Product classification
HS code for Frozen fish roe: 0303.91
Fish, frozen, livers, roes and milt.
Classification of frozen fish roe under HS 0303.91
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).
- Covers
- 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)
- 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. 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.
Top exporters and importers of HS 030391 (the code used for frozen fish roe), 2025
In 2025, the largest exporter of HS 030391 (the code used for frozen fish roe) 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 roe.
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 roe
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 roe
What is the HS code for Frozen fish roe?
The HS code for Frozen fish roe is 030391 (Fish; frozen, livers, roes and milt). The primary HS code for frozen fish roe, livers, and milt is 0303.91.
How do I classify Frozen fish roe for customs?
Frozen fish roe is classified under HS code 030391 — Fish; frozen, livers, roes and milt. This is a 6-digit subheading level code.
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.
Which countries are the top exporters of frozen fish roe (HS 030391)?
In 2025, the top exporters of HS 030391 (the code used for frozen fish roe) 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 roe (HS 030391)?
In 2025, the top importers of HS 030391 (the code used for frozen fish roe) 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 roe the same in all countries?
The base HS code 030391 for Frozen fish roe 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 roe in Brazil?
Brazil splits HS 030391 into 2 NCM codes, so the right one for frozen fish roe depends on the product's details: 0303.91.10 (Frozen mullet roe), 0303.91.90 (Other frozen fish livers, roes and milt).