Frozen Fish Livers and Roes

Roe derived from sturgeon species (family Acipenseridae) — including beluga, osetra, and sevruga — requires CITES export and import permits because all sturgeon are listed on CITES Appendix II. Salmon roe, flying fish roe (tobiko), and roe from non-CITES species do not require CITES documentation. Importers should confirm the species source with suppliers before shipment to avoid seizure at the port of entry.

Yes. Frozen fish livers in their whole or processed-but-not-rendered form fall under this heading. Fish liver oils — such as cod liver oil — that have been extracted and rendered are classified under a separate fats and oils heading. The physical state and degree of processing at the time of export determine the correct classification, and misclassification can affect both duty rates and applicable FDA product categories.