HS Code Classification Guide for Various Fish Oils: Refined (TG), Re-esterified, Mixed, and Ethyl-esterified (EE) Released

The classification of fish oils in the Harmonized System (HS) depends heavily on the processing methods and resulting changes in chemical structure. This follows the general classification principles of Chapter 15 (Animal or vegetable fats and oils and their cleavage products; prepared edible fats; animal or vegetable waxes) and the degree of processing. Below is a detailed breakdown of the classification for each type of fish oil.

1. Refined Fish Oil (Triglyceride - TG Form)

Refined fish oil refers to products that have undergone purification processes such as degumming, deacidification, bleaching, and deodorization while maintaining the original Triglyceride (TG) structure found in fish. Since these processes do not alter the fundamental chemical structure of the oil, it is classified under HS Subheading 1504.20.

• Classification Principle: HS 1504.20 covers "Fats and oils and their fractions, of fish, other than liver oils (whether or not refined, but not chemically modified)."
• HS Code: Refined TG fish oil derived from a single species is typically classified under 1504.20-0000.
• Key Point: Simple refining increases purity but does not change the glycerol ester backbone, meaning it is not considered "chemically modified" for the purposes of this heading.

2. Re-esterified Fish Oil

Re-esterified fish oil is produced by hydrolyzing the original triglycerides to separate fatty acids and then re-bonding (esterifying) them with glycerol to achieve a specific fatty acid composition or position. This process involves significant chemical structural changes and is categorized as chemical modification beyond simple refining.

• Classification Principle: HS Heading 1516 covers "Animal or vegetable fats and oils and their fractions, partly or wholly hydrogenated, inter-esterified, re-esterified or elaidinized, whether or not refined, but not further prepared."
• HS Code: Re-esterified fish oil from a single species is classified under 1516.10-9000.
• Key Point: This heading encompasses oils where the fatty acids have been rearranged or structurally modified through chemical treatment.

3. Mixed Fish Oil

Mixed fish oil refers to products created by blending two or more types of fish oils, or mixing fish oil with other animal or vegetable fats. These mixtures are viewed as 'mixtures or preparations' formulated for specific nutritional or functional purposes.

• Classification Principle: HS Heading 1517 covers "Edible mixtures or preparations of animal or vegetable fats or oils or of fractions of different fats or oils of this Chapter."
• HS Code: Mixed fish oils intended for edible use are generally classified under 1517.90-9000.
• Key Point: This heading applies to composite products rather than single-source oils.

4. Ethyl-esterified Fish Oil (EE Form)

Ethyl-esterified (EE) fish oil is produced by hydrolyzing the triglyceride structure and then esterifying the resulting fatty acids with ethanol instead of glycerol. This results in fatty acid ethyl esters, which possess a completely different chemical structure from natural fats.

• Classification Principle: Chapter 15 defines fats and oils primarily as "glycerol esters of fatty acids." Since ethyl esters do not meet this definition, they are excluded from Chapter 15. Instead, they are treated as food preparations used to supplement specific nutrients.
• HS Code: EE fish oil is classified under HS Subheading 2106.90-9099 as "Food preparations not elsewhere specified or included."
• Key Point: This classification is used because the chemical modification is so extensive that the product loses the essential character of a Chapter 15 oil and becomes a functional food preparation.

Conclusion

In summary, the classification of fish oil is determined by the final chemical structure and the processing steps involved rather than the raw material alone.

• Refined TG form (Natural structure): Heading 1504
• Re-esterified TG form (Chemically rearranged): Heading 1516
• Mixed preparations (Blended oils): Heading 1517
• Ethyl-ester form (Ethanol bond): Heading 2106

To ensure accurate classification, it is essential to provide detailed manufacturing process descriptions and technical ingredient analysis reports during the customs declaration process.