I observed the opening of a first time shipment with 500 kgs of dark leaf packing shisha tobacco at a bonded warehouse just outside of Rotterdam. The shipment looked complete. The buckets were sealed with a fresh molasses sheen. The shipment had been sitting at the Berlin lounge for eight weeks.

The customs agent revised the calculation of the shisha duty. The number had nearly doubled the budget of the shipment.

The first time importer had declared the shipment hookah basesd on the net weight. Every bucket, every gram of molasses, and flavor were calculated. The customs authority had declared the entire weight as tobacco. They did not care about the sugar syrups. They did not separate the humectants. Everything was taxed at the full tobacco excise rate.

This mistake ultimately cost the first time importer 14,000 euros and nearly ruined his first year of trading.

The first time importer should have had a better understanding of TWI, Tobacco Weight Percentage.

An Introduction to TWI and Why An Importer Should Care

TWI, Tobacco Weight Percentage or Tobacco Weight Index, is a measurement of the actual content of tobacco within a shisha tobacco product when compared with the total weight.

The formula for TWI is: TWI = (Weight of Dry Tobacco / Total Product Weight) x 100

A standard 1,000 gram bucket of bulk shisha tobacco can contain anywhere between 300 and 400 grams of actual tobacco. The rest of the bucket is molasses, and other preservatives, glycerin and flavorings.

Customs authorities in most countries don’t evenly tax the whole bucket. Instead, they segregate tobacco versus non-tobacco parts of the bucket and create separate tariff lines. The difference can be substantial.

Management of bulk shisha tobacco import as a whole, TWI is not a technical footnote, but a direct line item on your cost sheet.

Three Important Weights

Ordering bulk shisha tobacco import incurs three important weights:

Gross weight. Total weight of everything, including empty pails or buckets, vacuum seals, cardboard outer cartons, pallet wrap, or other packaging. This weight determines freight costs. It is not a consideration for duties.

Net weight. This is simply the weight of the product within its packaging. It is commonly thought to be the weight that customs uses for consideration.

Tobacco dry weight. The tobacco leaf content after the removal of moisture, sugars, and humectants. This is typically the weight that most customs consider for the purpose of excise duty, provided you know how to declare it correctly.

The difference between the net weight and the tobacco dry weight is the source of a lot of loss for importers. A dark leaf shisha tobacco blend contains anywhere between 55 to 65 percent non-tobacco ingredients. Putting net weight as tobacco means you will be paying duty for material that is not tobacco.

How TWI Changes the Customs Classification and Duty Rate

Handlings shisha tobacco in different parts of the world differs. The way in which the product is processed, and the regulations that apply governs customs classification.

European Union: TPD and Excise Directives

In the EU, shisha tobacco falls under CN code 2403 11 00. Excise duty applies to the tobacco content, and there is no single method for determining tobacco content. Hence, each member state has its own method.

For some customs authorities, a manufacturer’s TWI declaration is sufficient. Some authorities require an independent lab analysis. Some authorities only apply the full excise rate to the net weight, and, in the absence of the importer contesting this, will expect the appropriate documentation.

As per the EU Tobacco Excise Directive (2011/64/EU), the taxable base for smoking tobacco is the weight of the product. However, countries have some flexibility on how they define “product” when it comes to tobacco for shisha. This creates a gray area in which TWI documentation can decrease your duty assessment by 40 to 50 percent.

United States: TTB and PCA Requirements

Shisha tobacco is regulated by the U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB). The excise tax is per pound of tobacco. The definition of “tobacco” includes the leaf and any added sugars or humectants unless the burden of proof is on the importer.

Because of the Prevent All Cigarette Trafficking (PACT) Act, additional requirements are placed on the importer. The importer is required to register with the TTB and disclose the ingredients of the product. TWI documentation is essential to showing that the product is shisha tobacco and not a product associated with a higher tax category.

Middle East and North Africa: Variations in Tariff Codes

Ad valorem duties plus excise taxes on tobacco are found in the UAE, Saudi Arabia and Egypt. Whether a product is classified under “shisha tobacco products” or “tobacco preparations” determines the duty rate.

A precise TWI on your commercial invoice and certificate of analysis may impact the tariff line applied. The tariff line can make a difference of between 50 percent and 200 percent of the declared value.

Why are Standard Invoices Wrong?

Most bulk shisha tobacco invoices only indicate the net weight. They also do not separate tobacco dry weight, and this is normally accepted for domestic sales. This is not the case for international sales.

The customs broker requires:

• Includes the net weight of the consignment
• Includes TWI of certified TWI or a lab or manufacturer specification
• Includes tobacco dry weight calculated from the above two

Without TWI, it is classified conservatively (most likely) and assumes that the entire net weight is taxable as tobacco.

A Practical Illustration

Net weight per bucket	1,000 g
TWI (manufacturer stated)	35%
Tobacco dry weight per bucket	350 g
Non-tobacco weight per bucket	650 g
Pallet of 100 buckets net weight	100 kg
Pallet tobacco dry weight	35 kg
Excise duty on 100 kg (no TWI declared)	Full rate on 100 kg
Excise duty on 35 kg (TWI declared)	Full rate on 35 kg

In such a case, the importer paying TWI would be subject to duties on 35 kg of tobacco as opposed to 100 kg. The savings would be proportional to the local excise duty; however, the principle would remain the same.

How to Ensure TWI Accuracy

You will need documentation that will be accepted by a customs authority. These are the most common ways.

Manufacturer Specification Sheet

A reliable supplier will provide a specification sheet with TWI for each product batch. The sheet must include:

• – Batch number and production date
• – Total net weight
• – Tobacco dry weight after moisture removal
• – TWI percentage
• – Testing method (oven drying, Karl Fischer, etc.)

At Linkup Hookah, we provide batch-specific documentation. Our bulk tobacco products are tested each production run to provide buyers with the TWI data required to clear customs.

Independent Laboratory Analysis

Some customs authorities will need a Certificate of Analysis from an accredited third party. They will take a sample from the consignment, examine it, and provide a report with the measured TWI.

Sample testing is costly, with prices ranging $200 to $500, but it eliminates border disputes for imports, which is a bonus for massive importations of shisha tobacco, considering the savings over the duty incurred.

Testing Tobacco Internally (TTL)

You could determine TWI by an oven method in-house. Weigh a sample of the product, and dry it to an oven temperature of 100°C for two hours, and weigh it again. The weight difference will be the moisture and any additional ingredients, with the remaining weight comprising the solids of the tobacco.

While this method isn’t certified for customs, it helps you derive approximate values to support the claims of your suppliers.

Typical Errors Made By Importers

Erroneous Assumption 1: All Buckets Have Identical TWI

Not all blends have the same TWI. A dark leaf blend that has a heavy molasses soak can have a TWI of 30 to 35 percent. On the other end of the spectrum, a blond leaf blend that is lightly processed can range from 40 to 45 percent TWI. A leaf that is based on a tea or an herbal product may have no tobacco at all.

Never take a single TWI value for all variations of a product. A separate value and documentation must be maintained for each SKU.

Erroneous Assumption 2: Not Accounting for the Shelf Life and Moisture Migration

TWI may fluctuate in time. During transportation, molasses can separate from the tobacco leaf. The value that was uniformly 38 percent TWI at the factory may change after being transported for six weeks in a 40°C shipping container.

Make your measurements based on the samples received, and do not rely on a spec sheet that was written half a year ago.

Erroneous Assumption 3: Assuming the Customs Broker Will Figure It Out

Many customs brokers are not skilled in shisha tobacco. They tend to play it safe by classifying shisha under an expansive category. If you cannot provide them with a TWI certificate, they will likely take the net full weight of the shisha.

You have to give them a number. It is your profit on the line.

How to Format Your Commercial Documents for a TWI Declaration

On your commercial invoices and packing slips, you need to create a separate line item for every SKU that includes:

1. Description of the item
2. Individual net weight
3. Quantity
4. Total net weight
5. TWI
6. Calculated dry weight of the tobacco
7. HS code with specific subheading for tobacco

Include the TWI certificate or a copy of the manufacturer specifications as supporting evidence.

This needs to be sent to your customs broker prior to the shipment arriving. Don’t delay until the shipment reaches the port. If the broker submits the shipment TWI data during the clearance process, the declaration cannot be modified without incurring delays and additional payment.

Which Products Benefit Most from a TWI

Almost all bulk tobacco shipments gain from a properly executed TWI. Beyond that, there are a couple categories that receive particular benefit.

dark leaf tobacco — These tend to have molasses and glycerin. The non-tobacco fraction can exceed 60 percent. Without TWI documentation, you pay duty on the full bucket weight.

Flavored molasses tobacco — The majority of the time, these products are 70 percent flavor carrier with only 30 percent net tobacco. The duty costs are less when TWI is declared.

Bulk buckets for commercial lounges — lounges purchase by the kilogram. A multi-venue operation may place an order for anywhere between 500 to 2,000 kg of bulk shisha tobacco. Customs duties vary depending on volume.

Our Premium Darkside Series Bulk Dark Leaf Shisha Tobacco is an attractive option for importers who request TWI data. Each batch is accompanied by a spec sheet which brokers and customs officials typically accept.

For lounges that require variety in higher amounts, the Premium Musthave Series High Demand Dark Leaf Shisha Tobacco is an excellent option as it also offers batch-level documentation and a broader flavor selection.

For thookah hoses who prefer lighter, more accessible options, the Premium Adalya Series Bulk Shisha Tobacco Flavored Molasses satisfies the demand for TWI documentation in a blond leaf format.

What a Proper TWI Certificate Looks Like

A TWI certificate from a supplier should include these elements:

• – Supplier name and address
• – Product name and SKU
• – Batch or lot number
• – Production date
• – Net weight per container
• – Test method (drying at 105°C for 3 hours, or equivalent)
• – Tobacco dry weight as percentage of net weight
• – Signature of quality control representative
• – Date of testing

Whenever a supplier cannot provide a TWI certificate with any of the required fields, you must ask why. A supplier not providing batch-level TWI data demonstrates either poor testing or poor control over production quality. In either case, the customs risk falls on you.

Regulations Are Not the Same – Plan for Where You Are Going

A TWI approach applicable to the Netherlands isn’t necessarily useful for Saudi Arabia. Each country maintains its own tariff schedule and its own criteria for acceptance.

Before you make a bulk purchase order for shisha tobacco imports, check with your local customs broker:

• – What are the customs authorities requirements around tobacco and weight validation? What do they accept?
• – Are they okay with manufacturer certificates? Or do they insist on certificates from third party laboratories?
• – Is there an HS Code for hookah tobacco that separates tobacco from non-tobacco?
• – What is the excise on the tobacco vs. the excise on the complete product?

Get their recommendations in writing. Customs brokers are not a reliable source for your documentation. They will change and border authorities do change, Documentation is the only constant.

The TWI Bottom Line

For the individual authorizing the purchase order, TWI is not a quality control issue, it is a cost control issue.

An overstatement of TWI on a customs declaration means paying excise duty on a product that is not tobacco. For one pallet of dark leaf shisha, this cost can even run in the thousands of dollars. For a full year’s importing program, it can reach a hundred thousand dollars.

This happened to the importer in Rotterdam. He noticed this and now follows TWI. For his second order, his duty bill was 47% lower than his first. The only difference was a tobacco weight percentage declaration.

The price distinction for tobacco versus molasses is made by that piece of paper. Your customs authority will not provide you with the lower rate. You must supply the evidence.

Know your TWI. Document your shipments. Keep your savings.