WORLD TRADE
ORGANIZATIONG/RO/W/87
25 June 2002
(02-3527)
Committee on Rules of Origin Original:  English
CHAPTERS 1-24 (AGRICULTURAL PRODUCTS AND FISH)
Submission by Korea
The following communication, dated 20 June 2002, has been received from the Permanent
Mission of Korea.
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Comparative review on soju and vodka in association with
rule of origin issue of the heading 2208.90
(Issue No. 104)
Background
1. At the meeting of the Committee on Rules of Origin (CRO) in December 2002, Korea
proposed to create a new split subheading specifying Soju, a distinctive alcoholic beverage mainly
produced in Korea and Japan, in order to eliminate the ambiguity of description of goods arisen from
chairman’s recommendation under the heading 2208.90.  Korea showed keen interest on this issue
and highlighted the rational creation of a new split subheading for Soju in collaboration with Japan at
the CRO’s meeting in April 2002. As to Korea’s proposal, U.S delegation stated that Soju and Vodkaseem to have some similarities in the composition and more specific information on Soju would be
required. In this context, Korea would like to pr esent detailed information and our views in light of
history, materials, characteristics, manufacturing process and so on about Soju as well as the
differences between Soju and Vodka.
The point at issue on the classification
2. Korea has classified Soju as other spirits under the heading 2208.90 since adopting the
International Convention on the Harmonized Commodity  Description and Coding System (HS) which
has come into effect on and after Jan 1, 1988. There is no doubt that Vodka is classified in the
subheading 2208.60 as single category of spirits in accordance with the HS system.
3. In a glance, Soju might be considered as Vodka since there are some similarities between
both in the respect of materials, manufacturing process and appearance. Both of them are also
categorized as spirits. From this point of view, this paper will focus on how different Soju and Vodka
are. In case Soju is not different from Vodka, it should be reclassified in the heading 2208.60 from the
heading 2208.90 which Korea has been applying so far. The following table shows the current
classification structure under the heading 2208.G/RO/W/87
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Classification structure of the heading 2208
HS Code Description of goodsOrigin Criteria
(Chairman’s
recommendation)
2208 Undenatured ethyl alcohol of an alcoholic strength
by volume of less than 80%; spirits, liqueurs and
other spirituous, beverages
2208.20 Spirits obtained by distilling grape wine or grape
marcCTH
2208.30 Whiskies CTH
2208.40 Rum and tafia CTH
2208.50 Gin and geneva CTH
2208.60 Vodka CTH
2208.70 Liqueurs and cordials CTH
2208.90 Other
2208.90 (a) Undenatured ethyl alcohol of an alcoholic
strength by volume of less than 80% vol.CTH except from heading
2207
2208.90 (b) Kirschwasser and ratafia CTH
2208.90 (c) Other CTH except by  dilution
only and except from2106.90
NOTE : Subheading 2208.90(a),(b) and (c) are not part of HS code but newly created splitsubheadings for the purpose of rule of origin under the CRO’s chairman’s recommendation.
History of Soju
4. Soju means that it is made by burning something and it is categorized as  spirits.  Soju is
defined as an alcoholic beverage, made from starch of grains, through the process followed by
saccharification and fermentation with mold and yeast, distillation and mixture with various additives.It was introduced to Korea from Mongols in the late 13
th century during the time of Koryo dynasty of
Korea. It was known that the origin of traditional Soju would be traced back to Persia, where might be
considered as the cradle to develop distillation technology of Soju, It had been exceedingly loved by
the kings and nobels at those period. But today, Soju is very popular among general public, as it is
produced massively and cheaply by dozens of factories in Korea. It can be seen easily that ordinarypeople drink Soju at a restaurant and at home after work or during the weekend.G/RO/W/87
Page 3
5. The category of Soju is divided into the sub-categories of “ distilled-soju”  produced by the
traditional production process, and “diluted-soju” produced by the modernized and advanced process.
At one time, Korean government had banned production of distilled-soju in an effort to resolve food
problem from 1965 to 1991. Instead, diluted-soju made of neutral ethyl alcohol, which obtained from
cheap imported tapioca or molasses has been allowed to produce since 1965. As a result, diluted-sojureaches to over 99 percent of total soju production in Korea, while distilled-soju occupies extremely
tiny portion of only 0.39 percent in 2000. Accordingly, most of Soju in domestic and foreign markets
refers, at present, to diluted-soju. Distilled-soju is usually selling at the price of 6-7 times of diluted-
soju in the markets. Sales amount of Soju in Korea is presented in the Table 2.
Sales amount of Soju in Korea
(Unit: in million of Korean Won)
Sales Amount
Type
1997 1998 1999 2000
Diluted-soju 1,183,412 1,386,312 1,602,134 1,678,658
Distilled-soju 7,696 5,197 4,730 6,553
Total 1,191,108 1,391,509 1,606,804 1,685,211
Source : Korea Tax Administration (2001)
Features and Manufacturing Process of Soju
Distilled Soju
6. Traditionally it was distilled in a pot still which collected evaporation, thus it is sometimes
called “dew wine”. Today, it is not much different from the old production process. It is produced by
distilling fermented grains such as rice or barley by the use of pot still and filtering then blending withother ethyl alcohol obtained from grains or mixing w ith specific additives to give its own flavours.  In
order to harmonize quality and soften aroma, it is often stored in the wooden container.
7. The alcoholic strength of distilled-soju is generally ranging from 35% to 45%.  Depending on
a variety of materials which give it unique flavors, a number of Korean traditional folk liquors are
produced, for example Mepssal-soju (non-glutinous rice), Chapssal-soju (glutinous rice), Bori-soju(barley), Mil-soju (wheat), Noju (mixture of non-glutinous rice and glutinous rice), Samhae-ju
(mixture of ginger and honey), Yak-soju (mixture with medicinal stuffs). It retains peculiar flavor and
aromas as it is distilled by pot still that keeps flavor of raw materials intact as much as possible. It also
contains the secondary constituents such as aldehydes, fusel oil other than alcoholic.
8. Typical production process of distilled-soju is presented in the Figure 1.
Production Process of Distilled Soju
Materials Saccharification
FermentationDistillation Store
Maturation
Bottling Mixture Purification
FiltrationG/RO/W/87
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Main materials are cereal grains such as rice, barley and wheat.  To have raw materials be saccharified
and fermented, mold and yeast are used. After then, it is distilled by pot still and stored to be matured
in the wooden container. By removing impurities through the caborn filtering and purification process
and then by mixing with additives such as glucose, acid, aromatic and flavouring which needs to
apply special know-how, it is to be bottled for a final process.
Diluted Soju
9. Diluted-soju is made of neutral ethyl alcohol (called Joojung in Korean) of an alcoholic
strength of 95% by volume or higher, which is drawn from fermented sweet potatoes, tapioca and
distilled so as to obtain as pure alcohol as possible. Joongjung is the alcohol which occurs in beer,
wine, cider and other alcoholic beverages. It is obtained by fermentation of certain kind of sugars by
means of yeast or other ferments and continuous distillation.
10.   To produce diluted-soju, that ethyl alcohol is not further distilled, but it is purified and
diluted with water, and various additives are mixed. The process of dilution and addition is required
highly sophisticated technology in order to adjust alcoholic strength fitting to customer’s preference
and to produce its own peculiar flavour. This drink has a relatively low alcoholic strength ranging
from 20-25% compared with the distilled-soju and has light, bitter, sour and sweet taste stemmed
from additives.
11. Production process of diluted-soju is shown in Figure 2.
Production process of diluted Soju
1. 
2. 
3. 
4. 
5. 
6. 
7. 
8. 
At the first stage, raw material, ethyl alcohol is diluted with water up to not more than 45% by
volume. Then, the activated carbon is input for deodorization as well as removal the impurities such
as methanol, fusel oils and a number of other chemical compounds. Next process is to mix various
additives with first diluted alcohol based on the most highly sophisticated technology and know-how
that are strictly kept in the form of top secret of companies. In the process of blending, water is addedand by filtration with cotton or filtering paper at least three times, the quality of Soju is harmonized
and the taste is refined. It is finally bottled for the commercial products. Major ingredients to be
mixed into diluted Soju are as follows:
/g108 95% of ethyl alcoholEthyl
alcoholDilution Deodorization Mixture
BlendingWater Additives
Filtration BottlingG/RO/W/87
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/g108 quality water
/g108 sweeteners:  stevioside, oligoes, high fructose, aspartame, etc.
/g108 citric acid for sour taste
/g108 amino acid:  to harmonize the quality of Soju
/g108 salt in powder
/g108 activated carbon : fine filtration in power or granule
Overview of vodka
12. Vodka is a neutral spirits, usually obtained by distilling fermented mash of cereal grains
(barley, oats, rye, etc.) or potatoes. Vodka was created sometime in the 12th century, probably in
Russia, possibly Poland, based on the distillation technology, which might be originated in Persia.
Starting out as a crude, rye-based spirit used for medical purposes, vodka was known in Russian aszhiznennia Vodka. From the beginning of the 17th century it had become customary for Vodka to be
served at Russian imperial banquets. All formal meals began with bread and Vodka. Vodka was also
drunk ceremonially at religious festivals and in church ritual. By the 18th century, vodka was being
distilled from barley, maize or, more popularly, potatoes throughout the Russian Empire. The West,
however, was slow to appreciate vodka. In the USA, production of vodka started in 1934, under theguidance of a Russian who had learned the secrets of its distilling from the Smirnoff family, who had
been the exclusive suppliers of vodka to the Czar. Since 1940, vodka has been produced not only in
Russia and Poland but also in England, France and so on.   
13. Vodka is defined as a spirits without any distinctive character, aroma, taste or color. The
alcoholic strength of Vodka is generally ranging from 40% to 60%. It is widely used for main
component of cocktails, as it is colourless, odourless, tasteless and well harmonized with other
alcoholic drinks.
14. The typical production process is fermented, distilled, filtered, diluted and bottled just like
distilled-soju process. Vodka is essentially non-aged neutral spirits that can be distilled from just
about anything fermentable. Although the legendary potato is used in the production of some vodka,
most of brands today are made from grains such  as rye, wheat, barley and corn. As regards
saccharification process, it is saccharified by means of malt unlike Soju which mold is used. It is
characterized by continuous filtration with white birch charcoal and it is stored in the stainless
container without retaining color, aroma and taste.
Differences between Soju and Vodka
Distilled Soju and Vodka
15. Some similarities exist between distilled-soju and Vodka as both are classified into spirits and
produced through fermentation, distillation and filtration process. There are, however, differences in
terms of materials, saccharification, additives and filtration process.
16. Main raw materials of distilled-soju are rice, barley or wheat which are widely cultivated in
Asian countries, and at the same time, mould and yeast should be used for the process ofsaccharification and fermentation. In contrast, main materials of Vodka are rye, potato etc., which can
be easily obtained in the place of production, and in particular, malt should be used for
saccharification process of Vodka. In the process of distillation, di stilled-soju is dis tilled by the use of
pot still to keep natural flavour of raw materials as much as possible, while Vodka is distilled by
patent still and then filtered by white birch charcoal. In addition, in order to harmonize and enhancequality, distilled-soju is mixed with some additives such as sweetening, acid, seasoning and often by
blending with other grain spirits, while such a mixture are hardly proceed for Vodka in order toG/RO/W/87
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maintain its own characteristics without color, tastes and aroma. On the other hand, The alcoholic
strength of distilled-soju is generally ranging from 35% to 45%, in Japan, legally less than 45%, while
that of vodka is over 40% in the USA.
Diluted Soju and Vodka
17. Other than diluted-soju and vodka are classified into spirits, there are also some similarities in
that both are distilled by using patent still and then diluted with water to adjust alcoholicity. There are,
however, also differences in various aspects betwee n them in the process of fermentation, mixtures,
filtration, alcoholicity, flavouring and main use.
18. Like distilled-soju, in the basic process of producing neutral ethyl alcohol, yeast and mould
should be used for fermentation and in the process of dilution, various kinds of ingredients are added
to bear unique taste. In contrast, Vodka needs malt instead of yeast and few additives to keep its ownnon-taste character. The alcoholicity of diluted-soju is relatively low ranging from 20% to 25%,
legally less than 35% in Japan, which is fitted for customary preference of Asian people, while that of
vodka is more than 40%. On the other hand, U.S Code of Federation Regulation(CFR) defines the
alcoholic strength of vodka, if bottled, is not less than 80 deg. Proof, which is equivalent to 40 %
1.
19. Vodka is normally used for main component of cocktail, while diluted-soju is not suitable for
cocktail use as it contains low alcoholicity as well as food additives. In particular, Korean Alcohol
Law specifies that those spirits produced by using malt and by filtering with white birch charcoal
should not be classified into Soju.
20. Table 2 presents a brief comparison of Soju and Vodka.
Comparison of Soju and Vodka
Soju
Diluted Type Distilled TypeVodka
MaterialsEthyl alcohol
produced from
tapioca, sweet potatoRice, barley Rye, wheat, potato
Saccharification Mold Mold Malt
Additives Need Need Barely need
Still Patent still Pot still Patent still
MaturationStainless container/
Wooden containerWooden container Stainless container
PROCESS
Filtration Cotton or charcoal Cotton or paper White birch charcoal
Alcoholic content 20-30% 35-45% 40-60%
                                                     
1 Title 27 of CFR, Chapter 1, Part 5, Section 5.22.G/RO/W/87
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Soju
Diluted Type Distilled TypeVodka
Taste Taste Taste Tasteless, colourless
Production areaAsian countries
(Korea, Japan, China)Western countries
(Russia, Poland,
USA, France etc.)
Conclusions
21. It is widely believed that the distilled method of  spirits had been originated in Persia in the
first place. During the crusades since 11th century, it had been spread over Europe, resulting in
development of brandy and whiskey in Western Euro pe as well as Vodka in Eastern Europe, being
adapted to their culture and customary preference. On the other hand, it had been also spread over
Eastern Asian countries, ultimately Korea and Japan, resulting in development of Soju, by the effect
of Mongol’s presence in Western Asia or by the influence of Islamic culture around 12th century,
being adapted to their own culture. Accordingly, even if the origin of distilled spirits may have taken
place in one area, a variety of spirits had been adapted and modified in association with peculiar
culture and preference retained in each area.
22. In conclusion, the alcoholic drinks are closely associated with culture, tradition background,
customary preference of drinks and the way of life in the production region. From this point of view,
the origin of Soju and Vodka is quite different historically and geographically even if they areclassified into same category of spirits and they also use similar sorts of raw grain materials. Several
differences between them exist in the process of fermentation, distillation, mixture and filtration,
which differentiate them from various similarities they have. Moreover, tastes and main use, which
have long been adapted to people’s customary preference within similar cultural area, are also quite
different. Accordingly, Soju and Vodka should not be considered or treated, as the same category ofspirits, or rather should be respected with their own cultural and traditional background.
23. In fact, even though alcoholic beverages such as brandy (made of grape), whiskey, rum and
tapia, gin and geneva, and vodka are falling on the same sort of sprits, under the HS classification
structure of the heading 2208, they are classified sepa rately as shown in table 1. In this respect, it is
reasonable that Soju should be differentiated from the other spirits enumerated above, as there are
various differences in terms of main materials, manufacturing technology and characteristics. Thus,
Soju as one of distinctive Asian originated spirits should be classified into the heading 2208.90. Fromthis point, Korea has classified soju as other sprits into the heading 2208.90 since Jan 1
st, 1988 after
adopting HS convention in 1987.
24. Finally, Korea would like to remind Members that, considering the significance and
importance of Soju as a rapidly emerging global Asian alcoholic drink, the new split subheading
covering Soju is necessary to be created for origin purpose with CTH rule. This is corresponding tothe reason what Kirschwasser and Ratafia have been suggested to create a new split subheading,
2208.90 (b).G/RO/W/87
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APPENDIX
Supplement of Korea Proposal
Background of proposal
1. It is pointed out that the chairman’s recommendation on the split subheading 2208.90 doesn’t
provide a clear instruction necessary to determine the origin of Soju in terms of classification. Main
arguments arisen from chairman’s recommendation are: first, there are no definitions or differences
between ex-2208.90 (a) and ex-2208.90 (c) as it doesn’t give detailed description of both split
subheadings. Second, there is no apparent logical background ex-2208.90 (b) describing
“Kirschwasser and Ratafia” as well as conferring separate rule of origin from ex-2208.90(a) and ex-
2208.90(c).
2. Based on the review of ambiguity stemmed from chairman’s recommendation, Korea
proposed that new split subheading for Soju be created for the purpose of clarification of applying the
rule of origin, that is, CTH rule. However, Korea’s proposal does not intend to change the result of
chairman’s recommendation since it describes “ ex-2208.90 (c) as CTH except by dilution only and
except from 2106.90 ” for the origin criterion. As explained, Soju is not produced by mere dilution
only but by complex dilution mixed with various additives based on sophisticated production know-how.
3. Our proposal is, therefore, intended to complement chairman’s recommendation so as to
eliminate the ambiguity in the application of rule of  origin. In addition, with its significance in trade
volume and importance in the global markets, Soju should be treated as a separate split subheading,
equivalent to Kirwasser and Ratafia, ones of west ern spirits, which are suggested as ex-2208.90(b) of
the chairman’s recommendation.G/RO/W/87
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Korea Proposal on Revision of Chairman’s Recommendation
(Issue No. 104)
Chairman’s Recommendation Korea Proposal
HS Code
No.Description
of goodsOrigin
CriteriaHS CodeDescription
of goodsOrigin
Criteria
-ex
2208.90(a)Undenatured
ethyl alcohol of
an alcoholic
strength by
volume of less
than 80% vol.CTH, except
from 2207-ex
2208.90(a)Undenatured
ethyl alcohol of
an alcoholic
strength by
volume of less
than 80% vol.CTH, except
from 2207
-ex2208.90(b)Kirschwasser
and ratafiaCTH -ex
2208.90(b)Kirschwasser
and ratafiaCTH
-ex
2208.90(c)Other CTH, except
by dilution
only or
except from
2106.90-ex
2208.90(c)(ii) Soju or
Shochu(iii) CTH
-ex
2208.90(d)Other CTH, except
by dilution
only or
except from
2106.90
The export volume of Korean diluted-Soju by countries
(Unit: US$ thousand)
2000 2001 Increase Rate (%)
Japan 82,937 87,261 5.21
USA 3,384 4,165 23.08
China 430 537 24.88
Australia 127 259 103.94
Canada 131 138 5.34
Singapore 65 136 109.23
Indonesia 89 132 48.31
Other countries 696 881 26.72
Total 87,859(0) 93,509(3) 6.43
Source : Korea Customs Service, 2002G/RO/W/87
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NOTE: the numbers in bracket in the row of TOTAL refer to export amount of distilled-soju. As it is
insignificant amount, it is included in the export amount of diluted-soju.
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