As reported last week, GOED is working to better understand the HTSUS codes used by the omega-3 industry to import products into the United States in order to request a possible exemption from the tariffs imposed by US President Trump’s 2 April 2025 Executive Order. With the exception of China, these tariffs are mostly on hold for 90 days (other than the 10% baseline tariffs).
At this time, it’s our understanding that HTSUS 29159010 (also written as 2915.90.10), which is included in the exemption list associated with the 2 April 2025 Executive Order, is not applicable to omega-3 oils. We are compiling a list of HTSUS codes from members that actually are used, but this is not a simple task, as some members are providing export codes that are sometimes (but not always) different than the US importation codes. To our knowledge, there are no exemptions for any omega-3 oil currently being imported into the US.
It is also worth noting that there were supposed to be no tariff exemptions and at this time there is no mechanism in place to apply for an exemption. We also received a recap of a conversation in the United States Congress with the Senate Finance Committee and the United States Trade Representative (USTR), where Congressional representatives from many districts around the country were telling the USTR that they needed an exemption (for beef, bananas or bamboo sheets, for example) and the answer from USTR was consistent that exemptions will not be allowed.
Finally, it has been suggested that it could be counterproductive to ask for exemptions because it could bring undue attention to the industry or products being imported.
To date, we have heard from 25+ members and we are still clarifying some of the information, with a plan to share the list of codes with members once it is organized. We have also been in contact with US supplement associations (GOED partner United Natural Products Alliance and the Council for Responsible Nutrition), both of which have broader expertise and government connections, to determine the best path forward and make sure we are presenting a consistent message to the authorities, if we choose to do so. We will continue to keep members informed on this important topic.
If you have not provided Harry Rice with your HTSUS codes, please do so as soon as possible. For clarification, the codes we need are the US importation codes, not the codes used to export products to the US.
For additional background from other trade associations, see these UNPA and CRN interviews.
