HS Code for TOFA

Tall Oil Fatty Acids (TOFA) are classified under HS code 3823.13. This classification is governed by Chapter 38, which covers miscellaneous chemical products, and specifically heading 3823, which includes industrial monocarboxylic fatty acids and acid oils from refining. According to GIR 1, classification is determined by the heading text. Subheading 3823.13 is a specific provision for tall oil fatty acids. TOFA is a product of the fractional distillation of crude tall oil, which is a byproduct of the Kraft process of wood pulp manufacture. To be classified under 3823.13, the product must generally contain 90% or more by weight of fatty acids (calculated on the dry weight) and less than 2% rosin. If the rosin content is higher, the product may be classified as distilled tall oil under heading 3803. The distinction is critical as it separates the industrial fatty acid from the crude or semi-refined tall oil products. TOFA is primarily used in the production of alkyd resins, dimer acids, and oilfield chemicals, and its classification in 3823 reflects its status as a chemically processed industrial fatty acid rather than a simple vegetable oil.

Products Included

• Distilled Tall Oil Fatty Acids (TOFA)
• TOFA with fatty acid content > 90%
• Low-rosin tall oil fatty acids
• Industrial grade TOFA for resin manufacture
• Refined TOFA used in lubricants

Common Misclassification

The most frequent misclassification for TOFA is HS code 3803.00, which covers Tall Oil, whether or not refined. The Explanatory Notes clarify that 3803.00 covers crude tall oil and distilled tall oil containing more than 2% rosin. Once the rosin content is reduced below 2% through further distillation, it must be classified as TOFA in 3823.13. Another error is using 3823.19, the "other" category for industrial fatty acids, which is incorrect because TOFA has its own specific subheading. It should also not be confused with vegetable fatty acids in 1518.

FAQ

What is the HS code for TOFA?

The HS code for Tall Oil Fatty Acids is 3823.13. This applies to products with low rosin content (typically less than 2%).

What is the difference between HS 3803 and 3823.13?

HS 3803.00 is for crude or distilled tall oil with higher rosin content, while 3823.13 is specifically for the fatty acid fraction separated during distillation with very low rosin levels.