No — both liquid (typically a 70% aqueous solution) and crystalline sorbitol classify to the same 10-digit line, 2905440000. However, the physical form must be accurately described on the commercial invoice and packing list, as liquid bulk shipments require tank containers and have different weight/volume measurement conventions than crystalline product shipped in bags or supersacks.

Sorbitol used as a food ingredient is regulated by FDA as a food additive with GRAS status. The foreign manufacturer should be registered with FDA under the Bioterrorism Act facility registration requirement. Importers should obtain a certificate of analysis confirming FCC (Food Chemicals Codex) grade compliance and retain it for FDA inspection purposes. Shipments may be subject to FDA examination at the port of entry, particularly from facilities with prior import alerts. Consulting a licensed customs broker familiar with FDA-regulated chemical imports is recommended.