Product classification
HS code for TOFA: 3823.13
Industrial monocarboxylic fatty acids, acid oils from refining, tall oil fatty acids.
Classification of TOFA under HS 3823.13
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.
- Covers
- 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
- Also under 3823.13
- Kraton TOFA
- Forchem TOFA
- Georgia-Pacific TOFA
- Respol Resins TOFA
- DRT TOFA
Codes often confused with 3823.13
Common mistake. 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.
Top exporters and importers of HS 382313 (the code used for TOFA), 2025
In 2025, the largest exporter of HS 382313 (the code used for TOFA) in UN Comtrade data was Sweden, with 28% of world exports; the largest importer in UN Comtrade data was the Netherlands, with 14% 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 382313, not only TOFA.
Top exporters 2025 · share of world exports
- 1 Sweden $64M 28% of world exports
- 2 Netherlands $59M 26% of world exports
- 3 United States $53M 23% of world exports
World total: $227M Reported figures on UN Comtrade ↗
Top importers 2025 · share of world imports
- 1 Netherlands $47M 14% of world imports
- 2 Sweden $34M 9.8% of world imports
- 3 Saudi Arabia $20M 5.9% of world imports
World total: $344M 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 that did not report are estimated from what other countries recorded trading with them. 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. 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 code for TOFA
Brazil classifies TOFA under NCM 3823.13.00: HS 3823.13 with 00 added.
Source: Siscomex NCM table, updated Oct 2026. The Portuguese text on each NCM page is the official one.
EU Regulatory Requirements
This product category is subject to the EU Deforestation Regulation (EUDR). Importers must provide due diligence statements proving the product was not produced on deforested land after December 31, 2020.
Questions about TOFA
What is the HS code for TOFA?
The HS code for TOFA is 382313 (Industrial monocarboxylic fatty acids, acid oils from refining; tall oil fatty acids). The HS code for Tall Oil Fatty Acids is 3823.13. This applies to products with low rosin content (typically less than 2%).
How do I classify TOFA for customs?
TOFA is classified under HS code 382313 — Industrial monocarboxylic fatty acids, acid oils from refining; tall oil fatty acids. This is a 6-digit subheading level code.
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.
Which countries are the top exporters of TOFA (HS 382313)?
In 2025, the top exporters of HS 382313 (the code used for TOFA) in UN Comtrade data were Sweden ($64M, 28% of world exports), the Netherlands ($59M) and the United States ($53M). World exports came to about $227M, 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 TOFA (HS 382313)?
In 2025, the top importers of HS 382313 (the code used for TOFA) in UN Comtrade data were the Netherlands ($47M, 14% of world imports), Sweden ($34M) and Saudi Arabia ($20M). World imports came to about $344M, 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 TOFA the same in all countries?
The base HS code 382313 for TOFA 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 TOFA in Brazil?
In Brazil, TOFA (HS 382313) is classified under NCM 3823.13.00.