HS Code for Frozen fish roe

Frozen fish roe is classified under HS code 0303.91. This classification is governed by the General Interpretative Rules (GIR) 1 and 6, which prioritize the terms of the headings and subheadings. Heading 0303 covers fish, frozen, excluding fish fillets and other fish meat of heading 0304. Within this heading, the 0303.9x series is reserved for edible fish offal. Specifically, 0303.91 is designated for livers, roes, and milt. The product must be in a frozen state and must not have undergone further processing such as smoking, salting, or being prepared as caviar. If the roe is simply extracted from the fish and frozen to maintain freshness for transport or future processing, it remains within this primary commodity code. The classification is strictly based on the preservation method (freezing) and the anatomical part of the fish (roe/offal).

Products Included

• Frozen salmon roe (sujiko or ikura)
• Frozen herring roe
• Frozen cod roe
• Frozen pollock roe (mentaiko base)
• Frozen fish milt (shirako)
• Frozen sturgeon roe (not prepared as caviar)

Common Misclassification

The most frequent misclassification occurs with HS codes 1604.31 and 1604.32. These codes are reserved for caviar and caviar substitutes. If the fish roe has been seasoned, salted, or prepared for immediate consumption as a delicacy, it must be moved to Chapter 16. Another common error is using 0302.91, which is specifically for fresh or chilled fish roe. Importers must distinguish between the chilled state (0302) and the frozen state (0303) to ensure compliance. Additionally, if the roe is still inside the whole fish, the entire fish is classified under the specific species code in 0303, rather than the roe code.

FAQ

What is the HS code for frozen fish roe?

The primary HS code for frozen fish roe, livers, and milt is 0303.91.

How does 0303.91 differ from 1604.31?

HS code 0303.91 is for raw, frozen roe intended for further processing or cooking. HS code 1604.31 is for prepared caviar (typically sturgeon) that has been salted or preserved for direct consumption.