Honey export entries
In 2018 the Ministry for Primary Industries (MPI) finalised their definitions of manuka honey, monofloral and multifloral.
In July 2018 new statistical keys were created in the New Zealand Tariff to reflect these definitions to allow for better reporting and monitoring of industry activity, to facilitate access to markets which require certification, and to protect New Zealand’s reputation in overseas markets.
The new statistical key process has now been operating for nine months. A review of the export entry data indicates that industry (including brokers) needs more assistance with the new process. The benefits of more accurate reporting, both for government and for industry, are lost if the quality of the input material is not up to standard.
To promote better practice, Customs (in collaboration with MPI) has developed the following guidance:
Tariff item 0409.00.00 Natural honey
Includes only natural honey – if any other substance that is not also a natural honey product has been added the product cannot be classified in 0409.00.00.
Extracted honey includes all forms of extracted honey (eg. liquid, powder, freeze dried, filtered, creamed, etc.) and is broken into two groupings – bulk and retail:
- extracted bulk honey includes honey that is packaged for further processing/packaging by the importer – ie. not for retail sale. It is subdivided into three categories:
|Manuka honey, monofloral (presented as bulk)
|Manuka honey, multifloral (presented as bulk)
|Other than manuka honey (presented as bulk)
- extracted retail honey is honey packed for retail sale and is sub-divided on the same basis:
|Manuka honey, monofloral (in retail packs)
|Manuka honey, multifloral (in retail packs)
|Other than manuka honey (in retail packs)
Comb honey means natural honey that is still in the honeybees' wax comb and includes comb cut into chunks.
0409.00.00 27B – Comb
Honeydew means honey produced by bees from the secretions of aphids or other plant sap-sucking insects, rather than nectar.
0409.00.00 31L – Honeydew
Other means any natural honey product that cannot fit into the above descriptions.
This is an historic default category. It should not be used for extracted honey in its various forms, however presented. For example, wildflower honey and clover honey, if extracted, are to be classified in the bulk “other” (17E) or retail “other” (25F) codes respectively.
Powders are derived from extracted honey so they too are classified as above depending on their bulk/retail status. Similarly, natural honey that has had any other substances added to it is not to be classified here, or in 0409.00.00 at all.
This natural honey default “other” is also subdivided as follows:
|Manuka honey, monofloral (ie. not extracted, not honeycomb, not honeydew)
|Manuka honey, multifloral (ie. not extracted, not honeycomb, not honeydew)
|Other than manuka honey (ie. not manuka, not extracted, not honeycomb, not honeydew)
In practice, this classification should rarely, if ever, be used. Customs is in the process of reviewing whether or not this latter category of “other” and associated statistical keys should be removed and would welcome comments from industry.
Other honey products
As noted above, 0409.00.00 can only be used for products that are comprised solely of natural honey. If there are any other ingredients the product is not classified in 0409.00.00.
Listed below are guidelines for where other common honey products may be classified. The guidance has been drawn from international classification rulings that have been made on the basis of detailed descriptions of products presented for a ruling so can be used for general guidance only. If you require a definitive ruling or guidance particular to your product you should contact firstname.lastname@example.org
Honey Lozenges (NZ equivalent: 1704.90.00.00G)
Includes honey propolis lozenges as well as lozenges with other flavourings or substances, however small. For example menthol, ginger, lemon, cranberry, echinacea, etc. includes candies.
Classification rulings in other jurisdictions indicate that these will be classified in 1704.90.00.00G. (NZ WTD equivalent)
Honey Spreads (NZ equivalent: 2106.90.99)
Includes natural honey product with added flavouring, or other substances (including deer velvet) designed to be used as a spread. Likely to be classified in NZ equivalent: 2106.90.99.
Syrups and dry powder concentrates (NZ equivalent: 2106.90.99)
Honey in liquid or powder concentrate form when combined with other substances (eg. with milk powder or added to herbal tea infusions) as a preparation for other foods or beverages. Likely to be classified in NZ equivalent: 2106.90.99. Honey with cacao is likely to be classified in 1806 depending on the amount of cacao.
Throat sprays and dietary supplement capsules (NZ equivalent: 2106.90.99)
Royal jelly (NZ equivalent: 0410.00.00) including in capsules
Unprocessed bee pollen (NZ equivalent: 1212.99.00)
Unprocessed bee pollen is classifiable under the provision for other vegetable products of a kind used primarily for human consumption, not elsewhere specified or included in subheading 1212.99.00.
However if either jelly or pollen is combined with each other or with any other substance the likely classification will be in 2106.90.00 for example, natural honey enriched with bee’s royal jelly is classified in 2106.90.00.
Persons who are authorised to submit an export entry into Trade Single Window are required to take due care that the information they enter is correct.
The goods description entry is a free text entry and should provide a plain language description of the specific nature and type of the good sufficient to identify it for cross-border regulatory purposes such as customs, phytosanitary, statistical or transport. The description should not be a generic trade description, catalogue number, concession description, or the text either of a tariff classification heading, or of a tariff classification that does not accurately describe the particular goods declared on the detail line.
Good information in means good information out
The new statistical keys for honey have been introduced to provide better data for this industry to help it understand trends and growth patterns and also to ensure that the relevant agencies can monitor and ensure compliance and manage reputational risk. The quality of the information entered will directly influence the quality of the data that Customs can provide for these purposes.