HTS Code for dietary supplements in the form of softgel capsules

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## Common ground All options are dietary supplements in softgel capsule form, intended for oral consumption to support health. ## Options at a glance **1504.10 – Fish liver oil softgels** - **Defining trait:** Made from unmodified fish liver oils (e.g., cod liver), retaining their natural character. - **Typical examples:** Cod liver oil capsules, vitamin A/D-rich softgels. - **Best fit when:** The primary base is fish liver oil, even if vitamins are added. **1504.20 – Fish oil softgels** - **Defining trait:** Made from non-liver fish oils (e.g., from mackerel, salmon), not chemically altered. - **Typical examples:** Omega-3 fatty acid capsules from fish body oil. - **Best fit when:** The oil comes from fish flesh or non-liver sources. **1504.30 – Marine mammal oil softgels** - **Defining trait:** Derived from oils of marine mammals (e.g., whales), not chemically modified. - **Typical examples:** Sperm whale liver oil capsules, traditional seal oil supplements. - **Best fit when:** The source is a marine mammal, not fish. **2106.90 – Other dietary supplements** - **Defining trait:** Not derived from fish or marine mammal oils; includes plant-based or synthetic sources. - **Typical examples:** Vitamin E softgels (from soy), probiotic capsules, vegan DHA from algae. - **Best fit when:** The oil base is not from fish or marine mammals. ## Key differences | Feature | 1504.10 | 1504.20 | 1504.30 | 2106.90 | |-----------------------|------------------|------------------|--------------------|----------------------| | Source | Fish liver | Fish body | Marine mammal | Other (plant/synth) | | Chemical modification | None | None | None | Not applicable | | Vitamin enrichment | Allowed (if kept character) | Same | Same | Same | ## How to choose - Is the oil sourced from fish liver? → 1504.10 - Is it from fish body (not liver), but not marine mammal? → 1504.20 - Is it from a marine mammal (e.g., whale, seal)? → 1504.30 - Is the base plant-based, synthetic, or non-fish/non-mammal? → 2106.90 ## Overlaps & pitfalls - A softgel with fish liver oil and added vitamins fits **1504.10**, even if enriched. - If the product contains both fish liver oil and fish body oil, it should still be classified under **1504.10** if liver oil is dominant or defining. - **No clear priority rule** is given; use the *main source* of oil as the deciding factor. If uncertain, classify by primary ingredient



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