Product classification
HS code for Frozen fish milt: 0303.91
Fish, frozen, livers, roes and milt.
Classification of frozen fish milt under HS 0303.91
Frozen fish milt, also known as soft roe, is classified under HS code 030391. This classification is part of the broader Chapter 3 of the Harmonized System, which encompasses fish and aquatic invertebrates. Heading 0303 specifically addresses frozen fish. Within this heading, the subheading 030391 is designated for livers, roes, and milt. The classification logic follows the General Rules for the Interpretation (GRI) of the Harmonized System, identifying the product first by its biological origin (fish), then by its preservation state (frozen), and finally by its specific edible part (milt). This code ensures that reproductive organs used as food are distinguished from standard muscle meat or other offal types like heads or tails. Because milt is often considered a delicacy in various cuisines, its specific classification helps customs authorities monitor trade volumes and apply appropriate tariffs based on its unique market value compared to other fish parts.
- Covers
- Frozen herring milt
- Frozen mackerel milt
- Frozen cod milt (shirako)
- Frozen salmon milt
- Frozen pufferfish milt
- Also under 0303.91
- Frozen Norwegian Cod Roe
- Frozen Ikura (salmon roe)
- Frozen Tobiko (flying fish roe)
- Frozen Masago (capelin roe)
- Frozen Lumpfish Roe
Codes often confused with 0303.91
Common mistake. A common misclassification occurs with HS code 030399, which covers other edible fish offal. While milt is technically offal, the HS system provides a more specific code (030391) that takes precedence. Another error involves HS code 051191, which is used for products of fish or crustaceans that are unfit for human consumption. If the milt is intended for bait or industrial use rather than food, it may be moved to Chapter 5. Finally, fresh or chilled milt must be classified under 030291 rather than 030391.
Top exporters and importers of HS 030391 (the code used for frozen fish milt), 2025
In 2025, the largest exporter of HS 030391 (the code used for frozen fish milt) in UN Comtrade data was the United States, with 43% of world exports; the largest importer in UN Comtrade data was Japan, with 54% of world imports. Countries that did not report 2025 data are estimated from partner records, which can understate them.
Figures cover everything classified under HS 030391, not only frozen fish milt.
Top exporters 2025 · share of world exports
- 1 United States $535M 43% of world exports
- 2 Russia* ~$272M 22% of world exports · partner records ↗
- 3 China $79M 6.3% of world exports
World total: $1.2B Reported figures on UN Comtrade ↗
Top importers 2025 · share of world imports
- 1 Japan $652M 54% of world imports
- 2 China $129M 11% of world imports
- 3 Taiwan* ~$102M 8.6% of world imports · partner records ↗
World total: $1.2B Reported figures on UN Comtrade ↗
How these figures are built
109 countries reported 2025 trade to UN Comtrade in HS 2022, and their own totals are used. Countries marked * did not, so their figures add up what other countries recorded trading with them, and their exports are valued at buyers' CIF prices. Those estimates miss trade with other non-reporting countries, so they can be low, and a non-reporting country can rank higher than shown or be missing from the list. World totals add both and leave out trade between two non-reporting countries. UN Comtrade records Taiwan as "Other Asia, not elsewhere specified". Saudi Arabia's exports under that code are left out: they are far too large to be trade with Taiwan, so mostly undisclosed partners. Figures are in current US dollars; reported imports are mostly valued CIF and exports FOB, and exports include re-exports. The UN Comtrade links show the underlying records; they can also list a few reporters left out here (regional groups and older HS editions).
Source: UN Comtrade (United Nations Statistics Division), 2025 annual data.
Brazil NCM codes for frozen fish milt
Brazil splits HS 0303.91 into 2 NCM codes. Pick the one that matches your product:
- 0303.91.10Frozen mullet roe
- 0303.91.90Other frozen fish livers, roes and milt
Source: Siscomex NCM table, updated Oct 2026. The Portuguese text on each NCM page is the official one.
Questions about frozen fish milt
What is the HS code for Frozen fish milt?
The HS code for Frozen fish milt is 030391 (Fish; frozen, livers, roes and milt). The HS code for frozen fish milt is 030391, which includes frozen livers, roes, and milt.
How do I classify Frozen fish milt for customs?
Frozen fish milt is classified under HS code 030391 — Fish; frozen, livers, roes and milt. This is a 6-digit subheading level code.
Is there a difference between roe and milt in HS classification?
No, both frozen roe (hard roe) and frozen milt (soft roe) are classified under the same subheading, 030391.
Which countries are the top exporters of frozen fish milt (HS 030391)?
In 2025, the top exporters of HS 030391 (the code used for frozen fish milt) in UN Comtrade data were the United States ($535M, 43% of world exports), Russia (about $272M) and China ($79M). World exports came to about $1.2B, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Countries that did not report 2025 data are estimated from partner records, which can understate them.
Which countries are the top importers of frozen fish milt (HS 030391)?
In 2025, the top importers of HS 030391 (the code used for frozen fish milt) in UN Comtrade data were Japan ($652M, 54% of world imports), China ($129M) and Taiwan (about $102M). World imports came to about $1.2B, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Countries that did not report 2025 data are estimated from partner records, which can understate them.
Is the HS code for Frozen fish milt the same in all countries?
The base HS code 030391 for Frozen fish milt is internationally standardized for the first 6 digits across 200+ countries. Individual countries may add additional digits for national tariff lines and specific classifications.
What is the NCM code for frozen fish milt in Brazil?
Brazil splits HS 030391 into 2 NCM codes, so the right one for frozen fish milt depends on the product's details: 0303.91.10 (Frozen mullet roe), 0303.91.90 (Other frozen fish livers, roes and milt).