Yongguan Classification Class | Brief Analysis of Fat-based Health Food Classification

 

 

Fat-based health foods are highly favored by consumers for their unique nutritional value and are often referred to as "liquid gold." With the global rise in health-conscious consumption, these products have become increasingly diverse, offering a growing variety of options. Below, we provide an overview of the customs classification of fat-based health foods.

Category I: Single-ingredient Products

01 Cod Liver Oil

Most individuals born during the 1980s and 1990s may remember consuming cod liver oil, recognized by its distinctive yellow hue and mild fishy taste. Sourced from the livers of fish, cod liver oil is abundant in vitamins A and D, effective in both preventing and managing conditions such as night blindness and pediatric rickets, making it a staple health supplement. Since the establishment of China's first cod liver oil manufacturing plant in 1950, this supplement has become a common household item and a memorable part of childhood for many in the nation.

Cod liver oil is a specifically listed item in the tariff schedule. In accordance with General Classification Rules I and VI, cod liver oil should be classified under the tariff line 1504.1000.

 

 

 

 

02 Fish Oil

While fish oil and cod liver oil share similar names, their compositions are distinctly different. Fish oil is derived from the fat of fish, with its primary components being Omega-3 fatty acids. Omega-3 refers to a group of polyunsaturated fatty acids. The two most representative components are eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA), which offer numerous health benefits such as vasodilation, inhibition of blood clotting, and enhancement of brain cell development.

Fish oil is a specifically listed item in the tariff schedule. In accordance with General Classification Rules I and VI, fish oil should be classified under the tariff line 1504.2000.

 

 

 

 

03 Algal Oil

Algal oil is a concentrated lipid extracted from marine algae species such as Crypthecodinium cohnii, Schizochytrium, and Ulkenia. Unlike fish oil, which is abundant in both EPA and DHA with a typically higher EPA content, algal oil primarily contains DHA, which is beneficial to human health.

In accordance with General Classification Rules I and VI, algae oil should be classified under the tariff line 1515.6000 as microbial oils, fats, and their derivatives.

 

 

 

 

 

04 Krill Oil

Krill oil is primarily extracted from Antarctic krill and contains EPA and DHA, though their concentrations are generally lower than in fish oil. Moreover, krill oil includes astaxanthin, which also offers significant health benefits.

In accordance with General Classification Rules I and VI, krill oil should be classified under the tariff line 1506.0000 as other animal oils, fats, and their derivatives.

 

 

 

 

For various single-ingredient products classified under Chapter 15 of Tariff Rules, such as those under tariffs 15.04, 15.06, and 15.15, based on the classification decision J2006-0003 issued by GACC, trace amounts of antioxidants, stabilizers, and other substances may be added for safety or preservation purposes. However, the substances added must not alter the general intended use of the product.

II. Mixed-ingredient Products

(I) Commodities under Heading 15.17

Besides the aforementioned single-ingredient fat-based products, mixed oil and fat products are also quite common. In line with the notes under Heading 15.17, mixtures of animal, vegetable, or microbial fats and oils should be classified accordingly. These mixtures may include minor additions of colorants, fragrances, vitamins, and similar substances.

As an example, the "Bonabidicici DHA Beverage," discussed in the GACC Classification Decision No. Z2022-0010, comprises primarily sunflower oil, DHA algal oil, and wheat germ oil. Small amounts of lemon and orange juice are incorporated for flavor adjustment.

Given that this product is a mixed fat-based product, the minor inclusion of flavoring agents does not alter its fundamental property. Accordingly, according to General Classification Rules I and VI, it must be categorized as a mixed fat-based product under tariff line 1517.9090.

(II) Commodities under Other Headings

In general, mixed fat-based products should be primarily classified under Heading No.15.17. Since Heading 15.17 specifies the substances that can be added, if the additives exceed the scope permitted under Heading 15.17, consideration should be given to other headings. For example, a certain brand's "Algal Oil DHA Capsules" contains the following main ingredients in the capsule contents: 63% algal oil, 15% medium-chain triglycerides, 9% sweet orange oil, 3%nervonic acid, and so on. As the ingredients "nervonic acid" and "sweet orange oil" exceed the allowed range of goods that can be added under Heading 15.17, they cannot be classified as mixed fat-based products under this heading anymore. In accordance with General Classification Rules I and VI, this product should be classified under tariff line 2106.9090 as an unclassified food item not listed under other headings.

Furthermore, some products, although containing a single type of fat, may have complex added substances. In such cases, consideration should be given to classifying them under chapters other than Chapter 15. Taking a certain brand's "Fish Oil Gummies" as an example, they appear as soft candies, with the following main ingredients: 33% fish oil, 27% xylitol, 18% water, 12% sorbitol, 7% gelatin, and so on. It is important to note that the sweetness of the product does not come from real sugar, but from the synthetic sweetener xylitol. The substances added to this product exceed the scope permitted under Chapter 15. Additionally, according to the exclusion clause of Heading 17.04, this "sugar-free" fish oil gummy does not fall under the definition of sugar confectionery in 17.04. Therefore, in accordance with General Classification Rules 1 and 6, this product should be classified under tariff line 2106.9090 as an unclassified food item not listed under other headings.

 

 

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Disclaimer：The above content is translated from Chinese version of Alayongguan. The Alayongguan version shall prevail.