When shipping goods to and from the EU, customs risk analysis relies on goods being described as precisely as possible.
This requirement has been highlighted by the World Customs Organization (WCO) in its “Guidelines on acceptable and unacceptable terms for the description of goods”, based on the European Commission’s own Guidance on acceptable and unacceptable terms for the description of goods in 2007.
In the EU, this DG TAXUD guidance, revised several times (most recently in 2021), specifies the need for a plain language description and clearly states that generic terms (e.g. “general cargo”, “parts”) are not acceptable where the description must enable the identification of the goods.
This requirement stems from the need for customs authorities to base their risk analysis on adequate goods descriptions and gained renewed importance in 2021 with the introduction of the Import Control System 2 (ICS2).
Although the document is not legally binding, it reflects a specific legal requirement established under the Union Customs Code (UCC) and its implementing provisions (notably Regulation (EU) 2015/2446) and signals a clear trend towards increased control of data quality in customs declarations.
Objective of the guidance: legal compliance and operational harmonisation
The EU Commission explicitly states:
“The objective of this guidance is to meet the legal requirement to publish such a list where legally required and to give guidance for all situations where a plain language description is required.”
In this context, the guidance serves a dual purpose:
- to comply with the legal obligation to publish a list of unacceptable terms in goods descriptions
- to provide consistent criteria for all situations where a plain language description is required
This approach addresses the need to ensure that the information provided in customs declarations is sufficient for customs controls, in particular for security purposes.
Scope: summary declarations and risk analysis
The guidance applies to all situations where a clear and sufficiently precise description is required for customs authorities to identify goods.
In particular, it responds to the need for customs authorities to base their risk analysis on adequate descriptions when the declarant of the summary declaration does not provide the commodity code.
The Commission warns that vague descriptions prevent the identification of potentially high-risk consignments and may lead to unnecessary delays and additional controls in the logistics chain.
End of generic descriptions
One of the clearest messages of the guidance is the prohibition of generic or ambiguous terms.
Regulation (EU) 2015/2446 provides, in Annex B, under the requirement relating to the Description of goods (for columns A1, A2 and all column F datasets), that general terms cannot be accepted:
“Description in plain language sufficiently precise for the customs services to be able to identify the goods. Generic terms (such as ‘consolidated cargo’, ‘various goods’, ‘parts’ or ‘freight of all kinds’) or descriptions which are not precise enough shall not be accepted. The Commission shall publish a non-exhaustive list of such descriptions.”
Examples of unacceptable descriptions include:
- “general cargo”
- “parts”
- “goods”
- “freight of all kinds”
The reason is clear: these descriptions do not allow customs authorities to identify the true nature or function of the product quickly and unambiguously, as required by legislation.
It is also important to note that the list of unacceptable generic terms and suggested acceptable alternatives is non-exhaustive and subject to continuous updates.
Direct impact on customs compliance
The Commission highlights that inadequate descriptions can have significant operational consequences:
- Delays in Entry Summary Declarations (ENS) and clearance processes
- Increased physical inspections
- Greater administrative intervention
- Inefficiencies in the logistics chain
A shift in approach
Traditionally, many operators have considered the TARIC code sufficient to describe goods, as it is linked to classification, duties, taxes and documentary controls.
However, the current approach introduces a key nuance: Customs authorities need to identify the product, not just classify it, as this information is essential for intelligence and security purposes. As a result, the description must provide sufficient detail on:
- the nature of the product
- its use or function
- relevant and objective characteristics
The Commission’s guidance does not introduce a new obligation, but rather clarifies and reinforces an existing requirement. Its impact, however, is significant:
- it raises the standards for data quality in goods descriptions
- it strengthens the role of data in risk analysis and security
- it requires a review of operational practices that were previously considered sufficient
Companies engaged in international trade must therefore adapt their processes to ensure that:
- goods descriptions are specific and understandable
- generic or ambiguous terms are avoided
- requirements for summary declarations are properly met
Many of the recommendations set out in this guidance, as well as those from the WCO, have already been adopted by other countries and regions, becoming international best practices for customs compliance.
Conclusion
This development represents a further step in the evolution of customs compliance at both EU and global level, where data quality becomes a central element of risk control and analysis.