HS2022 Chapter 4: Dairy produce; birds’ eggs; natural honey; edible products of animal origin, not elsewhere specified or included — Practical Working Guide

Target: HS2022 Chapter 4 (HS Section I) — practical guidance for Japan / Import & Export (both).
Typical products in scope (examples): liquid milk and cream, milk powder, yogurt/fermented dairy, whey ingredients, butter/ghee, cheese, shell eggs, liquid/powder eggs, natural honey, and (HS2022 change) edible non-living insects. (世界税関機構)

Terminology used consistently in this guide

  • Section = HS Section I (Live animals; animal products)
  • Chapter = 2-digit code (here: 04)
  • Heading = 4-digit code (e.g., 0406)
  • Subheading (HS6) = 6-digit code (e.g., 0406.10)
  • National tariff line code / national code = country-specific digits beyond HS6 (Japan uses further subdivisions beyond HS6). (本州税関)
  • Notes = Section Notes / Chapter Notes / Subheading Notes (legally binding classification “levers”).

0. Bottom line first: What is in / not in this Chapter (ultra-summary)

  • Typical examples INCLUDED in this Chapter (3–6):
    • Milk & cream, not concentrated, no added sugar (e.g., UHT whole milk; fresh cream) → 0401 (世界税関機構)
    • Milk & cream, concentrated or sweetened (e.g., sweetened condensed milk; milk powder) → 0402 (世界税関機構)
    • Yogurt and other fermented/acidified dairy (often even with added sugar/flavourings/fruit/nuts/cocoa) → 0403 (世界税関機構)
    • Whey / modified whey and other natural milk constituents (NESOI)0404 (世界税関機構)
    • Butter, dairy spreads, and other milk fats (incl. ghee)0405 (世界税関機構)
    • Cheese and curd0406 (世界税関機構)
    • Birds’ eggs: in shell (0407) and not in shell / yolks (0408) (世界税関機構)
    • Natural honey0409 (世界税関機構)
    • Edible non-living insects in basic states (fresh/chilled/frozen/dried/smoked/salted/in brine) and insect flours/meals fit for human consumption → 0410.10 (HS2022) (世界税関機構)
  • Typical examples commonly EXCLUDED (3–6; include likely alternative Chapter/Heading):
    • High-lactose whey-derived products: whey products with >95% lactose (anhydrous, dry matter basis)1702 (lactose), not Chapter 4 (世界税関機構)
    • Whey protein concentrates/isolates meeting the Chapter Note protein threshold (e.g., >80% whey proteins, dry matter basis, in the Chapter Note wording) → 3502 (albumins), not Chapter 4 (世界税関機構)
    • “Filled milk” / dairy analogues where natural milk constituents are replaced (e.g., milkfat replaced by vegetable oils) → commonly 1901 or 2106 (depending on product form and presentation), not Chapter 4 (世界税関機構)
    • Edible insects otherwise prepared/preserved (e.g., “snack-style” insect foods) → generally Section IV (prepared foods; often Chapter 16/20/21 depending on facts) (世界税関機構)
  • The top practical decision points (1–3):
    1. Basic dairy vs prepared food: Is it still a Chapter 4 “basic state,” or has it become a preparation (Section IV)? (世界税関機構)
    2. Whey ingredient traps: lactose % (1702) and whey protein % (3502) can override “it’s from milk” intuition. (世界税関機構)
    3. Insects (HS2022): basic-state edible insects are now explicitly recognized under 0410.10, but prepared insect foods can move out of Chapter 4. (世界税関機構)
  • (Optional) Situations where misclassification tends to be “high-cost” in practice:
    • Dairy products often face high duties / quotas / strict SPS controls in many countries; even a small HS error can create clearance delays, duty differences, or invalid FTA claims. (Verify tariff/quota treatment per importing country and date.) (本州税関)

1. How to reach this Chapter (classification logic)

1-1. Core classification rules (where GIR matters)

  • GIR 1 (words + Notes) dominates for Chapter 4:
    • Many outcomes depend on Chapter Notes that define terms (e.g., “butter”) and force exclusions (e.g., lactose >95% → 1702; whey protein threshold → 3502). (世界税関機構)
  • GIR 6 (Subheading selection) is where operational errors happen:
    • Within a heading, HS6 splits often depend on fat %, form (powder vs other), or egg state (in shell vs not). (世界税関機構)
  • Avoid “classifying by product name only.” In Chapter 4, the label “whey powder,” “milk powder,” “coffee creamer,” “protein,” “yogurt with cereal,” etc. is not decisive without specs.

1-2. Decision flow (pseudo flowchart)

  • Step 1: Is it dairy / bird eggs / natural honey / edible insects / other edible animal-origin NESOI?
  • Step 2: Is it a “basic state” product or a “prepared food”?
    • If it is a prepared/preserved food (recipes, sauces, snack products, composite preparations) → test Section IV (Ch. 16/19/21, etc.) first. (Insect products are a common boundary area.) (世界税関機構)
  • Step 3: For dairy ingredients, check note-driven “override tests” early:
    • If whey-derived product has >95% lactose (dry matter basis) → likely 1702 (not Ch.4). (世界税関機構)
    • If it is a whey protein concentrate matching the Chapter Note protein threshold (e.g., >80% whey proteins, dry matter basis) → likely 3502 (not Ch.4). (世界税関機構)
  • Step 4: If still in Chapter 4, choose by product family:
    • Milk/cream → 0401/0402
    • Fermented/acidified (incl. yogurt) → 0403
    • Whey / modified whey / other natural milk constituents → 0404
    • Milk fats (butter, dairy spreads, ghee) → 0405
    • Cheese/curd → 0406
    • Bird eggs → 0407/0408
    • Natural honey → 0409
    • Insects / other edible animal-origin NESOI → 0410 (世界税関機構)
  • Common boundary disputes (e.g., boundary between Chapter X and Chapter Y):
    • Chapter 4 vs Chapter 19/21: milk-based preparations where milk constituents are replaced or the product becomes a “food preparation.” (世界税関機構)
    • Chapter 4 vs Chapter 35: whey protein concentrates/isolates that meet the note threshold. (世界税関機構)
    • Chapter 4 vs Chapter 17: lactose/pure milk sugar direction. (世界税関機構)

2. Main Headings (4-digit) and what they cover

2-1. Table of key 4-digit Headings (REQUIRED)

Heading (4-digit)Plain-English summaryTypical examples (products)Key decision criteria / exclusions / cautions
0401Milk & cream, not concentrated, no added sugarUHT milk; pasteurized creamHS6 split by fat %. Verify “concentrated” vs not. (世界税関機構)
0402Milk & cream, concentrated and/or sweetenedsweetened condensed milk; milk powderHS6 split by powder vs other, fat %, with/without sugar. (世界税関機構)
0403Yogurt; buttermilk; kefir; other fermented/acidified milk & creamyogurt (incl. flavoured); kefir; buttermilkChapter Note expands what yogurt may contain if it remains essentially yogurt and added substances do not replace milk constituents. (世界税関機構)
0404Whey (incl. modified whey) and other natural milk constituents (NESOI)whey powder; whey permeate; milk constituents mixesTwo key exclusions: (i) >95% lactose → 1702; (ii) certain whey proteins → 3502. Also “modified whey” has a specific definition. (世界税関機構)
0405Butter and other milk fats & oils; dairy spreadsbutter; dairy spreads; ghee/butter oil“Butter” and “dairy spreads” have defined fat/water limits; ghee/dehydrated butter not in 0405.10. (世界税関機構)
0406Cheese and curdmozzarella; cheddar; processed cheese; curdNote-driven rule: certain whey concentrates with added milk/milkfat meeting thresholds are treated as cheese. (世界税関機構)
0407Birds’ eggs, in shellshell eggs; fertilised eggs for incubationSplit between incubation eggs vs other fresh eggs, and by Gallus domesticus vs other. (世界税関機構)
0408Birds’ eggs not in shell; egg yolksliquid egg; dried egg powder; frozen yolkSplit by yolks vs other, and dried vs other. (世界税関機構)
0409Natural honeymonofloral honey; blended honey (still “natural”)If “honey-based preparation” with other ingredients, re-test Section IV. (世界税関機構)
0410Insects and other edible products of animal origin, NESOIedible non-living insects; other edible animal-origin NESOIHS2022: 0410.10 insects are defined (basic states + flours/meals fit for human consumption). Prepared insect foods generally move to Section IV. (世界税関機構)

2-2. Operationally important splits at the 6-digit Subheading level (REQUIRED)

Key split criteria you will actually use:

2–5 confusing Subheading pairs/groups:

  • 0401 vs 0402 (milk/cream not concentrated vs concentrated/sweetened)
    • Where the split happens: concentration and/or added sugar. (世界税関機構)
    • Information needed to decide: Brix/solids %, water removal step, sugar addition, product spec.
    • Typical mistake pattern: calling condensed milk “0401” because it is still “milk.”
  • 0403 (yogurt) vs 1901/2106 (food preparations)
    • Where the split happens: whether the product retains the essential character of yogurt and whether added substances are used to replace milk constituents. (世界税関機構)
    • Information needed to decide: formulation role of additions (texture/character vs substitution), product identity in commerce, ingredient/function list.
    • Typical mistake pattern: any “yogurt with cereal” pushed into Chapter 19 automatically (but Chapter Note explicitly allows some additions if the product remains yogurt). (世界税関機構)
  • 0404 (whey) vs 1702 (lactose)
    • Where the split happens: whey-derived products with >95% lactose (dry matter basis) move to 1702 by Chapter Note. (世界税関機構)
    • Information needed to decide: certificate of analysis showing lactose % on dry matter; whether product is obtained from whey.
    • Typical mistake pattern: “whey permeate powder” treated as 0404 without checking lactose %.
  • 0404 (whey ingredients) vs 3502 (albumins / whey protein concentrates)
    • Where the split happens: concentrates meeting the Chapter Note protein threshold (e.g., >80% whey proteins, dry matter basis) move out to 3502. (世界税関機構)
    • Information needed to decide: protein profile, whey protein % on dry matter, product description (WPC/WPI), lab method basis.
    • Typical mistake pattern: classifying WPC80/WPI as 0404 “because it is whey-derived.”
  • 0410.10 (basic-state insects) vs Section IV prepared foods
    • Where the split happens: basic states listed in the Chapter Note vs “otherwise prepared or preserved.” (世界税関機構)
    • Information needed to decide: process (seasoning, roasting, coating, ready-to-eat snack), ingredient list, intended use.
    • Typical mistake pattern: any insect product declared as 0410.10 even when clearly a prepared snack.

3. Interpreting Section Notes and Chapter Notes (legal text → practical meaning)

3-1. Relevant Section Notes

  • Key points (summary):
    • In Section I, references to a genus/species include young animals (rarely decisive for Chapter 4 operations). (世界税関機構)
    • “Dried” includes dehydrated, evaporated, and freeze-dried across the HS unless context says otherwise. This matters for milk powder, dried eggs, and dried insects. (世界税関機構)
  • Practical meaning (with concrete examples):
    • “Freeze-dried egg yolk powder” is still treated as dried in HS terms; don’t reclassify just because “freeze-dried sounds highly processed.” (世界税関機構)
  • Typical patterns where a Section Note “moves you to another Chapter”:
    • Not a common Chapter 4 pattern; Chapter Notes are the main “movers” here.

3-2. Chapter Notes for this Chapter

  • Key points (summary):
    • “Milk” includes full-cream and partially/fully skimmed milk. (世界税関機構)
    • Yogurt can be concentrated/flavoured and can contain various additions, as long as additions are not used to replace milk constituents and the product remains essentially yogurt. (世界税関機構)
    • “Butter” and “dairy spreads” are defined with specific fat/water/solids limits. (世界税関機構)
    • Certain concentrated whey products with added milk/milkfat must be classified as cheese if they meet three thresholds (milkfat on dry matter; dry matter range; mouldable). (世界税関機構)
    • Exclusions that frequently re-route Chapter 4 goods:
      • >95% lactose whey-derived products → 1702 (世界税関機構)
      • milk products with natural constituents replaced (e.g., milkfat replaced by other fats) → 1901 or 2106 (世界税関機構)
      • certain whey protein concentrates → 3502; globulins → 3504 (世界税関機構)
    • HS2022 adds a definition for “insects” under heading 0410, limited to edible non-living insects in basic states (and insect flours/meals fit for human consumption). (世界税関機構)
  • Definitions (if any):
    • Butter: milk-derived only; milkfat within a defined range; water and milk-solids-not-fat limits; no added emulsifiers (but some minor additions like salt/cultures are allowed). (世界税関機構)
    • Dairy spreads: spreadable water-in-oil emulsion; milkfat is the only fat; milkfat within a defined range. (世界税関機構)
    • Modified whey: whey with lactose/proteins/minerals removed (partly or fully), or with whey constituents added, or mixtures of natural whey constituents. (世界税関機構)
    • Insects (for 0410): edible non-living insects (whole/parts) in specified basic states + flours/meals fit for human consumption; excludes insects otherwise prepared/preserved. (世界税関機構)
  • Exclusions (state alternative Chapter/Heading explicitly):

4. How the Chapter Notes change classification outcomes (where the code flips)

Purpose: make “note-driven splits” visible.

  • Impact point 1: Butter vs dairy spreads vs other milk fats
    • What to check (information needed): milkfat %, water %, milk solids-not-fat %, ingredients (emulsifiers?), whether it’s ghee/dehydrated butter. (世界税関機構)
    • Evidence to collect in practice: spec sheet/COA, ingredient list, manufacturing description.
    • Typical misclassification: calling ghee “butter (0405.10)” even though the Subheading Note excludes ghee from that butter subheading. (世界税関機構)
  • Impact point 2: Whey concentrate that becomes “cheese” by rule
    • What to check (information needed): milkfat content on dry matter; dry matter %; whether moulded/capable of moulding. (世界税関機構)
    • Evidence to collect in practice: COA showing dry matter and fat; product form/packaging photos; process flow.
    • Typical misclassification: treating a mouldable whey concentrate with added milkfat as 0404 “whey powder” instead of 0406 “cheese.” (世界税関機構)
  • Impact point 3: Lactose threshold sends whey-derived goods to Chapter 17
    • What to check (information needed): lactose % expressed as anhydrous lactose on dry matter (and whether the product is obtained from whey). (世界税関機構)
    • Evidence to collect in practice: lab method and basis statement; dry matter calculation; manufacturing description.
    • Typical misclassification: classifying high-lactose whey permeate as 0404 when it meets the >95% lactose exclusion. (世界税関機構)
  • Impact point 4: Whey protein concentrates can jump to Chapter 35
    • What to check (information needed): whey protein % on dry matter and product nature (concentrate/isolate). (世界税関機構)
    • Evidence to collect in practice: COA; protein fraction details; marketing/spec description.
    • Typical misclassification: declaring WPC80/WPI under 0404 “milk constituents” despite meeting the Chapter Note threshold. (世界税関機構)
  • Impact point 5: Insects in HS2022 (0410.10) vs prepared insect foods
    • What to check (information needed): processing state vs the Chapter Note’s basic states; presence of sauces/seasoning/coating; “ready-to-eat snack” presentation. (世界税関機構)
    • Evidence to collect in practice: ingredient list, process description, retail packaging, photos.
    • Typical misclassification: roasted/seasoned insects declared as 0410.10 even though the Note excludes insects “otherwise prepared or preserved.” (世界税関機構)

5. Common mistakes in practice (cause → correction)

Write 5–10 items using this exact pattern:

  1. Mistake: Classifying sweetened condensed milk as 0401
    • Why it happens: teams focus on “it’s milk,” ignoring concentration/sugar criteria.
    • Correct approach (which Note / which Heading logic supports it): concentrated and/or sweetened milk/cream belongs in 0402. (世界税関機構)
    • Prevention (documents to verify / internal questions to ask): “Is it concentrated?” “Is sugar added?” COA/label + process step (evaporation).
  2. Mistake: Treating yogurt with fruit/cocoa/cereals as a “prepared food” by default
    • Why it happens: additions trigger an assumption it’s no longer yogurt.
    • Correct approach (which Note / which Heading logic supports it): Chapter Note allows yogurt to contain various additions if they do not replace milk constituents and the product keeps the essential character of yogurt. (世界税関機構)
    • Prevention: ask “Are additions substituting milk solids/fat?” “Is the product commercially yogurt?” Keep formulation rationale on file.
  3. Mistake: Whey permeate / deproteinized whey powder classified as 0404 without checking lactose
    • Why it happens: invoice says “whey powder,” and teams stop there.
    • Correct approach: if whey-derived product exceeds the Chapter Note lactose threshold, it goes to 1702. (世界税関機構)
    • Prevention: require lactose % (dry matter basis) in COA for whey-derived powders.
  4. Mistake: WPC/WPI (high whey-protein products) left in 0404
    • Why it happens: “milk constituent” sounds correct; protein threshold is missed.
    • Correct approach: Chapter Note excludes specified whey-protein concentrates to 3502 (albumins). (世界税関機構)
    • Prevention: require protein % on dry matter and whether it is a “whey protein concentrate/isolate.”
  5. Mistake: Ghee classified as butter (0405.10)
    • Why it happens: ghee is marketed as “clarified butter.”
    • Correct approach: Subheading Note states butter (0405.10) excludes dehydrated butter/ghee, which is classified elsewhere within 0405. (世界税関機構)
    • Prevention: confirm whether product is dehydrated/clarified and check the Subheading Note before coding.
  6. Mistake: Whey concentrate with added milkfat treated as whey (0404) when it meets the “cheese” test
    • Why it happens: raw material is whey, so teams assume 0404.
    • Correct approach: if it meets the Chapter Note conditions (fat on dry matter; dry matter range; mouldable), it must be treated as cheese (0406). (世界税関機構)
    • Prevention: collect dry matter + fat on dry matter; document whether moulded/capable of moulding.
  7. Mistake: Insect snack foods declared as 0410.10
    • Why it happens: HS2022 has “insects,” so teams use it broadly.
    • Correct approach: 0410.10 covers edible non-living insects in specific basic states; insects “otherwise prepared or preserved” are excluded (generally Section IV). (世界税関機構)
    • Prevention: require full ingredient list + processing description; establish an internal trigger: “If seasoned/roasted/coated → re-test Section IV.”
  8. Mistake: Egg products confusion: 0407 vs 0408
    • Why it happens: “eggs” used for both shell eggs and liquid/powder eggs.
    • Correct approach: in shell → 0407; not in shell (incl. yolks; dried/frozen) → 0408. (世界税関機構)
    • Prevention: require state description (in shell / liquid / powder / frozen), and whether yolk-only or whole egg.

6. Points to watch for FTA/EPA origin certification

6-1. Relationship between HS classification and PSR (Product-Specific Rules)

  • HS assignment selects the PSR line; misclassification can invalidate a preference claim.
  • Chapter 4 is especially sensitive because:
    • dairy and egg supply chains often involve cross-border processing (powdering, blending, fermentation, cheese-making)
    • PSRs may include specific change-in-tariff-classification rules and/or value/weight limits (agreement-dependent). (外務省)

6-2. HS version differences referenced by agreements (HS2012 / HS2017 / HS2022)

Why this matters for Chapter 4: HS2022 introduced new insect subheading 0410.10 and changed the yogurt subheading structure (see Section 7). If an agreement uses an older HS edition, you must map codes carefully. (世界税関機構)

  • Japan–EU EPA
    The Japan–EU EPA PSR annex uses HS 2017 in its HS classification column. (外務省)
    Practical caution: if your operational classification is HS2022, map HS2022 → HS2017 before selecting the PSR line (and keep an audit trail).
  • CPTPP
    The CPTPP PSR annex indicates HS Classification (HS2012). (MITI FTA)
    Practical caution: map HS2022 → HS2012 before PSR selection, particularly for items impacted by HS2022 changes.
  • RCEP
    RCEP has a transposed PSR set in HS2022, implemented by Parties from 1 January 2023 (check the importing Party’s implementation and the shipment date). (ニュージーランド税関)

How to handle transposition (old → new mapping) in general

  • Practical approach:
    1. classify the finished good in HS2022,
    2. map HS2022 → the agreement HS edition using official correlation tables,
    3. apply PSR in the agreement’s HS edition,
    4. keep an audit trail showing mapping logic and sources. (世界税関機構)
  • Do not guess mappings when splits/merges exist; record “Information needed to decide” and what evidence is required.

6-3. Practical checklist (data needed for origin analysis)

  • Final goods: HS2022 HS6 + mapped HS code in the agreement’s HS edition (if different)
  • Inputs: origin of raw milk/cream, cultures/enzymes, sugar/cocoa/fruit additions, packaging
  • Processing steps and locations (pasteurization, evaporation, drying, fermentation, cheese-making, egg breaking/pasteurization, etc.)
  • Supporting documents & retention (general guidance):
    • BOM, production records, supplier origin declarations, certificates, process flow charts, purchase/sales invoices

7. Differences between HS2022 and earlier HS editions (what changed and why)

7-1. Change summary (REQUIRED TABLE)

Comparison (e.g., HS2017→HS2022)Change type (new / deleted / split / merged / wording / scope)Codes affectedPractical meaning of the changeOperational impact
HS2017 → HS2022Restructuring (subheading change)Yogurt moved from 0403.10 (HS2017) to 0403.20 (HS2022)Aligns HS6 structure with expanded yogurt scope (including certain added items)Update ERP/HS master data; revise FTA mapping and historical trend reports that use HS6 for yogurt (世界税関機構)
HS2017 → HS2022New subheading split + new Chapter Note definition0410.10 (Insects) created; 0410.90 (Other) created; older 0410.00 replaced at HS6 levelEdible non-living insects are identified explicitly (basic states + flours/meals fit for human consumption)Add insect-specific HS6; train teams on boundary with prepared insect foods (Section IV) (世界税関機構)

7-2. Why it changed (REQUIRED)

  • Based on the WCO HS2022 correlation table remarks:
    • Edible insects were separated into new subheading 0410.10 for monitoring/clarity, and related scopes across the HS were adjusted. (世界税関機構)
    • The yogurt subheading was restructured to reflect the expanded scope of heading 04.03 regarding yogurt containing certain added items. (世界税関機構)

8. HS codes added or removed before HS2022 (historical perspective)

HS edition transitionWhat changed in Chapter 4 (high level)Evidence basisNotes / mapping hints
HS2007 → HS2012Information needed to decideConsult official HS2007↔HS2012 correlation tables for Chapter 4Treat as a controlled mapping exercise if you run legacy ERP codes
HS2012 → HS2017Information needed to decideConsult official HS2012↔HS2017 correlation tables for Chapter 4Important when applying CPTPP PSRs (HS2012) while operating in HS2022 (MITI FTA)
HS2017 → HS2022Clear HS6-level changes include yogurt subheading restructuring and creation of insect subheadingWCO correlation table + HS2022 legal textPrioritize mapping for 0403 (yogurt) and 0410 (insects) (世界税関機構)

9. Clearance trouble scenarios caused by violating Notes (case-style)

  • Case name (short): WPC80/WPI declared as 0404 “whey”
    • What went wrong (which Chapter Note / Section Note was violated): Chapter Note excludes certain whey-protein concentrates by protein threshold to 3502. (世界税関機構)
    • Why it happens (product naming, set treatment, end-use misunderstanding, processing state misunderstanding, etc.): “whey protein” marketing language masks the legal note boundary.
    • Typical impacts (general: amendments, additional duty/tax, increased inspection, delays, etc.): reclassification, post-entry correction, delays while COA/specs are reviewed.
    • Prevention (advance ruling, pre-check, document readiness, etc.): require COA (protein on dry matter) and keep it in the customs product file.
  • Case name (short): Whey permeate powder treated as 0404 without lactose test
    • What went wrong (which Chapter Note / Section Note was violated): Chapter Note sends whey products with >95% lactose (dry matter basis) to 1702. (世界税関機構)
    • Why it happens: documentation says “whey powder” but it’s effectively lactose-rich permeate.
    • Typical impacts: tariff impact, dispute over classification, delays due to laboratory documentation requests.
    • Prevention: COA showing lactose % basis; internal rule: “whey permeate → check lactose threshold.”
  • Case name (short): Filled milk / non-dairy creamer classified as 0402
    • What went wrong (which Chapter Note / Section Note was violated): Chapter Note excludes milk products where natural constituents are replaced by other substances (typical destination 1901/2106). (世界税関機構)
    • Why it happens: label still says “milk” or “creamer,” but milkfat was replaced.
    • Typical impacts: reassessment, SPS/labeling mismatch checks, delays.
    • Prevention: require fat source breakdown and manufacturing description; confirm whether substitution occurred.
  • Case name (short): Seasoned roasted insects declared as 0410.10
    • What went wrong (which Chapter Note / Section Note was violated): 0410.10 covers edible insects in limited basic states; insects otherwise prepared/preserved are excluded (generally Section IV). (世界税関機構)
    • Why it happens: teams see “insects” and stop; they don’t apply the processing-state test.
    • Typical impacts: reclassification, food safety review delays, incorrect PSR line selection for FTA.
    • Prevention: ingredient list + process description required for all insect items; consider advance ruling for new product lines. (本州税関)

10. Import/export regulatory considerations (compliance)

For Japan, Chapter 4 goods are commonly affected by food safety and animal quarantine controls.

  • Quarantine / sanitary & phytosanitary (SPS)
    • Imported foods: importers must submit an import notification under Japan’s imported food safety framework (handled via quarantine stations). (厚生労働省)
    • Animal Quarantine Service (MAFF AQS): dairy/egg and certain animal-origin products are subject to animal quarantine inspection and may require an inspection certificate from the exporting country, depending on product and origin. (農林水産省)
    • Note that import suspensions/prohibitions can apply based on animal disease situations by country/region; always verify current status before shipping. (農林水産省)
  • CITES / species restrictions
    • Not typically applicable to standard dairy/eggs/honey, but could become relevant if a product contains regulated wildlife-derived ingredients (rare for Chapter 4 operations).
  • Export controls (if applicable)
    • Not typically applicable for common Chapter 4 food goods.
  • Other permits / notifications
    • Requirements can depend on product specs, composition, end-use, and destination; verify latest official notices and consult competent agencies when in doubt.

Official places to verify (agencies / official guides / contact points):

  • Japan MHLW Imported Foods Inspection Services (import notification concept) (厚生労働省)
  • MAFF Animal Quarantine Service: animal products import process & dairy product inspection requirements (農林水産省)
  • Japan Customs: tariff classification guidance and advance ruling system (本州税関)

Typical preparatory documents (general):

  • Invoice/packing list with clear product identity (e.g., “whey protein isolate,” “sweetened condensed milk,” “dried egg yolk”)
  • COA/spec sheet: fat %, moisture, dry matter, lactose %, whey protein %
  • Ingredient list and process description (especially for yogurt with additions, creamers/filled milk, insect products)
  • Certificates required by SPS/animal quarantine processes (case-dependent) (農林水産省)

11. Practical checklist (classification → clearance → origin → regulations)

  • Before classification (collect product information)
    • Product family: milk/cream vs fermented vs whey ingredient vs milk fat vs cheese vs eggs vs honey vs insects
    • Form/state: liquid/powder; in shell/not; dried/frozen; prepared snack/recipe or basic state
    • Key lab metrics: fat %, moisture, dry matter, lactose %, whey protein %
    • Ingredient list + processing flow (especially for “prepared” risk)
  • After classification (re-check Notes / exclusions / boundaries)
    • Apply Chapter Note exclusions early (lactose threshold; whey protein threshold; replaced milk constituents). (世界税関機構)
    • For “dried” products, remember HS meaning includes freeze-dried. (世界税関機構)
    • For insects, confirm whether it is basic-state (0410.10) or prepared/preserved (Section IV). (世界税関機構)
  • Before declaration (invoice description, units, supporting documents)
    • Ensure invoice names match HS logic (e.g., “whey protein isolate” vs “whey powder”)
    • Attach COA when Notes create threshold tests
  • FTA/EPA checks (PSR, materials, processes, retention)
    • Confirm agreement HS edition; map HS2022 → agreement HS edition if needed; keep audit trail. (外務省)
  • Regulatory checks (permits/notifications/inspection)

12. References (sources)

Primary HS sources

  • [WCO-HS2022-CH04] HS2022 legal text — Chapter 4 (headings/subheadings + Chapter/Subheading Notes). Accessed: 2026-02-13. (世界税関機構)
  • [WCO-HS2022-SEC-I] HS2022 legal text — Section I Notes (definition of “dried” including freeze-dried). Accessed: 2026-02-13. (世界税関機構)
  • [WCO-CORR-2017-2022] HS2017→HS2022 correlation (Table I) — change rationale and mapping notes (incl. insects; yogurt subheading restructure). Accessed: 2026-02-13. (世界税関機構)
  • [WCO-HS2017-CH04] HS2017 legal text — Chapter 4 (baseline for mapping). Accessed: 2026-02-13. (世界税関機構)

Japan customs / regulatory (official)

  • [JP-MHLW-IMPORTED-FOODS] MHLW Imported Foods Inspection Services (import notification requirement). Accessed: 2026-02-13. (厚生労働省)
  • [JP-MAFF-AQS-ANIMAL-PRODUCTS] MAFF AQS — Bring animal products into Japan (inspection process; suspensions). Accessed: 2026-02-13. (農林水産省)
  • [JP-MAFF-AQS-DAIRY] MAFF AQS — Animal quarantine inspection for dairy products (inspection certificate concept). Accessed: 2026-02-13. (農林水産省)
  • [JP-CUSTOMS-CLASSIFICATION] Japan Customs — Advance ruling on classification. Accessed: 2026-02-13. (本州税関)
  • [JP-CUSTOMS-HS-OVERVIEW] Japan Customs FAQ — outline of tariff classification and HS headings/subheadings/national subdivisions concept. Accessed: 2026-02-13. (本州税関)

FTA/EPA HS edition evidence (examples)

  • [JP-EU-EPA-PSR] Japan–EU EPA PSR annex showing HS classification (2017). Accessed: 2026-02-13. (外務省)
  • [CPTPP-PSR] CPTPP PSR annex showing HS Classification (HS2012). Accessed: 2026-02-13. (MITI FTA)
  • [RCEP-PSR-HS2022] RCEP transposed PSR in HS2022, implemented from 1 Jan 2023 (confirm by Party/date). Accessed: 2026-02-13. (ニュージーランド税関)

Internal working files used for this guide

  • Template: HS2022_Chapter_Template_v1.1.md
  • Disclaimer text: Disclaimer_v1.1.txt
  • Regulatory checklist notes (JP): JP_Regulatory_Notes.md
  • Sources index (curation scaffold): Sources_Index.md
  • FTA HS edition mapping scaffold: FTA_HS_Edition_Map.md

Disclaimer (MUST BE INCLUDED VERBATIM; DO NOT MODIFY)

This material is provided for general informational purposes regarding HS classification, customs clearance, FTA/EPA rules of origin, and import/export regulations. It does not constitute legal advice, tax advice, customs advice, or a definitive classification ruling for any specific transaction. Final HS classification is determined by the customs authority of the importing/exporting country, and classification outcomes may differ for the same or similar products depending on specifications, composition, end-use, form, degree of processing, commercial reality, documentation, and other transaction-specific facts. Tariff rates, origin rules, import/export regulations, permits, and inspec change due to legal amendments or administrative updates; you must always verify the latest official laws, regulations, public notices, and agreement texts. For important transactions, you should consider using the customs advance ruling system and/or consulting qualified professionals (customs brokers, attorneys, tax advisors) and conduct appropriate verification before making decisions. The author assumes no liability for any damages arising from the use of, or inability to use, this material.

Appendix A. Key national tariff line subdivisions in Japan (optional)

  • Japan’s tariff schedule further subdivides HS headings/subheadings into national tariff line codes / national codes for duty/statistics and operational control. (本州税関)
  • Practical tip for Chapter 4: lock the correct HS6 first (0401–0410), then determine the correct Japan national code for the declaration date (often driven by form, fat %, intended use, or detailed product type). (本州税関)

Appendix B. How to find customs advance rulings / decisions (optional)

  • Japan Customs offers an advance ruling on classification so traders can obtain an official view before importation. (本州税関)
  • Practical steps (general):
    • Prepare a product file: COA/specs (fat %, moisture, lactose %, whey protein %), ingredients list, photos/labels, process flow (e.g., fermentation, drying, concentration).
    • Submit an inquiry through the Japan Customs advance ruling channel and retain the written response for your compliance file. (本州税関)

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