iron/steel)
- HS Code: 720840 (first 6 digits)
- EU CN Code: 72084090 (verify in TARIC)
- CBAM Status: Heading 7208 is covered → CBAM applies
- Action: Calculate emissions, report quarterly, coordinate with EU importer
Scenario 2: Aluminium Products
- Your HSN: 76012000 (Unwrought aluminium alloys)
- HS Code: 760120
- EU CN Code: 76012000
- CBAM Status: Heading 7601 is covered → CBAM applies
- Action: Full CBAM compliance required
Scenario 3: Textile Products
- Your HSN: 61012010 (Cotton jackets)
- HS Code: 610120
- EU CN Code: 61012010
- CBAM Status: NOT in CBAM Annex I → CBAM does NOT apply
- Action: No CBAM compliance needed (standard customs only)
Common Mistakes to Avoid
Top 5 Mistakes Indian Exporters Make
-
Assuming HSN = CN Code
While the first 6 digits match, the last 2 digits may differ. Always verify the exact CN code in EU TARIC database.
-
Using Only HS Code for CBAM
CBAM regulations use 8-digit CN codes. A 6-digit HS code is insufficient for determining exact CBAM applicability.
-
Ignoring HS Heading Coverage
Some CBAM products are listed by 4-digit HS heading, meaning ALL CN codes under that heading are covered, even if not explicitly listed.
-
Not Coordinating with EU Importer
CBAM compliance is a shared responsibility. Ensure your EU importer has correct codes and emissions data.
-
Using Outdated Code Lists
CN codes are updated annually. Always check the latest EU Combined Nomenclature and CBAM regulations.
Code Verification Best Practices
- Double-check: Verify CN codes using multiple sources (TARIC database, customs broker, EU importer)
- Document: Keep records of code classifications and verification sources
- Update regularly: Review codes annually when CN nomenclature is updated
- Seek expert help: Consult customs experts or CBAM consultants for complex products
- Test with small shipments: Verify codes with initial small shipments before scaling up
Need Expert Help with CBAM Compliance?
EnCarbonSys specializes in helping Indian exporters navigate EU CBAM regulations. We provide CN code verification, emissions calculation, and complete CBAM compliance solutions.
Get Expert GuidanceFree CN Code Checker Tool (Coming Soon)
EnCarbonSys CN Code Tool
We're developing a free CN code checker tool specifically for Indian exporters. This tool will:
- Convert your HSN code to the corresponding EU CN code
- Instantly check if your product is covered by CBAM
- Provide the full TARIC code for EU import declarations
- Show applicable CBAM requirements and deadlines
- Generate compliance checklists for your specific products
Stay tuned! We'll link the tool here once it's live. In the meantime, contact us for manual CN code verification and CBAM guidance.
Conclusion: Clarity for CBAM Success
Understanding the differences between HS, HSN, CN, and TARIC codes is fundamental to CBAM compliance. Here's what you need to remember:
Key Takeaways
- HS Code (6 digits): Global foundation, first 6 digits of all codes
- HSN Code (8 digits): India-specific, used for Indian customs and GST
- CN Code (8 digits): EU-specific, primary reference for CBAM
- TARIC Code (10 digits): EU imports, required for customs declarations
- For CBAM: Identify your CN code, check Annex I, comply if covered
- First 6 digits match: Use your HSN to find the corresponding CN code
With this knowledge, you can confidently determine whether CBAM applies to your products and take the necessary steps for compliance. The key is to move from your familiar HSN code to the EU's CN code system and verify against the official CBAM product list.
For more CBAM insights and compliance resources, explore our complete CBAM resource library.
References & Resources
Official EU CBAM information, regulations, and guidance documents
Full text of the CBAM regulation including Annex I (covered products)
Official tool for looking up CN and TARIC codes
Annual updates to EU CN codes and classifications
Global HS code lookup and classification tools
Central Board of Indirect Taxes and Customs - HSN code information
Comprehensive guide to CBAM-covered CN codes
Free tool to check if products are covered by CBAM
Professional CBAM compliance services for Indian exporters