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15161000
ANIMAL, VEGETABLE OR MICROBIAL FATS AND OILS AND THEIR CLEAVAGE PRODUCTS; PREPARED EDIBLE FATS; ANIMAL OR VEGETABLE WAXESAnimal, vegetable or microbial fats and oils and their fractions, partly or wholly hydrogenated, inter-esterified, re-esterified or elaidinised, whether or not refined, but not further prepared

Animal fats and oils and their fractions

Classification of hydrogenated animal fats

CN code 151610 covers animal fats and oils and their fractions, partly or wholly hydrogenated, inter-esterified, re-esterified, or elaidinised, whether or not refined, but not further prepared. Hydrogenation is a chemical process involving saturation of double bonds in fatty acids with hydrogen in the presence of a catalyst, increasing the hardness and melting point of the fat. Products under this heading include hydrogenated tallow, hydrogenated fish fat, and other chemically modified animal fats. Classification requires confirmation that the fat has undergone the chemical modification specified in the tariff heading. These products are used in the food, oleochemical, and technical industries.

Regulatory requirements for trans fats

Partial hydrogenation of fats leads to the formation of trans fatty acid isomers, which pose health risks. Regulation (EU) 2019/649 sets the maximum level of industrially produced trans fatty acids in food intended for the final consumer and food supplied for retail at 2 grams per 100 grams of fat. This restriction does not apply to naturally occurring trans fats in animal fats. Hydrogenated fats are also subject to Regulation (EC) No 1069/2009 on animal by-products if the raw material is animal waste. Labelling must indicate that the product is partly or wholly hydrogenated.

Import and trade practice

When declaring hydrogenated animal fats, CN code 151610 should be indicated with a certificate of analysis confirming the degree of hydrogenation, melting point, and fatty acid profile. Veterinary documentation is required if the raw material originates from animal by-products. Import is subject to controls at approved border control posts. In 2026, the market for hydrogenated fats is declining due to trans fat regulations and changing consumer preferences. Food manufacturers are increasingly replacing partially hydrogenated fats with alternative technological solutions. Fully hydrogenated fats, which do not contain trans acids, may continue to find industrial applications.

Hydrogenated animal fats CN 1516 10 - EU import rules

Hydrogenated animal fats and oils under CN 1516 10 carry a conventional duty of 10.9%. These products must comply with EU veterinary requirements and undergo border controls through the TRACES system. A veterinary health certificate from an approved third country is mandatory. Entry is permitted only through designated Border Control Posts (BCPs). Import VAT applies at the national rate upon clearance.

Frequently asked questions

What trans fat limits apply in the EU?
Regulation (EU) 2019/649 sets the maximum level of industrial trans fatty acids at 2 grams per 100 grams of fat in consumer food. The limit does not apply to naturally occurring trans fats in animal fats. Partially hydrogenated fats are the main source of industrial trans fats.
Does fully hydrogenated fat contain trans fatty acids?
Fully hydrogenated fat contains minimal amounts of trans fatty acids, as complete hydrogenation eliminates double bonds. Trans isomers are mainly formed during partial hydrogenation. Fully hydrogenated fats can therefore more easily comply with EU trans fat limits.
Does hydrogenated fish fat require veterinary control?
Yes, if the raw material is fish fat subject to fishery product regulations. Importing hydrogenated fish fat requires a health certificate, registration in TRACES NT, and controls at an approved border control post in accordance with EU official controls legislation.
What veterinary controls apply to hydrogenated animal fats CN 1516 10?
Hydrogenated animal fats CN 1516 10 require pre-notification in TRACES, a veterinary health certificate from the country of origin, and entry through a designated Border Control Post. Documentary, identity and physical checks are performed.