Complete Practical Guide to Importing Squid into Japan

HS Classification, Import Quotas, and Seafood Legality Compliance

Contents

HS Classification, Import Quotas, and Seafood Legality Compliance

Executive Summary and Key Takeaways
Common Judgment Errors in Practice
The Three Key Decision Axes for Squid Imports
Practical Import Decision Flow (Simplified)
Import Quota Procedures and Customs Clearance Flow
- Practical Steps for HS Chapter 03 Raw Squid
- Key Points for HS 1605 Prepared Squid Products
Seafood Legality Compliance Checklist
- Mandatory Items
- Practical Tips
Common Compliance Failures
Practical Summary
Practical Q&A
References

Executive Summary and Key Takeaways

When importing squid into Japan, it is critical to understand that all squid imports—whether raw materials or processed products—are subject to Japan’s seafood legality and traceability framework, commonly referred to as the Seafood Distribution Properness Scheme (Japan’s IUU control regime).

While import quota (IQ) regulations apply only to raw squid classified under HS Chapter 03, processed squid products under HS 1605 are not exempt from compliance. For commercial imports, importers are generally required to verify and submit documentation proving lawful harvesting, such as Catch Certificates and Processing Statements.

In practice, many importers mistakenly assume that “non-quota items require no procedures.” Failure to comply with seafood legality requirements can directly lead to customs clearance suspension, corrective orders, or even termination of ongoing trade relationships.

Therefore, the fundamental rule in squid import operations is to assess the following three elements together:

HS classification
Applicability of import quota regulations
Applicability of seafood legality and traceability requirements

Common Judgment Errors in Practice

In day-to-day import operations, the following mistakes are frequently observed:

Assuming that processed products are exempt from both import quotas and legality compliance, and importing without certificates
Mixing frozen raw squid and heat-processed products in one shipment and handling HS classification and compliance collectively
Believing that Catch Certificates apply only to raw materials, and clearing processed products without documentation

The reason there is no single, uniform answer is that squid imports are subject to multiple overlapping regulatory regimes, depending on their physical state, degree of processing, and intended use.

Since 2022 in particular, seafood legality compliance has become a baseline requirement, making the former approach of “checking quotas only” no longer sufficient.

The Three Key Decision Axes for Squid Imports

Decision Axis 1: HS Classification and Import Quotas (Traditional Focus)

Category	Main HS Chapter	Import Quota	Practical Position
Fresh / Frozen Raw Squid	HS Chapter 03	Applicable	Import quota approval generally required for commercial imports
Prepared / Processed Squid	HS 1605	Not applicable	No quota required, but other regulations apply

Up to this point, traditional understanding remains valid.

Decision Axis 2: Applicability of Seafood Legality Regulations (Most Critical in Recent Years)

Squid is designated as a regulated aquatic species under Japan’s seafood legality and traceability framework, which aims to prevent IUU (Illegal, Unreported, and Unregulated) fishing.

Key points:

Coverage is not limited to HS Chapter 03
Processed products under HS 1605 are also included
Commercial imports are generally required to comply

👉 The assumption that “non-quota items are exempt from seafood legality requirements” is incorrect.

Decision Axis 3: Practical Compliance by Import Type

Import Type	Import Quota	Seafood Legality Compliance	Practical Assessment
HS 03 Raw Squid (Commercial)	Required	Required	Most heavily regulated
HS 1605 Processed Squid (Commercial)	Not required	Required	Frequently overlooked
Small-Quantity Samples	Generally not required	Case-by-case	High risk if later converted to commercial use

Practical Import Decision Flow (Simplified)

Confirm product form: fresh/frozen raw material or processed product
Confirm import purpose: sample or commercial
Verify HS code (Chapter 03 or HS 1605)
Check import quota requirements (HS 03 only)
Confirm seafood legality compliance (Catch Certificate, COO, etc.)
Submit customs declaration, verify duties, labeling, and documentation

Import Quota Procedures and Customs Clearance Flow

Practical Steps for HS Chapter 03 Raw Squid

Step	Practical Notes
Import Quota Application	Filed with Japan Customs (under Ministry of Finance). Application deadline is typically ~2 weeks before the planned import date. Required documents include sales contract, planned quantities, and Certificate of Origin (COO).
Customs Declaration	Declare under HS Chapter 03 within approved quota limits. Quota approval number must be attached.
Inspection & Approval	Quantity, quality, and origin are verified at clearance. Catch Certificate and legality checks are conducted.

Risk: Exceeding quota limits results in denial of clearance and potential additional duties (often ranging from hundreds of thousands to millions of yen).

Key Points for HS 1605 Prepared Squid Products

Small sample imports may, in limited cases, be exempt from full HS coding
For commercial imports, HS classification must reflect processing level, packaging, and heat treatment
Commercial imports require submission of a Catch Certificate and Processing Statement under the seafood legality framework
Errors in labeling or duty rates may require post-clearance corrections

Seafood Legality Compliance Checklist

Mandatory Items

Catch Certificate
Verification of legality of harvesting country and fishing area (e.g., ICCAT, CCAMLR compliance)
Confirmation of compliance with Japanese domestic regulations (e.g., protected or endangered species)

Practical Tips

Obtain and verify Catch Certificates before shipment
Maintain a shared checklist with exporters and trading partners

Common Compliance Failures

Converting sample imports into commercial sales → clearance suspension and reputational damage
Incorrect HS code declaration → additional duties and statistical discrepancies
Missing Certificate of Origin (COO) → legality compliance violations
Misclassification due to mixed shipments → raw and processed products declared under one HS code

Practical Summary

For squid imports, the following three checks must always be performed together:

HS classification (Chapter 03 or HS 1605)
Applicability of import quota regulations
Applicability of seafood legality and traceability requirements

Particular caution is advised in the following cases:

First-time sourcing countries
New products with ambiguous processing levels
Conversion from samples to commercial imports

In such cases, prior consultation with a licensed customs broker or trade compliance specialist is strongly recommended.

Practical Q&A

Q1. Are processed squid products (HS 1605) subject to seafood legality compliance even if they are not subject to import quotas?

A. Yes. Commercial imports are generally required to comply.
Squid is a regulated species under Japan’s seafood legality framework. Regardless of whether the product is raw (HS 03) or processed (HS 1605), importers are required to verify lawful harvesting. Even non-quota items require Catch Certificates and Processing Statements.

Q2. Are Catch Certificates required for “processed” or “heat-treated” squid?

A. In most cases, yes.
The presence or absence of processing or heat treatment does not affect applicability. Even for prepared products, documentation proving lawful harvesting of the raw squid and a Processing Statement describing the manufacturing process are typically required.

Q3. Do small-quantity sample imports fall under seafood legality regulations?

A. In principle, yes, but treatment depends on whether the import is non-commercial.
Imports strictly for testing or evaluation may be simplified. However, if samples are later diverted to commercial sale, the risk of regulatory violations is high. In practice, obtaining documentation from the outset is recommended.

Q4. Can Catch Certificates issued for EU exports be used for Japanese import procedures?

A. In some cases, yes, but content verification is essential.
If the EU-issued certificate contains all information required under Japan’s system—such as fishing country, fishing area, quantity, and processing details—it may be accepted. Otherwise, reissuance or supplemental documentation will be required.

Q5. How should compliance be handled when importing frozen raw squid and processed products together?

A. Each product must be handled separately.
Frozen raw squid (HS 03) is subject to both import quotas and seafood legality compliance, while processed products (HS 1605) are not subject to quotas but still require legality compliance. Mixed shipments must clearly separate HS codes, certificates, and declarations to avoid clearance delays.

Q6. What are the risks if non-compliance with seafood legality requirements is discovered?

A. Risks extend beyond customs suspension and can affect ongoing trade.
Deficiencies may result in clearance suspension, corrective orders, and additional document submissions. Repeated or serious violations can damage supplier credibility and disrupt future import operations.