HS Code for Fish roe substitute

Fish roe substitutes are classified under HS code 1604.32. This classification is governed by the specific structure of heading 1604, which distinguishes between prepared fish, caviar, and caviar substitutes. While caviar itself (the roe of the sturgeon) is classified under 1604.31, all other prepared fish eggs intended for consumption as a caviar alternative fall under 1604.32. To qualify for this code, the roe must be prepared or preserved—typically through salting, drying, smoking, or the addition of flavorings and colorants. The Harmonized System Explanatory Notes clarify that caviar substitutes are products consumed like caviar but prepared from the eggs of fish other than sturgeon (e.g., salmon, carp, pike, tuna, or lumpfish). These products are often washed, cleaned of adherent organs, salted, and sometimes pressed or dried. The classification is based on the biological origin of the eggs and the subsequent processing that makes them a prepared foodstuff rather than a raw agricultural product.

Products Included

• Lumpfish roe (dyed and salted)
• Salmon roe (Ikura), prepared or preserved
• Capelin roe (Masago), seasoned
• Flying fish roe (Tobiko), processed
• Cod roe, salted or smoked
• Pollock roe, prepared

Common Misclassification

A common misclassification occurs with HS code 1604.31, which is strictly reserved for caviar obtained from the sturgeon species. Importers often confuse the two when dealing with high-end roe. Additionally, raw or simply frozen fish roe should be classified in Chapter 3 (e.g., 0302.91, 0303.91, or 0305.20) depending on its state. If the roe is not prepared (i.e., only chilled or frozen), it does not belong in 1604.32. Furthermore, 'vegan caviar' made from seaweed or algae is classified under 2106.90 as a food preparation not elsewhere specified.

FAQ

What is the HS code for fish roe substitute?

The HS code for fish roe substitute is 1604.32, which specifically covers caviar substitutes prepared from fish eggs.

Is salmon roe considered a caviar substitute?

Yes, for HS classification purposes, salmon roe is classified as a caviar substitute under 1604.32 because it is not derived from sturgeon.