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15162000
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

Vegetable fats and oils and their fractions

Classification of hydrogenated vegetable oils

CN code 151620 covers vegetable 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 of vegetable oils is a chemical process where unsaturated fatty acid bonds are saturated with hydrogen in the presence of a nickel catalyst. Products include hydrogenated palm oil, soybean oil, rapeseed oil, and other chemically modified vegetable oils. Full hydrogenation produces hard fats with high melting points, while partial hydrogenation yields semi-solid fats. Inter-esterification rearranges fatty acids between glycerol molecules, modifying the physical properties of fat without creating trans acids.

Trans fat regulations and safety

Partially hydrogenated vegetable oils are the main source of industrially produced trans fatty acid isomers, linked to cardiovascular disease risk. Regulation (EU) 2019/649 limits industrial trans fatty acid content to 2 grams per 100 grams of fat in food intended for the final consumer. EU food manufacturers increasingly use inter-esterification as an alternative to partial hydrogenation, as this process does not generate trans fatty acids. Import of hydrogenated vegetable oils requires documentation confirming compliance with trans fat limits. Labelling must indicate the type of chemical modification. Hydrogenated oils for biodiesel production are subject to different requirements than food-grade oils.

Import and trade practice in 2026

Importers of hydrogenated vegetable oils should indicate CN code 151620 in customs declarations with a certificate of analysis confirming product parameters including degree of hydrogenation, melting point, fatty acid profile, and trans acid content. Major exporters include Malaysia and Indonesia for hydrogenated palm oil, and South American countries for hydrogenated soybean oil. Hydrogenated palm oil imports are subject to EUDR deforestation requirements. Solid fats are transported in cartons, drums, or big bag containers. In 2026, the hydrogenated fat market is evolving toward inter-esterified products that meet trans fat regulatory requirements.

Hydrogenated vegetable oils CN 1516 20 - EU trans fat rules

Hydrogenated vegetable oils under CN 1516 20 carry a conventional duty of 5.1%. Since 2021, EU Regulation 2019/649 limits industrial trans fats to 2 g per 100 g of fat in food. Importers must provide documentation confirming compliance with this limit. These oils are used in margarine, confectionery and bakery production. A BTI ruling can clarify classification for partially hydrogenated products.

Frequently asked questions

Is hydrogenated palm oil subject to EUDR?
Yes. Hydrogenation is a chemical modification of palm oil, but the source product still originates from oil palm. The EUDR Regulation (EU) 2023/1115 covers palm oil and its derivatives, including hydrogenated products. The importer must submit a due diligence statement.
What is the difference between inter-esterification and hydrogenation?
Inter-esterification rearranges fatty acids between glycerol molecules without changing the degree of saturation, so trans fatty acids are not formed. Hydrogenation saturates double bonds with hydrogen, and partial hydrogenation generates trans isomers.
What trans fat limits apply to hydrogenated oils in food?
Regulation (EU) 2019/649 sets a maximum of 2 grams of industrial trans fatty acids per 100 grams of fat in food for the final consumer. Fully hydrogenated oils have negligible trans levels, but partially hydrogenated oils may exceed this limit.
What is the EU trans fat limit for hydrogenated oils CN 1516 20?
EU Regulation 2019/649 limits industrial trans fats to 2 g per 100 g of fat in food products. Hydrogenated vegetable oils CN 1516 20 exceeding this limit cannot be placed on the EU market for food use.