Caviar substitutes

Caviar substitutes prepared from fish eggs

FSSAI CLEARANCE · AQCS CLEARANCE

HSN 1604 32 00 (Caviar substitutes) is subject to Food Safety and Standards Authority of India (FSSAI) Import Licence and mandatory foreign-manufacturer registration under the Food Safety and Standards Act, 2006, as a high-risk fish product. Animal Quarantine and Certification Services (AQCS) Sanitary Import Permit clearance applies concurrently, and consignments are permitted only through 79 designated food-import ports with effect from 1 March 2023.

What this is

HSN code

1604 32 00

Chapter

16 · Preparations of meat, fish or crustaceans, molluscs or other aquatic invertebrates

Primary regulator

FSSAI · Food Safety and Standards Act, 2006 (high-risk food regime)

Customs documentation

Import Licence from FSSAI
Sanitary Import Permit from AQCS
Health Certificate from AQCS

Applicable Partner Government Agencies

FSSAIFSSAI·Food Safety and Standards Authority of India

AQCSAQCS·Animal Quarantine and Certification Services

Procedural directions for customs clearance are issued by: Directorate General of Foreign Trade, Central Board of Indirect Taxes and Customs.

Compliance steps

1
Confirm the foreign manufacturing facility is registered with the Food Safety and Standards Authority of India under the high-risk-food regime covering fish and fish products. The FSSAI Import Licence (document code 911001) and the Specimen Copy of Label (document code 0110FS) must be uploaded in e-Sanchit before filing the bill of entry.
CBIC Instruction 30/2022-Cus dated 14-11-2022 · FSSAI order dated 10-10-2022
2
Obtain the AQCS Sanitary Import Permit (document code 911DF1) and Health Certificate (document code 6360AQ) prior to dispatch. At the bill of entry, quote the e-Sanchit IRN of the Sanitary Import Permit to obtain the AQCS NOC for CTIs listed in Annexure A (Sl. No. 3) of CBIC Circular 24/2022-Cus.
CBIC Circular 24/2022-Cus dated 28-11-2022 · CBIC Instruction 09/2023-Cus dated 07-03-2023 · FSSAI clarification order dated 18-11-2022
3
Route the consignment exclusively through one of the 79 designated food-import ports under General Note 4(D) of Schedule I of the ITC (HS) 2022. Verify label compliance with the FSSAI rectifiable-labelling regime before seeking out-of-charge; non-rectifiable labelling defects are grounds for detention.
CBIC Instruction 05/2023-Cus dated 08-02-2023 · CBIC Instruction 10/2022-Cus dated 28-06-2022 · FSSAI Letter 1828/Misc Matters/FSSAI/Imports-2021 dated 17-06-2022

A word of counsel

The most common error on this tariff line is treating the FSSAI Import Licence as the sole clearance document and neglecting the AQCS Sanitary Import Permit as a separate, independent requirement. A consignment carrying a current FSSAI licence but lacking the AQCS NOC — evidenced by the 911DF1 IRN quoted on the bill of entry — will be detained at the designated port, accruing demurrage and ground rent, with no option to regularise the missing PGA clearance retrospectively without re-routing the permit application.

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Frequently asked

Does HSN 1604 32 00 require BIS certification?

No, caviar substitutes prepared from fish eggs fall outside the BIS Quality Control Order regime; no BIS QCO covers this product family. Import is governed by the Food Safety and Standards Authority of India under the Food Safety and Standards Act, 2006, with a concurrent AQCS Sanitary Import Permit requirement and a 79-designated-port restriction operative from 1 March 2023.

Which ports are designated for import of caviar substitutes under this tariff line?

Import is permitted only through the 79 designated food-import ports listed in the Annexure to CBIC Instruction 05/2023-Cus dated 08-02-2023, in accordance with General Note 4(D) of Schedule I of the ITC (HS) 2022; consignments arriving at any other port are liable to detention and re-export.

Is foreign-manufacturer registration with FSSAI mandatory before shipment?

Yes. Per CBIC Instruction 30/2022-Cus and the FSSAI order dated 10 October 2022, the overseas facility manufacturing fish products for export to India must be registered with FSSAI before the import is permitted; shipments from unregistered facilities will not receive out-of-charge.

Last verified against gazette notifications: 2026-05-16. Source: FSSAI / AQCS / DGFT / CBIC / Indian Customs CUSDATA.