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15

Official Chapter Guide

Animal, vegetable, or microbial fats and oils; edible fats and waxes, excluding specific fats and oils covered in other headings.

Tariff Landscape

  • Duty Rates: Most animal and vegetable oils are dutiable, but the specific rate can vary widely depending on subheading and origin.
  • Trade Policy Implications: Limited direct impact from Section 301 or Section 232 tariffs; however, thorough examination of commodity-specific ADD/CVD cases is prudent.
  • High-Risk Areas: Pay attention to labels that might carry claims requiring certification (e.g., "Certified organic" standards), which can affect duty rates and compliance.

Classification Strategy

  • Common Mistakes: Misclassifying products with non-qualifying excess ingredients like cocoa butter or improperly denatured oils.
  • Complex Areas: Differentiating solvent-extracted olive oils and understanding specific exclusions of fatty acids, waxes, or chemical products not in this chapter.
  • Key Focus: Ensure accurate understanding of restrictions and detailed criteria for subcategories like virgin olive oil and erucic acid content.

Legal Framework

Executive Summary

  • Exclusions: Pig fat, poultry fat, cocoa butter, certain edible preparations, and various residues.
  • Olive Oils: Heading 1509 excludes solvent-extracted olive oils.
  • Denatured Fats: Heading 1518 excludes merely denatured fats, which are classified as undenatured equivalents.
  • Specific Inclusions: Soap-stocks, oil foots, stearin pitch, and wool grease residues fall under heading 1522.
  • Definitions: Virgin olive oil must not exceed 2.0 g/100 g free acidity; "low erucic acid" oils contain less than 2% erucic acid.
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