HS 230120 Flours, meals and pellets, of fish or of crustaceans, molluscs or other aquatic invertebrates

What products does HS 230120 cover?

This subheading covers flours, meals, and pellets derived from fish or from crustaceans, molluscs, or other aquatic invertebrates, which are primarily used as animal feed or as ingredients in animal feed formulations. These products are obtained by drying, grinding, and often pressing the raw materials to remove oils, resulting in a protein-rich meal. The WCO Harmonized System Explanatory Notes for Heading 2301 explicitly include these processed forms of aquatic animal matter, distinguishing them from fresh or chilled products. Official definitions from the USITC Harmonized Tariff Schedule (HTS) and the EU TARIC system align with this scope, encompassing products like fishmeal, shrimp meal, and krill meal, provided they are in the specified forms.

What falls outside HS 230120?

The following products are excluded from HS 230120: live, fresh, chilled, frozen, dried, salted, or in brine fish, crustaceans, molluscs, or other aquatic invertebrates, which are classified in Chapters 3 or 5. For instance, whole dried shrimp intended for human consumption would fall under Chapter 3, not Heading 2301. Similarly, fish waste or offal that has not been processed into flour, meal, or pellets, such as fish heads or guts, would typically be classified under HS 0511. Products specifically prepared for human consumption, even if derived from aquatic invertebrates (e.g., powdered clam extract for flavoring), are generally excluded and classified elsewhere, often in Chapter 16 or 21, depending on their preparation and intended use.

What are common classification mistakes for HS 230120?

A common error is misclassifying fish or crustacean products that are not in the form of flours, meals, or pellets. Importers sometimes incorrectly apply HS 230120 to dried whole fish or crustaceans, or to unprocessed fish waste, failing to recognize the specific processing requirement of "flours, meals and pellets." Another mistake involves products that contain fishmeal but are formulated as complete animal feeds, which are typically classified under HS 2309, as per General Interpretative Rule (GRI) 3(b) if the complete feed character is predominant. Furthermore, products intended for human consumption, even if in powdered form, are often erroneously placed here instead of their appropriate Chapter 16 or 21 headings, overlooking the primary use criterion.

How should importers classify products under HS 230120?

The correct procedure for classifying products under HS 230120 involves first confirming the raw material (fish, crustaceans, molluscs, or other aquatic invertebrates) and then verifying the form of the product: flour, meal, or pellets. Importers and customs brokers should meticulously review product specifications, manufacturing processes, and intended use. Obtain detailed product descriptions, ingredient lists, and production flowcharts from the manufacturer. If the product is a mixture, apply General Interpretative Rule 3 to determine the essential character. For instance, if a product is predominantly fishmeal but contains minor additives, it would likely remain in 230120. Always consult the latest WCO Explanatory Notes, USITC HTS, and EU TARIC guidance for precise interpretations and binding rulings if uncertainty persists.