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Cargo Drones and Customs

Are cargo drones the future of international trade?

Google has their own division dedicated to improving the technology, and UPS recently received a license to operate an “unlimited number of drones.” Larger cargo drones — capable of carrying much heavier loads — are not yet operational but are projected to hit the market next year.

a Google drone in action. The technology has the power to push trade in a new direction.

What this new mode of transport entails for international trade remains unclear, but the impact of thousands of new air consignments could be massive. Countries with a close proximity to each other like Canada and the US could see their trade relation change in unpredictable ways. A drone fleet’s ability to fulfill orders endlessly resembles the pipeline mode more than any other, which is currently only used by the energy sector.

We sent a request to the CBSA media relations team but have yet to hear back from them on how they plan to regulate unmanned vehicles and their commercial consignments. Assuming that the regulations are similar to those of other commercial vehicles, drone operators should prepare for the following when extending their routes internationally:



  • Drone operators will require a carrier code (or 'SCAC' code)
  • Pre-manifest information must be sent before each voyage
  • For each consignment, a Customs release
  • Random inspections or check-ins at sites designated by Customs

Given the complexity and pace of Customs transactions it may be a while before autonomous vehicles accelerate international trade. Some fast-moving individuals are already shaking up the cross-border scene with drones: CBP in the US recently busted a meth trafficker who attempted to fly his contraband over the US – Mexican border. Could Amazon be next?



The HS classification of plant-based meat

 



What is a classification?

HS classification is the process of determining a products place in the universal index of international trade. Proper classification is essential to compliance, but finding the true classification of a certain product can be challenging and sometimes  absurd.

Plant-based meat vendors are working hard to brand their products as a meat alternative rather than as a traditional vegetarian product. While this marketing strategy is working, for Customs purposes these products remain under the same heading as all other imitation meats (2106.90). However, new products are arriving quickly (such as plant-based eggs and bacon) which could be classified differently depending on their ingredient list and level of manufacturing — if the product has one dominant ingredient (i.e. it is made of 100% beets) then the correct classification could reasonably shift to a different category.

 

Description HS Code Current Duty Rate PGA Requirements* Detail
Plant-based meat (incl. burger patties and sausages) 2106.90.99.99  10.5%  CFIA, Environment Canada  All plant-based meat products are classified as ‘food preparations not elsewhere specified’

*Note that the PGA requirements can vary depending on the country of origin, end use and state (dried, chilled, fresh) of the items you are importing. For more information, please contact us.

**Classifications are provided by Border Bee Customs Brokers as a reference guide for importers and should not be relied upon solely for commercial classification.



The HS Classification of Drones

Look up in the sky! its a … helicopter of an unladen weight not exceeding 998 kg


What is a classification?

HS classification is the process of determining a products place in the universal index of international trade. Proper classification is essential to compliance, but finding the true classification of a certain product can be challenging and sometimes  absurd.

Drones pose an interesting challenge for classification since their end use can vary significantly — most rulings to date have focused on their end use (as either surveying equipment or videography) leading to a variety of different headings and duty rates. The admissibility in Canada as Transport Canada has yet to regulate such products at time of import. Perhaps even more interesting from a Customs perspective, is how cargo drones will be regulated when it comes to cross-border traffic!?

 

 

 

Description HS Code Current Duty Rate PGA Requirements* Detail
Drone (UAV) 8802.11.00.14  0%  n/a  Drones for carrying cargo are classified as mini-helicopters. We would place other drones — including hobby and racing drones — under this heading as well.
Video Drone 8525.80.00.50  0%  n/a  Drones outfitted with video cameras — for which the principal purpose is taking video — will be classified as cameras.
Drone for Surveying 9006.30.90.00  5%  n/a  Some specialized drones, such as those for aerial surveying, have been classified by the CBSA as surveying cameras.
Drone Propellers and other parts 8803.10.00.00  0%  n/a  Parts for drones — excluding cameras — will be classified as parts of helicopters.

*Note that the PGA requirements can vary depending on the country of origin, end use and state (dried, chilled, fresh) of the items you are importing. For more information, please contact us.

**Classifications are provided by Border Bee Customs Brokers as a reference guide for importers and should not be relied upon solely for commercial classification.



The HS classification of Drones and Drone Parts

Drones pose an interesting challenge for classification since their intended use will have a large impact on their tariff heading: Drones outfitted with HD cameras will be classified as cameras, whereas drones for carrying packages

No permits are yet required to import drones so the admissibility is not an issue.

Description HS Code PGA Requirements* Explanation
Drone (UAV)  8802.11.00.14  Drones (or Unmanned Aerial Vehicles) designed for carrying cargo or delivery will fall under the “other aircraft” heading as lightweight helicopters
Video Drone  8525.80.00.50  Brokers note: if the camera installed in the drone is less valuable than other components, or if its primary function is not take video, it can be arguably classified as a drone.
 Survey Drone  9006.30.90.00  CBSA ruling  #272335. Drones meant for geographical surveying are classified as “cameras specially designed for aerial survey”
Drone Propellers  8803.10.00.00  Propellers for drones are considered parts of aircraft where imported separately from drones

 

*Note that the PGA requirements can vary depending on the country of origin, end use and state (dried, chilled, fresh) of the items you are importing. For more information, please contact us!

**All classifications are the opinion of Border Bee Customs Brokers Inc. and are meant to assist trade companies in their HS determinations. Unpredictable changes in classification may occur as a result of even minor modifications so we encourage importers to seek binding rulings where possible and not to use this article as legal advice.



The HS Classification of Cannabis Products

With the imports of legal cannabis plants and products set to jump significantly, Statistics Canada has published their list of harmonized system tariff classifications to help importers. Please find a list of the most common items below along with their OGD regulations:

Note that only licensed growers may import Cannabis products. Please check with Health Canada for the admissibility of what you plan to import before ordering.

Description HS Code OGD Requirements**
Live Plants 0602.90.90.90 Health Canada Permit, Phytosanitary Certificate, CFIA
Cannabis Seeds for Sowing 1209.99.10.29 CFIA: Phytosanitary Certificate, Plant Protection Permit, Health Canada Permit, *Seed Analysis (for orders > 500 kg)
Cannabis plants, herbs & seeds used in pharmacy 1211.90.90.50 Health Canada Permit, CFIA: No Permit Required Letter, Plant Protection Permit
Cannabis resin or oleoresin 1302.90.00.10 CFIA, Health Canada permit
Cannabis oil, extracts, and tinctures 1302.19.00.10 CFIA, Health Canada permit
Medicaments for retail sale, containing cannabis or cannabinoids 3004.90.00.21 CFIA, Health Canada

**Note that the OGD requirements can vary depending on the country of origin, end use and state (dried, chilled, fresh) of the items you are importing. For more information, please contact our office directly.