## Common ground
All options are food products designed to mimic the taste, texture, or function of butter.
## Options at a glance
**0405.20 – Milk-based substitutes**
- **Defining trait:** Made from milk or milkfat, even if modified.
- **Typical examples:** Cultured dairy spreads with milk fat content above 15%.
- **Best fit when:** The product contains milk fat or is derived from milk, regardless of added oils.
**1517.90 – Non-dairy substitutes**
- **Defining trait:** Not derived from milk or milkfat; typically plant-based.
- **Typical examples:** Margarine made from soybean or coconut oil without dairy.
- **Best fit when:** The product contains no milk or milkfat, even if it mimics butter.
**2008.97 – Peanut butter substitute**
- **Defining trait:** Specifically intended as a replacement for peanut butter, not butter.
- **Typical examples:** Soy-based spreads with nut-like flavor but no peanuts.
- **Best fit when:** The product is marketed or used as a peanut butter alternative (e.g., in sandwiches).
**2106.90 – Butter substitute (specific formulation)**
- **Defining trait:** Contains at least 15% milk fat and specific ingredient ratios (e.g., 38–44% butter oil, 36–42% vegetable oil).
- **Typical examples:** Commercial dairy-based spreads with defined composition.
- **Best fit when:** The product has a precise blend of ingredients and meets the listed percentages.
## Key differences
| Option | Base ingredient | Milk fat content | Key composition | Primary use case |
|-------|------------------|------------------|------------------|-------------------|
| 0405.20 | Milk/milkfat | ≥15% | Varies | General butter substitute |
| 1517.90 | Non-dairy | None | Plant oils, etc. | Vegan/dairy-free use |
| 2008.97 | Peanuts/peanut-like | N/A | Soy/nut-free | Peanut allergy alternative |
| 2106.90 | Milkfat + oil | ≥15% | Specific ratios | Commercial food prep |
## How to choose
- Is the product made from milk or milkfat? → 0405.20 or 2106.90
- Does it contain no milk or milkfat? → 1517.90
- Is it meant as a peanut butter replacement? → 2008.97
- Does it match the exact ingredient ratios (e.g., 38–44% butter oil)? → 2106.90
## Overlaps & pitfalls
- **Overlap:** A product with ≥15% milk fat could fall under both 0405.20 and 2106.90. The specific formulation in 2106.90 takes priority if ingredient ratios match.
- **Pitfall:** "Butter substitute" in name doesn’t imply HS Code—context and composition matter.
- **Priority note:** If a product fits multiple codes, use the most specific one (e.g., 2106.90 over 0405.20)