COMMUNICATION FROM AUSTRALIA, BARBADOS, CANADA, COSTA RICA,
ICELAND, NORWAY, AND THE UNITED KINGDOM

The following communication, dated 31 October 2025, is being circulated at the request of the delegations of Australia, Barbados, Canada, Costa Rica, Iceland, Norway, and the United Kingdom.

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1  Introduction

1.1.  At the Informal Working Group on MSMEs on 3 October 2025 (_INF/MSME/CN/31/Rev.1), the United Nations Sanitation and Hygiene Fund (SHF) highlighted challenges related to global trade and access to menstrual products, particularly for 1.72 billion women and girls who menstruate living across low- and middle-income countries (LMICS) and shared that it estimates that 613 million women and girls are currently relying on materials such as old cloth or toilet paper to manage their menstruation. The SHF noted that regulatory barriers, a lack of funding and investment, and limited understanding of the market contribute to a gap in access and underscored that accurate trade data would be essential to understanding the product access gap and identify market barriers.

1.2.  At the same meeting, AFRIpads, a Ugandan-based menstrual health social enterprise manufacturing reusable menstrual products for over 15 years, presented a case study on its experiences in supplying products to 7 million women and girls across 40 countries. The organization has encountered certain barriers to trade hindering its ability to export its products, including to neighbouring countries, despite demand. AFRIpads identified three trade barriers: (1) testing capacity for reusable pads is limited or non-existent; (2) the absence of harmonized standards; and, (3) there are no specific HS codes for (reusable) menstrual products and their classification is inconsistent across countries. AFRIpads elaborated that as the current version of the Harmonized System (HS) only has a heading (4-digit code) where disposable menstrual products are mixed with other products such as napkins (diapers), while newer categories are not included, it is not possible to derive trade statistics on this important sector, identify cost drivers from taxes or tariffs, align applicable standards (e.g. ISO) with traded goods, and indicated that more specific HS codes, including for the different types of menstrual products, would support import and export opportunities as well as contribute to market insights.

1.3.  In the current version of the HS Nomenclature[1], Heading 96.19 captures "sanitary towels (pads) and tampons, napkins (diapers), napkin liners and similar articles, of any material". According to the WTO Tariff & Trade Data (TTD), global imports for HS code 9619.00 was approximately USD 10 billion annually between 2020 and 2023. As the current version does not disaggregate the categories into subheadings, there is no granular data on the global trade in menstrual products (vis-a-vis other products such as napkins/diapers).

2  Considerations

2.1.  HS Heading 96.19 was first introduced in the HS 2012 edition as a new heading for "sanitary towels (pads) and tampons, napkins and napkin-liners for babies and similar articles, of any material", without further subdivisions. It was created by grouping together these products in a single heading, previously classified according to their constituent materials to simplify classification, ensure consistency, and better reflect trade in these products. Articles of this heading are characterized by their absorbent function, being designed to absorb and retain body fluids for sanitary or hygienic purposes. Non-absorbent articles are excluded and are generally classified according to their constituent material in the appropriate heading.

2.2.  Since the creation of HS Heading 96.19, the customs authorities of a number of WTO Members have added further granularity to their regional or domestic nomenclature (e.g. 8- or 10-digit level tariff lines or statistical categories), providing additional insights into the trade of menstrual health products to the particular market, benefitting both exporters and consumers. For example, Canada has established different tariff lines at the 8-digit level to separate products intended for use by babies (e.g. diapers) from other goods classified under 6-digit HS code 9619.00.

2.3.  The proposed thematic session would be an opportunity for Members to exchange views on these issues and build on past experiences, with the view to informing how to better capture trade in menstrual products in the Harmonized System. It would also be an opportunity to discuss possible next steps, such as whether further granularity in the Harmonized System could support greater trade by a range of producers, from MSMEs to multinational corporations, by providing market insights and identifying gaps in supply and access.

2.4.  The Harmonized System, the international product nomenclature system developed by the World Customs Organization (WCO) and used by more than 212 countries and economic unions, is updated every five to six years. The WCO is currently in the process of reviewing the Harmonized System, with the next updates to be implemented in HS 2033. The WCO has indicated that there is a window to submit proposals by mid-2026 for consideration.

3  Next Steps

3.1.  Taking into account the global demand for menstrual health products, volume of existing trade, importance of the sector, and mandate of the CMA, the proponents would like to propose that in the context of the CMA thematic sessions, Members and other stakeholders share experiences on, for example:

1._    The manner in which they have introduced national or statistic tariff lines under HS heading 96.19 (HS code 9619.00) to identify traditional menstrual products;

2._    The manner in which they have dealt with the domestic classification of reusable menstrual products; and,

3._    Consider how amendments to the Harmonized System could contribute to better supporting trade in menstrual products.

3.2.  With a view to better understanding trade in the sector, Members could also ask the Secretariat to examine the current trade data and consider experiences from other relevant stakeholders.

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