GOED continues to track the US tariff situation to determine the possibility of filing a request for tariff exclusions for the omega-3 industry. To this end, we have been consulting with two US dietary supplement associations, including our sister organization United Natural Products Alliance (UNPA). The current thought is that while we may be able to file a tariff exclusion request, the likelihood of refusal at this time is high and it’s a one-time opportunity. There are other factors at play that make considering the importance of timing as important as whether to file an exemption request.
Based upon feedback from members, we have compiled the following list of eight-digit omega-3 related US import codes. We have cross referenced this list with the Harmonized Tariff Schedule of the United States (HTSUS).
- 1504.10.20
- 1504.10.40
- 1504.20.20
- 1504.20.40
- 1504.20.60
- 1506.00.00
- 1515.60.05
- 1515.90.81
- 1516.10.00
- 1516.20.91
- 1516.30.00
- 1517.90.20
- 2106.90.99
- 2915.90.10
- 2916.19.50
- 3824.99.41
Members did provide other codes not included above; however, many contained only six digits, did not exist within the HTSUS or were likely specific to the country of export and not aligned with US import codes.
If you are a US company importing an omega-3 product (oil or finished product) and you don’t see the relevant eight-digit HTSUS code above, please let GOED know. If you are exporting an omega-3 product (oil or finished product) to the US and you don’t see the relevant eight-digit HTSUS code above, please confirm with your US customer what HTSUS code was used to import the product or check with a customs broker. GOED is unable to advise on what your import code is or should be.
With respect to HTSUS 2915.90.10, while many members have told us that this is not an appropriate code to use for omega-3 oils (as mentioned in last week’s news alert), we have learned that at least one member is using it. While it is currently on the exemption list associated with the 2 April 2025 Executive Order, that could change as a result of a current investigation by the US Secretary of Commerce. This investigation was initiated “under section 232 of the Trade Expansion Act to determine the effects on national security of imports of pharmaceuticals and pharmaceutical ingredients, and their derivative products. This includes both finished generic and non-generic drug products, medical countermeasures, critical inputs such as active pharmaceutical ingredients and key starting materials, and derivative products of those items.” In possibly related news, the Trump administration is considering adding tariffs for pharmaceuticals. GOED plans to look into this situation and will report back to the membership with any relevant information.
