Combined Nomenclature 2026 (CN) – what’s changing and how it impacts businesses in Poland

From 1 January 2026, businesses must apply the updated Combined Nomenclature (CN 2026) for goods classification in the EU. For companies that import into Poland, export from Poland, or report intra-EU movements, this is not just a customs update. CN codes are part of your product master data and appear across commercial documents, ERP systems and reporting workflows.

In practice, the 2026 update means you should verify whether the CN codes assigned to your key products are still valid and consistently used across your documentation and systems — so you can reduce the risk of errors, corrections, delays and logistics disruptions.

In this article, we explain what the Combined Nomenclature is, the key directions of change in the 2026 version, who is most affected, and how to plan a structured update in your organisation.

---

What is the Combined Nomenclature?

The Combined Nomenclature (CN) is an EU-wide goods classification system based on harmonised commodity codes. It enables consistent identification of goods in commercial documentation as well as in customs, trade policy and statistical procedures across the EU.

CN codes are used primarily:

• in customs declarations for import and export,
• to determine the applicable tariff treatment and trade-policy measures,
• in trade statistics, including Intrastat reporting,
• in company systems as part of product master data.

From a business perspective, a CN code is a core data attribute — like product name, unit of measure or country of origin. If the code is outdated or used inconsistently, the risk of mismatches between documents rises, often leading to corrections, operational friction and supply-chain issues.

The current CN 2026 text and code search tools are published by the European Commission, with links referenced in communications from the Directorate-General for Taxation and Customs Union (TAXUD).

---

Why does the CN code list change every year?

Annual updates reflect technological development, new product categories, and the need to refine existing classifications. The most common reasons include:

1. better alignment with market changes (new or modified products),
2. improved monitoring of selected goods for EU policy and statistical purposes.

In practice, an update may mean:

• some products must be classified more specifically,
• an existing code is split into several new ones,
• the wording/description of a position changes, refining classification rules.

---

What changes in the Combined Nomenclature 2026?

The 2026 version is primarily modernising and reorganising. New subheadings have been introduced to make certain product groups easier to track. For businesses, this increases the number of cases where the previous code needs to be refined.

Goods linked to energy technologies and modern industry

Examples of newly specified subheadings include goods and components used in supply chains for:

• battery technologies (e.g., nickel-manganese-cobalt oxides; lithium iron phosphate – codes in Chapter 28),
• photovoltaics (e.g., photovoltaic wafers – Chapter 38),
• wind power (e.g., tubular steel towers and tower sections for wind turbines – Chapter 73; wind turbine blades – Chapter 84),
• energy equipment and components (e.g., generators for hydrogen fuel cells, inverters with maximum power point tracking, plastic film separators, stacked galvanic cell assemblies – Chapter 85).

In practice, companies in manufacturing, energy, renewables, electronics and automotive should prioritise reviewing codes for the highest-value and highest-volume goods.

Updates in selected chemical groups

In line with international recommendations, new subheadings were also introduced in Chapter 29, including certain aromatic ethers and saturated aliphatic monocarboxylic acids and their derivatives.

For chemical businesses (and parts of the manufacturing sector), the key is to connect classification decisions to product parameters such as composition, properties and intended use.

Who will be affected the most?

CN updates usually have the biggest impact on companies that:

• regularly import from outside the EU or export outside the EU,
• report Intrastat due to large-scale movements of goods within the EU,
• maintain extensive product/component catalogues (manufacturing, distribution),
• trade in advanced or specialised goods where refinements happen more often.

In international groups, an additional risk is fragmented data ownership: classification may be set centrally, while the consequences of outdated codes occur locally (documentation, clearances, reporting). Clear roles and an approval process for changes are essential.

---

How to prepare your company for 2026 – 6 practical steps

1) Identify products with the highest business impact

Start by reviewing:

• goods with the highest value and volume,
• products critical for production continuity,
• groups likely to be affected by refinements (energy, electronics, chemicals, industry).

2) Map where CN codes appear in your organisation

Most problems come from data consistency. Check whether the code is identical in:

• ERP product master data,
• sales and purchase documentation,
• data provided to customs/logistics handling,
• reporting tools and operational reports.

3) Align cooperation rules with partners (logistics / customs handling)

Clarify:

• where partners obtain the commodity code,
• who is responsible for data updates,
• how doubts are raised and how changes are reviewed/approved.

4) Update systems and introduce data-quality controls

After implementing changes, add checks such as:

• code format validation,
• consistency checks between invoices and logistics documents,
• reconciliation between data sources (ERP vs reporting tools).

5) Assess the impact on reporting and import-related settlements

If you report trade flows, make sure that:

• the update is reflected in files, dictionaries and mappings,
• reporting systems do not pull codes from outdated sources,
• your team has clear rules for products where CN 2026 requires additional specificity.

It’s also worth verifying whether the classification update influences your settlement approach and documentation requirements. Where needed, consider structured support via tax advisory in Poland.

6) Document decisions and create a short internal procedure

A short document is enough, covering:

• responsibilities for updates,
• review schedule (e.g., annually around year-end),
• how decisions and product descriptions are archived,
• escalation rules when classification is uncertain.

---

Common mistakes after the update —and how to avoid them

Typical operational risks include:

• copying last year’s codes without verification despite new subheadings,
• inconsistencies between systems and documents,
• no internal documentation supporting the code chosen for technical products,
• no “first shipments in the new year” process test.

From an internal control perspective, the most effective approach combines prioritisation (key goods first) with data consistency (one source of truth across systems).

---

The Combined Nomenclature 2026 (CN) introduces refinements that matter especially for technology, energy and chemical sectors. For most companies operating in Poland, the key priority is ensuring CN code consistency across product data, documentation and reporting. A methodical approach —priorities, data mapping, integrations, quality checks and a simple procedure —helps reduce the risk of corrections and operational disruption.

---

Legal basis:
Commission Implementing Regulation (EU) 2025/1926 of 22 September 2025 amending Annex I to Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common Customs Tariff

---

If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

Contact us »

***