Quorn mycoprotein nuggets HTS 2106.90.9995: why CBP chose food prep, not meat
GRI 1CBP classified frozen Quorn Nacho Nuggets — breaded mycoprotein 'imitation meat' — under HTS 2106.90.9995 at 6.4% ad valorem, treating them as a food preparation not elsewhere specified rather than any meat or poultry preparation.
The obvious instinct is to file a breaded 'nugget' like a chicken nugget, which would push you toward the meat-preparation headings of Chapter 16 (for example 1602 for prepared meat). That's exactly what CBP did NOT do here, and the reason is the base ingredient. The nugget is roughly 49% mycoprotein — a fungus-derived protein — with no meat or poultry in it at all. Chapter 16 covers preparations of meat, fish or seafood, so a meat-free product has no home there. Heading 2106 is the residual bucket for edible preparations not specified or included elsewhere, and a further-processed, multi-ingredient mycoprotein food built for retail sits squarely in it. Under GRI 1 the terms of the headings decide it: no meat means no Chapter 16, and 2106.90.9995 catches it as 'other…frozen.' Final classification depends on the importer's actual product and should be confirmed by a licensed customs broker.
- Confirm the true protein base on your BOM — a mycoprotein or soy/pea base points to 2106, not the meat chapters.
- Check whether your product ships and sells frozen; the 2106.90.9995 statistical breakout is specifically the frozen line.
- Verify current Chapter 99 status and any exclusions for UK origin before you budget landed cost, since 6.4% is the base MFN rate only.
| Path | Code | Base duty |
|---|---|---|
| Path CBP used — food preparation n.e.s.i. | 2106.90.9995 | 6.4% |
| Alternative path (illustrative only, if the product actually contained poultry) illustrative | 1602.32 | varies by subheading |
| On a $60,000 shipment of frozen nuggets, the base 6.4% duty under 2106.90.9995 is about $3,840. The 1602.32 figure is purely hypothetical — it would only be in play if the product genuinely contained poultry, which this one does not, so treat any comparison as illustrative and don't assume a lower rate. Any Chapter 99 add-on is a separate variable: this math is base-rate only and assumes UK origin remains subject to whatever measure applies at entry, so verify current Chapter 99 status and exclusions. | ||
Illustrative comparison only. The alternative heading is one contrast possibility — the exact subheading for a different product configuration would need separate analysis (other Chapter 84/85 or specific provisions may apply). Any Section 301 / Chapter 99 figure assumes the goods remain subject to that measure at the time of entry; always verify the current Chapter 99 status and any applicable exclusions.
- Calling it a 'nugget' on paperwork invites a meat-chapter assumption; the entry language should make the mycoprotein base clear.
- Any reformulation that adds real meat or poultry could move it out of 2106 entirely.
- Duty rates and Chapter 99 measures change — the 6.4% cited is the general rate at ruling date and needs re-checking at entry.
- Reformulate with actual chicken or pork in the nugget → Likely moves to a Chapter 16 meat-preparation heading such as 1602, out of 2106.
- Import chilled/shelf-stable instead of frozen → Still 2106.90.99 likely, but a different statistical suffix than the frozen '95' breakout.
- Sell as an uncoated mycoprotein block rather than a breaded finished nugget → Still probably 2106 as a food prep, but the analysis shifts and a fresh ruling is worth confirming.
The lesson from this one is simple: the coating and the shape don't classify the product, the protein base does. A breaded 'nugget' that reads like chicken on the shelf is a heading 2106 food preparation the moment you confirm there's no meat in it. Read the BOM, not the marketing.
- Full ingredient breakdown showing the protein base and its percentage (mycoprotein vs any meat).
- Statement confirming the product contains no meat, fish or poultry.
- Frozen vs chilled shipping condition, since it drives the statistical suffix.
- Retail packaging photo and net weight per unit.
- Cooking/use instructions that show it's a finished consumer food.
- Origin documentation and a current Chapter 99 review for UK-origin goods.
Why are Quorn mycoprotein nuggets classified under HTS 2106.90.9995 and not as chicken nuggets?
In this case CBP classified them under 2106.90.9995 because the product is built on mycoprotein and contains no meat, so the meat-preparation headings don't apply. Your own product's classification should be confirmed with a licensed customs broker.
What is the duty rate on frozen imitation meat nuggets under HTS 2106.90.9995?
The ruling states a general rate of 6.4% ad valorem at the date of issue. Rates change, so verify the current HTSUS and any Chapter 99 measures before you rely on it.
Would a meat-free nugget ever fall under Chapter 16?
Chapter 16 covers preparations of meat, fish or seafood. A product with no meat generally has no home there, which is why this mycoprotein nugget landed in heading 2106. Any product that actually contains meat could be a different story.
Does Section 301 apply to these UK-origin nuggets?
Section 301 China tariffs turn on Chinese origin, so UK-origin goods aren't covered by that measure. Still confirm current Chapter 99 status and any other trade measures for UK-origin food at time of entry.
Does the vegan cheese coating change the HTS classification?
In this ruling the breader, batter and predust were part of the finished food but didn't move it out of heading 2106 — the mycoprotein base drove the outcome. Composition changes can shift classification, so re-check if you reformulate.
Can I use ruling N344354 for my own plant-based nugget entry?
It's a useful guide for similar meat-free products, but a CROSS ruling applies to the specific goods it describes. For your own product, have a licensed customs broker confirm the classification against your actual BOM.