Caviar Substitutes Prepared from Fish Eggs

True caviar (HTS heading 160431) is prepared exclusively from sturgeon roe and carries CITES permit requirements. Caviar substitutes under 160432 are made from the eggs of other fish species — commonly lumpfish, capelin, or flying fish — and are classified by preparation method and container type rather than species-based permit requirements.

Taiwan and Iceland are the top two sources, followed by Japan, Canada, and China. Taiwan and Iceland have well-developed processing sectors for lumpfish and capelin roe, which are the most commonly traded substitutes.

FDA regulates these products as processed seafood under the Seafood HACCP program, and prior notice is required before arrival. Importers should confirm the foreign establishment's eligibility and ensure HACCP documentation is in order. Admissibility and classification are complex — consult a licensed customs broker or FDA for guidance.