Looking for expert help with Seafood GST rate and HSN code? The team at Tax Garden, based in Kondapur, Hyderabad, helps Indian SMEs stay compliant. End-to-end filings, notices, and deadline tracking, all in one place.
Key Takeaways
- Fresh or chilled fish is nil GST. Frozen, dried or salted fish and shrimp are nil in bulk and 5% when pre-packaged and labelled (Notifications 10/2025 and 9/2025-CT(R)).
- Prepared or preserved fish and shrimp (1604, 1605), fish oil and fish meal are 5%. Cartons are 5%; plastic packing and freezing equipment are 18%.
- Exports are zero-rated. Even for nil-rated frozen fish, you can export under LUT and get a refund of credit on packing, chemicals and services (IGST Act Section 16).
- Cash to fishermen above Rs 10,000 a day is allowed when you buy from the producer (Rule 6DD(e)(iii); Rule 26(1)(e)(iii) of the 2026 Rules).
- Large buyers deduct 0.1% TDS on fish purchases above Rs 50 lakh from one seller (Section 194Q; Section 393(1) Sl. No. 8(ii) of the 2025 Act).
What is the GST rate on frozen fish and frozen shrimp? Frozen fish, fillets and frozen shrimp (HSN 0303, 0304, 0306) are nil-rated when not pre-packaged and labelled (Notification 10/2025-CT(R), S. No. 14). Pre-packaged and labelled packs of up to 25 kg meant for retail sale attract 5% GST (Notification 9/2025-CT(R), Schedule I, S. No. 3). Fresh or chilled fish is nil in any pack.
A seafood plant in Visakhapatnam, Nellore, Kochi, Veraval or Bhimavaram usually does three things at once. It buys shrimp and fish from farmers, landing centres and fishermen, often in cash. It peels, grades, freezes and packs them. And it ships most of the output abroad while selling some packs in India. Each step has its own GST and income tax rule, and most of the money is in two places: the export refund and the cash-purchase rules. This post covers FY 2025-26 (AY 2026-27) under the Income-tax Act 1961, with the Income-tax Act 2025 sections that apply from 1 April 2026. It's for owners and accountants of seafood processing plants, exporters and fisheries co-operatives. If you farm fish rather than process it, our fish farming and aquaculture guide is the better fit.
What GST rate applies to your seafood and your inputs?
The rate turns on two questions: is the fish fresh or processed, and is it pre-packaged and labelled? The rates below are the ones in force since 22 September 2025.
Tax Rate Chart
GST for Seafood Processors (from 22 September 2025)
Live fish (0301); fresh or chilled fish and fillets (0302, 0304)
10/2025-CT(R) S. Nos. 11, 12, 13
Fresh or chilled shrimp, prawns, crabs, squid (0306, 0307)
10/2025-CT(R) S. No. 13
Frozen, dried or salted fish and shrimp, not pre-packaged (0303 to 0309)
10/2025-CT(R) S. No. 14
Frozen, dried or salted fish and shrimp, pre-packaged and labelled
9/2025-CT(R) Sch I, S. No. 3
Prepared or preserved fish, canned tuna, breaded shrimp (1604, 1605)
9/2025-CT(R) Sch I, S. Nos. 103, 104
Fish oil (1504) and fish meal (2301)
9/2025-CT(R) Sch I, S. Nos. 81, 153
Ice (2201 90 10) and paper cartons (4819 10, 4819 20)
9/2025-CT(R) Sch I, S. Nos. 147, 322
Plastic packing (3923) and freezers, plate freezers (8418)
9/2025-CT(R) Sch II, S. Nos. 124, 407
Source: CBIC Notifications 9/2025-CT(R) and 10/2025-CT(R), 17 September 2025, in force 22 September 2025; CT(R) list checked up to 01/2026-CT(R)
What "pre-packaged and labelled" means. The Explanation to Notification 9/2025-CT(R) defines it as goods "intended for retail sale" of not more than 25 kg or 25 litres, pre-packed under Section 2(l) of the Legal Metrology Act, 2009, where the pack must carry Legal Metrology declarations. Say you sell frozen prawns worth Rs 5,00,000 to a supermarket chain in 1 kg branded pouches. That's 5%, so Rs 25,000 GST. The same prawns sold in 30 kg bulk cartons to a hotel are nil.
Processed products. Once shrimp is cooked, marinated, breaded or canned, it moves to heading 1605 (or 1604 for fish), and the 5% applies in any pack. Classify by what the product is, not by what your buyer calls it.
Job work for others. If you peel, grade or freeze shrimp owned by a registered exporter, your charge is job work at 5% under S. No. 26(ii)(a) of Notification 11/2017-CT(R), as substituted by Notification 15/2025-CT(R). That item covers food products of Chapters 1 to 22. For an unregistered owner it isn't job work under Section 2(68) of the CGST Act, so item (vii) applies at 18%. Our cold storage guide covers storage charges separately.
Do you need GST registration if most of your fish is nil-rated?
Nil-only domestic sellers. Section 23(1)(a) of the CGST Act says a person "engaged exclusively in the business of supplying goods ... that are not liable to tax or wholly exempt" isn't liable to register. A trader selling only fresh fish and loose frozen fish in India can stay unregistered.
Exporters should register anyway. Without a GSTIN you can't file an LUT or claim a refund. Section 25(3) allows voluntary registration, and the refund on packing and service credit usually pays for the compliance cost several times over.
Selling 5% packs. A goods-only supplier can use the Rs 40 lakh limit under Notification 10/2019-Central Tax, except in Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Puducherry, Sikkim, Telangana, Tripura and Uttarakhand. Our registration limit guide has the detail, and our GST registration service files the application.
Composition won't work for exporters. Section 10(2)(c) bars anyone making inter-State outward supplies, and an export is an inter-State supply under Section 7(5)(a) of the IGST Act.
How do export refunds work for a seafood exporter?
Here's the part many plants leave on the table. Your output may be nil-rated, but your cartons, plastic liners, chemicals, freight, testing and clearing charges carry GST. Section 16(2) of the IGST Act says credit "may be availed for making zero-rated supplies, notwithstanding that such supply may be an exempt supply". So an exporter of nil-rated frozen shrimp can still take that credit and get it back.
Step-by-Step Guide
LUT Export Refund Cycle for a Seafood Exporter
File the LUT before you export
Furnish a Letter of Undertaking in Form GST RFD-11 on the GST portal for the financial year (Rule 96A(1), CGST Rules). Renew it every year before the first shipment.
Export without IGST
Raise the export invoice under LUT. Goods must leave India within three months of the invoice, and payment must come in within the FEMA period, or you pay the tax with interest (Rule 96A(1)).
Report in GSTR-1 Table 6A
Show each export invoice with shipping bill details. GSTR-1 data flows to Customs to confirm the goods left India (Rule 96A(2)).
Work out the refund
Rule 89(4): (Turnover of zero-rated supply of goods x Net ITC) / Adjusted Total Turnover. Net ITC covers inputs and input services, not capital goods.
File RFD-01 within two years
The two years run from the date the ship or aircraft carrying the goods leaves India (Section 54(1) and Explanation 2(a)).
Source: IGST Act Section 16; CGST Act Section 54; CGST Rules 89(4), 96 and 96A
Example: in one month a registered exporter ships frozen shrimp worth Rs 2,00,00,000 under LUT and sells 5% retail packs worth Rs 20,00,000 in India. GST credit on cartons, packing, chemicals, ice and services is Rs 6,60,000.
| Item | Amount |
|---|---|
| Turnover of zero-rated supply (exports under LUT) | Rs 2,00,00,000 |
| Adjusted total turnover (exports + domestic 5% sales) | Rs 2,20,00,000 |
| Net ITC (inputs and input services) | Rs 6,60,000 |
| Maximum refund: Rs 2,00,00,000 x Rs 6,60,000 / Rs 2,20,00,000 | Rs 6,00,000 |
| Credit left for domestic sales | Rs 60,000 |
| Output tax on domestic packs (5% of Rs 20,00,000) | Rs 1,00,000 |
| Balance payable in cash | Rs 40,000 |
Two limits to keep in mind. Rule 89(4) caps the export value at 1.5 times the value of like goods you sell in India, if that's lower. And if you also sell nil-rated fish in India, Rule 42 makes you reverse the credit linked to those domestic exempt sales before you work out Net ITC. Our ITC reversal guide explains the split.
The IGST route. You can also pay IGST on the export and have it refunded. Notification 01/2023-Integrated Tax allows this for all goods from 1 October 2023 except pan masala, some tobacco products and some mint oils, so seafood qualifies. Under Rule 96(1), the shipping bill itself is the refund claim once the export manifest is filed and your GSTR-3B is in. Our export of goods GST guide and LUT and RFD-01 guide go step by step.
E-invoicing. If your aggregate turnover crossed Rs 5 crore in any financial year since 2017-18, B2B and export invoices must be e-invoices (Notification 10/2023-Central Tax). See our e-invoicing guide.
Income tax for seafood processors and exporters
Cash paid to fishermen. Section 40A(3) of the 1961 Act disallows a cash payment above Rs 10,000 to one person in a day. Rule 6DD(e)(iii) lifts that bar where you pay for "fish or fish products" to the "cultivator, grower or producer". From 1 April 2026 the same rule is Section 36(4) of the 2025 Act with Rule 26(1)(e)(iii) of the Income-tax Rules 2026. Keep a purchase voucher with the fisherman's name, boat or landing centre, weight and rate. The exception doesn't cover a commission agent or a fish trader who buys and resells; pay them by bank. Our Section 40A(3) guide lists the other exceptions.
TDS on large fish purchases. If your turnover exceeded Rs 10 crore in the previous year, you deduct 0.1% on purchases from one seller above Rs 50 lakh in the year (Section 194Q of the 1961 Act; Section 393(1), Table Sl. No. 8(ii) of the 2025 Act from 1 April 2026). Say your plant buys Rs 80,00,000 of shrimp from one aqua farmer in FY 2026-27. TDS is 0.1% of Rs 30,00,000, so Rs 3,000. Our Section 194Q guide covers the timing, and our TDS filing service files the quarterly returns.
Section 44AD for smaller plants. A resident individual, HUF or partnership firm (not an LLP) can declare 6% of turnover received by bank, UPI or account payee cheque by the return due date and 8% of the rest, if turnover is up to Rs 2 crore, or Rs 3 crore where cash receipts stay within 5% (Section 44AD of the 1961 Act; Section 58(2), Table Sl. No. 1 of the 2025 Act). A proprietor with Rs 1,80,00,000 of turnover, all by bank, declares at least Rs 10,80,000. Our Section 44AD guide explains the five-year lock-out if you drop out.
Tax audit and due dates. Audit is needed above Rs 1 crore of turnover, or Rs 10 crore where cash receipts and cash payments each stay within 5% (Section 44AB of the 1961 Act; Section 63(1) of the 2025 Act). Paying fishermen in cash can push you past the 5% cash-payment line, so plan for the Rs 1 crore limit if you do. For tax year 2026-27 under Section 263(1) of the 2025 Act, the return is due by 31 August 2027 for a non-audit business, 31 October 2027 if audited, and 30 November 2027 if a transfer pricing report applies.
Fisheries co-operatives. A co-operative society engaged in "catching, curing, processing, preserving, storing or marketing of fish" deducts the whole of that profit under Section 80P(2)(a)(vii) of the 1961 Act, which is Section 149(2)(a)(vii) of the 2025 Act from 1 April 2026. Our Section 80P guide covers filing.
Comparison
Domestic Seller vs Exporter: Quick Comparison
| Parameter | Selling in India | Exporting |
|---|---|---|
| GST on frozen fish | Nil in bulk; 5% if pre-packaged and labelled | Zero-rated, whatever the pack |
| Registration | Not needed if only nil-rated sales (Section 23(1)(a)) | Needed in practice to file LUT and claim refunds |
| Credit on packing and services | Reverse for nil-rated sales (Rule 42) | Allowed and refundable (IGST Section 16) |
| Composition scheme | Possible for intra-State goods sellers | Barred (Section 10(2)(c)) |
| Cash to fishermen | Allowed above Rs 10,000 to the producer | Same: Rule 6DD(e)(iii) / Rule 26(1)(e)(iii) |
Source: CGST Act Sections 10, 23, 25; IGST Act Sections 7 and 16; CGST Rules 42 and 89; Income-tax Rules 1962 Rule 6DD; Income-tax Rules 2026 Rule 26
Common mistakes seafood plants make
- Charging 5% on bulk cartons, or nil on retail packs. The test is retail sale in packs of up to 25 kg with Legal Metrology labelling. Check each product line.
- Not registering because the fish is nil-rated. An exporter without GST registration can't claim the refund on cartons, chemicals and freight.
- Missing the LUT renewal. Exports in a new financial year before the LUT is filed can't go out without IGST under Rule 96A.
- Paying agents in cash. Rule 6DD(e)(iii) protects cash paid to the fisherman or farmer, not to middlemen.
- Letting refund periods lapse. The two-year clock starts when each shipment sails. File RFD-01 monthly or quarterly.
- Classifying cooked or breaded shrimp under 0306. Prepared shrimp is heading 1605 at 5% in any pack.
How Tax Garden helps seafood processors and exporters
We register your plant, file your LUT each year, set the right rate for bulk, retail and prepared products, and file GSTR-1 and GSTR-3B through our GST return filing service. We work out your Rule 89(4) refund and file the RFD-01. On the income tax side, we keep purchase vouchers for cash buys in order, handle TDS on large purchases, and file your return through our ITR filing service, with books kept by our accounting and bookkeeping service. Call or WhatsApp us on 9640290977.
Related reading: Fish farming guide | Cold storage owners guide | Meat and chicken shops guide | IEC registration guide | Ice factory GST guide
