A practical decision‑tree and checklist for classifying Indonesian breaded/battered squid and cuttlefish under HS across BTKI, HTSUS and EU/UK CN. We cover 0307 vs 1605, what counts as “prepared,” par‑fry and raw‑inside scenarios, the 10% myth, and the invoice wording and proofs customs actually look for.
If there’s one HS question we hear every week, it’s from buyers wrestling with breaded squid. Is it Chapter 03 or Chapter 16? Does par‑frying matter? What if the squid is still raw inside? We’ve classified thousands of Indonesian shipments, and the rules are clear once you know how customs thinks.
Here’s the bottom line. Unprepared squid and cuttlefish live in Chapter 03 (0307). As soon as you “prepare” them with batter, breadcrumbs, spices, marinade or a par‑fry, they move to Chapter 16. In practice, breaded squid rings and cuttlefish karaage classify under the “prepared molluscs” bucket: HS 1605 “Molluscs, prepared or preserved” and, more specifically, the cuttlefish/squid subheading.
0307 vs 1605 in one minute
- 0307: Molluscs, live, fresh, chilled, frozen, dried, salted or in brine. No substantive preparation. Cleaning, cutting into rings, glazing, or IQF freezing doesn’t change this.
- 1605: Molluscs, prepared or preserved. Breaded, battered, seasoned, marinated, cooked or par‑fried. Whether the meat inside is raw doesn’t change the chapter.
Across the big three tariff books you’ll use:
- Indonesia BTKI: Prepared cuttlefish/squid are classified in heading 1605, subheading for “cuttlefish and squid.” Current editions map to 1605.54.00. Some older or misquoted references show BTKI 1605.52, which causes confusion. Verify the current BTKI text in your filing system.
- United States HTSUS: 1605.54 for cuttlefish and squid. Ten‑digit lines depend on packaging and other specifics.
- EU/UK CN: 1605 54 00 for cuttlefish and squid, prepared or preserved.
If your product truly has zero preparation beyond freezing or brining for preservation, you’re in 0307 (commonly 0307.49 for frozen squid/cuttlefish). But once coatings or par‑frying appear, think 1605. This leads us to the decision path.
A quick decision‑tree you can use today
- Is there any coating or seasoning on the squid/cuttlefish?
- No. Go to 0307.
- Yes. Continue.
- Is it only a light, functional predust of plain flour or starch, used to prevent sticking, with no spices or flavorings, not par‑fried, and typically under 5–8% of product weight?
- Yes. Likely 0307. Keep lab/production evidence. Continue to documentation.
- No. Continue.
- Is there batter and/or breadcrumbs, spice blends, marinades, tempura mix, karaage coating, or any par‑frying or full cooking step?
- Yes. 1605. In BTKI: 1605.54.00. In HTSUS: 1605.54. In EU/UK CN: 1605 54 00.
- Not sure. Gather evidence and seek a binding ruling. But assume 1605 until proven otherwise.
Practical takeaway: Customs cares more about the “preparation” than whether the center is raw. Breaded raw‑inside rings are still “prepared.”
The most common questions we get
Is breaded or battered squid always HS 1605 even if the meat is raw inside?
Yes. The act of breading/battering is a preparation. Raw interior doesn’t pull you back to 0307.
What proof do officers expect to accept 1605.54 (or BTKI 1605.54.00) for breaded rings?
Our files that clear smoothly include:
- Full ingredient breakdown with percentages, including batter pickup and oil uptake if par‑fried.
- Production flow diagram showing coating and any thermal step.
- Photos of finished product and a cross‑section.
- Specification sheet and label copy matching the invoice.
- QA records or a simple lab sheet confirming coating percentage and moisture.
If you don’t have percentages, expect questions. We keep these on file by SKU and it prevents 9 out of 10 holds.
Does a light predust (flour only) move squid from 0307 to 1605?
Not necessarily. A functional, plain flour or starch dusting at very low pickup, not par‑fried, and without flavoring is often accepted as 0307. But here’s the catch. Once you add spices, leavening, or meaningful pickup, most customs call it 1605. When in doubt, weigh it. If predust exceeds roughly 5–8% and affects taste or texture, prepare for 1605 classification.
How do I classify par‑fried squid rings versus fully cooked breaded squid?
Both are 1605. Par‑frying is a preparation step. Fully cooked remains 1605. Your invoice should say “par‑fried” or “fully cooked” and note oil uptake if you have it. That detail shortens reviews.
Which code applies to cuttlefish karaage from Indonesia—0307 or 1605?
Karaage involves a seasoned batter and usually a par‑fry. That is 1605. Use BTKI 1605.54.00, HTSUS 1605.54, and EU/UK CN 1605 54 00.
If batter is under 10% of weight, can I still use 1605?
Yes. There is no global “10% rule.” A small but flavorful or texturally meaningful coating is still a preparation. In our experience, under 5% plain predust can stay 0307 if it’s truly functional. Anything that’s clearly a breading or flavored batter goes to 1605, even at 6–8%.
What should the commercial invoice description include to avoid a CF‑28/verification hold?
Use a plain‑English, specific line. Two examples that work:
- “Frozen breaded squid rings, par‑fried in vegetable oil, raw‑internal, batter 32% by weight, IQF, retail packs 1 kg. HS 1605.54. Country of origin Indonesia.”
- “Frozen squid rings, predusted with wheat flour 3% by weight, no seasoning, not par‑fried, IQF bulk 10 kg. HS 0307.49. Country of origin Indonesia.”
Consistency between invoice, spec, and label is half the battle. We also attach the ingredient sheet on first shipments so customs doesn’t need to ask. This leads us to documentation.
Your compliance checklist for breaded squid shipments
- Ingredient breakdown with percentages, including coating and oil uptake if par‑fried.
- Process flow showing coating and any heat step.
- Photos of finished goods and cross‑section.
- Product spec sheet and label copy matching the invoice description.
- Packaging type and pack size. Airtight canning triggers different 10‑digit lines in some jurisdictions.
- Clear HS line per destination: BTKI 1605.54.00, HTSUS 1605.54, EU/UK CN 1605 54 00.
- For unprepared products, cite 0307 with the correct 8‑ or 10‑digit line for squid/cuttlefish and state “no seasoning/coating.”
In my experience, when those seven items are attached to the first two or three shipments, the file goes green next time. And if you’re ever challenged, you’ve got the facts at hand.
EU, US and Indonesia mapping at a glance
- EU/UK CN: Breaded or tempura squid and cuttlefish go to 1605 54 00. Rings, strips, tentacles, karaage. Raw‑inside or cooked, both fit.
- HTSUS: Breaded/battered squid and cuttlefish are under 1605.54. Ten‑digit lines vary by container type and other specifics. Your broker will finalize the suffix.
- BTKI: Use 1605.54.00 for prepared cuttlefish and squid. We still see “BTKI 1605.52” printed on some old templates. Update those. It invites questions.
If you’re shipping raw materials for a buyer to bread at destination, that’s 0307. In our catalogue, Loligo Squid (Whole Round / Whole Cleaned) is a typical 0307 item. Specify “no seasoning, no coating” on the invoice and include a simple spec. That small tweak avoids over‑classification or surprises at the border.
Trends we’re seeing this year
We’ve noticed more verification requests on coating percentages and par‑fry claims, particularly into the US and EU. Brokers tell us it’s driven by enforcement swings and data‑matching. Our advice. Put the percentages on paper, and keep photo evidence of the coating step. It turns a two‑week hold into a two‑hour email.
Need help with your specific SKU or invoice wording? You can Contact us on whatsapp, and we’ll sanity‑check your classification and documentation.
Common mistakes we fix all the time
- Using 0307 for tempura or karaage because the center is raw. The coating makes it 1605.
- Vague invoice lines like “Frozen squid.” That invites a hold. Spell out coating and process.
- Assuming a “10% coating rule.” It’s not a universal standard.
- Forgetting to update BTKI to 1605.54.00 for prepared squid/cuttlefish. Old 1605.52 references still float around.
- Leaving out the ingredient percentages. Officers don’t guess. They ask.
Quick takeaways you can use immediately
- Breaded, battered, seasoned or par‑fried squid/cuttlefish. Classify under 1605.54 (EU/UK CN 1605 54 00. BTKI 1605.54.00).
- Plain predust under roughly 5–8%, no seasoning, no par‑fry. Often remains 0307, but document it.
- Put coating percentage and processing steps on the invoice and spec. Add photos on first shipments.
- Align your HS line across documents and update any old templates referencing BTKI 1605.52.
We’ve helped buyers clean up classifications that were causing repeated holds. The pattern is always the same. Clear description, clear percentages, and the right chapter. If you want to see how we structure specs on raw squid items before value‑adding, browse our Loligo Squid (Whole Round / Whole Cleaned) listing or View our products for format ideas. Then tailor the same clarity to your breaded SKUs. Your customs broker will thank you, and so will your lead times.