The "Golden Age" of Lipid Health Supplements

As a veteran with 20 years of experience in the foreign trade industry, I have witnessed the development of lipid-based health foods from the initial cod liver oil to today's flourishing variety. These products, hailed as "liquid gold," have...Classification of CustomsSeemingly simple yet full of hidden complexities. Today, let me guide you through cracking the "golden liquid" access codes with a few typical cases.

The "ID card" of single-component products

In the family of lipid-based health products, single-component products are like citizens with clear identification, making classification relatively straightforward:

• Cod liver oil (1504.1000): This "old friend" that has grown up with generations is rich in vitamins A and D. During classification, it's important to note that the addition of trace amounts of antioxidants is permitted, but its fundamental characteristics must not be altered.
• Fish oil (1504.2000): Though only one character different from cod liver oil, its composition varies significantly. Its core value lies in Omega-3 fatty acids, with EPA and DHA content being key indicators.
• Algal oil (1515.6000): As a rising star, algal oil is often mistakenly classified as plant oil during categorization. In reality, it should be classified under microbial oils as 1515.6000.
• Krill oil (1506.0000): Contains a unique astaxanthin component, which requires special attention during classification to distinguish it from ordinary fish oil. It should be classified under the category of "other animal fats."

The "cross-border challenge" of hybrid products

When multiple oils combine or other ingredients are added, classification becomes complex. Here are two typical cases worth noting:

Case 1: Bettys DHA beverage (1517.9090)

This beverage blending sunflower oil, DHA algal oil, and wheat germ oil maintains its fundamental characteristics as a lipid product despite adding small amounts of lemon juice for flavoring - much like adding a lemon slice to a cocktail doesnt change its alcoholic nature.

Case 2: Algae oil DHA capsules (2106.9090)

When nervonic acid and sweet orange oil appear in the formula as "uninvited guests," the situation changes. These ingredients fall outside the scope allowed under tariff heading 15.17, much like unwelcome party crashers who must find another place—the "other" category of 2106.9090.

Special forms of "identity confusion"

Some products containing lipid components but with special forms often generate classification disputes:

• Fish oil gummies (2106.9090): It looks like candy but contains no sugar; despite having 33% fish oil, other ingredients overshadow the main component. This "neither-fish-nor-fowl" product can ultimately only be categorized as "other food."
• Microencapsulated fish oil: Though its form changes through microencapsulation technology, as long as no additional functional ingredients are added, it can still be classified as original fish oil.

Practical customs clearance recommendations

Based on years of hands-on experience, I have summarized the "Three-Look Principle" for the classification of lipid-based health supplements:

1. Look at primary components: Single-component products should first consider specific listings in Chapter 15
2. Look at additives: Those exceeding trace antioxidant ranges require alternative tariff headings
3. Look at product form: Special forms may alter fundamental product characteristics

A final reminder to all importers and exporters: Customs classification is a dynamic and technical task. When encountering new composite formula products, it is advisable to consult professional classification experts or apply for advance rulings in advance to avoid delays in customs clearance due to classification errors. After all, these "liquid gold" products are highly valuable, and smooth customs clearance is essential to let the gold truly shine.