Importing Korean Soy Sauce and Gochujang: FDA Acidified-Food Filing, the Sesame Allergen, and KORUS Duty-Free

Korean sauce is having a moment. Korea Customs put 2023 sauce exports at about USD 384 million, a record, of which fermented pastes like gochujang and doenjang made up around USD 111 million. The largest market was the United States at 21.8% of the total (Korea Customs, announced 2024). Buldak sauce and gochujang have driven the growth.
If you buy Korean soy sauce or gochujang, though, the gate is different from seaweed or instant noodles. Fermented pastes are not treated as ordinary food at the US border; depending on the product, they can fall into a category that demands a separate process filing.
Fermented pastes are not 'just food' in the US
The US Food and Drug Administration (FDA) sorts food in hermetically sealed containers by acidity (pH) and water activity (aw) and regulates it more tightly. A food with a final equilibrium pH above 4.6 and aw above 0.85 is a low-acid canned food (21 CFR Part 113); add acid to bring the final pH to 4.6 or below and it becomes an acidified food (Part 114). Because a sealed food must not spoil at room temperature and cause illness (botulism in particular), a product in this category has to file its heat or acidity control process with the FDA in advance.
The catch is that fermented pastes can land in this category. Gochujang and doenjang typically run a pH of roughly 4.5 to 5.5 and hold a lot of moisture, so the finished product's measured pH and aw decide which category it falls in. A high-salt product like soy sauce, with lower water activity, may fall outside it. So it is neither automatically covered because it is a paste, nor exempt because it is a sauce; the finished-product numbers decide.
If it is covered, two things attach. One is facility registration: a maker of acidified or low-acid canned food must register with the FDA and obtain a Food Canning Establishment number (FCE) on Form FDA 2541. The other is the process filing: for acidified food the scheduled process is submitted to the FDA on Form FDA 2541e, within 60 days of registration and before a new product is packed. The person supervising the process must complete an FDA-recognized Better Process Control School. Unlike seaweed or snacks, which only need ordinary facility registration, fermented pastes go one gate deeper here.
Facility registration and FSVP are the shared baseline
Whichever category the paste lands in, any foreign facility that manufactures, processes, packs or holds food bound for the US must complete FDA Food Facility Registration. It is free and online, but the facility must name a US Agent and renew every two years between October and December of even-numbered years; miss the renewal and it lapses, which stops entry. A Prior Notice is filed for each shipment. This baseline is the same one covered in importing Korean seaweed.
Then there is FSVP, the Foreign Supplier Verification Program. Here the buyer flip matters: FSVP is your obligation as the US importer, not the Korean supplier's. You are the one who verifies the supplier, so the documents you rely on (HACCP certificates, process-flow diagrams, test reports) come from the manufacturer. Asking your Korean supplier for these up front makes your own verification straightforward and keeps the trade stable.
Labels: soy and wheat, plus sesame
Allergen labeling matters especially for pastes. Traditional soy sauce is usually brewed from soybeans and wheat, and gochujang contains soybeans and grain, so the US major allergens soy and wheat must be declared. On top of that, sesame became the ninth major allergen in 2023 (the FASTER Act). Korean sauces often carry sesame oil or sesame seed, so sesame must be declared even when it sits inside a spice blend or seasoning, or the product becomes recallable. A Nutrition Facts panel is also required on packaged food. It is safest to produce the label to the destination standard.
Halal: the alcohol fermentation creates
Soy sauce and gochujang also travel to Muslim-majority markets, where an unexpected issue arises. Naturally brewed soy sauce develops a small amount of alcohol (ethanol) as yeast breaks down sugars during fermentation, which makes alcohol a question in halal certification. Whether a product is halal is judged by a certifier weighing the alcohol's source and level; in Malaysia, the Department of Islamic Development (JAKIM) runs certification against the national standard. The general principle distinguishes trace alcohol from fermentation from alcohol derived from liquor, but the final judgment differs by certifier and market. If you target Muslim-majority markets, fermentation-alcohol control and halal certification should be settled at the product-development stage.
The market barrier itself is also rising: Indonesia makes halal certification mandatory for imported food from 18 October 2026, a background and route covered in importing Korean seaweed. Pastes are food too and fall squarely into that flow.
Duty: HS 2103 and KORUS duty-free
Soy sauce and gochujang split by HS code. Soy sauce classifies under HS 2103.10, while other seasonings like gochujang and doenjang fall under HS 2103.90. The US base tariff is about 3% for soy sauce and about 6.4% for other sauces, but under the Korea-US FTA (KORUS) both are duty-free. It is not automatic, though: the US importer must meet the origin requirement and claim the preference, so a certificate of origin is worth up to 6.4% in landed cost.
| Item | HS code | US base tariff | KORUS preference |
|---|---|---|---|
| Soy sauce | 2103.10 | ~3% | Duty-free (0%) |
| Gochujang, doenjang, other seasonings | 2103.90 | ~6.4% | Duty-free (0%) |
The principle for deciding which code your product falls under is in what an HS code is, and FTA origin in practice is in certificates of origin and FTAs. The order of export clearance itself is in export customs clearance.
Shipping: the weak points of liquid and paste cargo
Soy sauce and gochujang are the opposite of seaweed as cargo. Where seaweed is light and weak to moisture, pastes are heavy, high-moisture liquids and semi-solids. Packed in glass or PET, they carry weight and are weak to breakage and leaks. They travel at room temperature, but heat can keep fermentation going or spoil the product, so a long summer voyage calls for attention to the temperature inside the container.
That makes packing and loading the core. Cushion the bottles against breakage, wrap them so a leak does not contaminate other cargo, and load so the weight does not concentrate on one side. When volume builds it ships as a full container (FCL); small volumes split across buyers move as consolidated cargo (LCL). Because liquid cargo hits its weight limit before it fills the volume, it is better to check the weight ceiling before the container's cubic capacity.
Five things to check before importing Korean pastes
To sum up, before you import Korean soy sauce or gochujang, check the following.
- Product classification: measure the finished product's pH and water activity to see whether it is a low-acid or acidified food.
- FDA registration: if covered, the FCE facility registration and process filing, and across the board facility registration and a US Agent.
- Label: produce the soy, wheat and sesame allergen declarations and the Nutrition Facts panel to the destination standard.
- Halal: for Muslim-majority markets, settle fermentation-alcohol control and halal certification at the product stage.
- Duty and shipping: check the HS 2103 code to line up KORUS origin, and pack against leaks and breakage.
Importing Korean sauce is less about loading the ship than about clearing the destination's food regulation first. Know at the order stage that a fermented paste is not just food in the US, design classification and registration together, and you avoid a shipment held at the US port for a missing process filing.
This guide is general information as of August 2026. The FDA's low-acid and acidified food classification and registration requirements, allergen labeling, halal criteria, and destination tariffs change with the rules and with product composition, so confirm with the FDA, customs authorities and your forwarder before you actually ship.
Interactive tool
HS code lookup
Soy sauce (2103.10) and gochujang or other seasonings (2103.90) carry different HS codes, and once the code diverges the destination tariff and FTA preference change. Enter the product name to check your product's HS code first.
Frequently asked questions
Why is registration stricter for soy sauce and gochujang than for ordinary food in the US?
The FDA sorts food in hermetically sealed containers by acidity (pH) and water activity (aw). A food with a final pH above 4.6 and aw above 0.85 is low-acid; add acid to bring the pH to 4.6 or below and it becomes acidified. Fermented pastes can fall into this category depending on the finished-product numbers, and if they do, an FCE facility registration and a per-product process filing are added on top of ordinary facility registration. It is not automatic, though; the finished product's measured pH and aw decide.
What are the FCE registration and the process filing?
A facility that makes acidified or low-acid canned food must register with the FDA and obtain a Food Canning Establishment number (FCE) on Form FDA 2541. On top of that is a process filing that submits the per-product scheduled process to the FDA; for acidified food it is Form FDA 2541e, filed within 60 days of registration and before a new product is packed. The person supervising the process must complete an FDA-recognized Better Process Control School.
Which allergens must be declared on soy sauce and gochujang labels?
Traditional soy sauce is usually brewed from soybeans and wheat, and gochujang contains soybeans and grain, so the US major allergens soy and wheat must be declared. Since 2023 sesame is the ninth major allergen (the FASTER Act), so a sauce carrying sesame oil or seed must declare sesame even when it sits inside a spice blend. A Nutrition Facts panel is also required on packaged food.
Is alcohol a problem when exporting soy sauce to Muslim-majority markets?
Naturally brewed soy sauce develops a small amount of alcohol as yeast breaks down sugars during fermentation, which makes the alcohol's source and level a question in halal certification. The general principle distinguishes trace alcohol from fermentation from alcohol derived from liquor, but the final judgment differs by certifier such as Malaysia's JAKIM and by market. If you target these markets, settle fermentation-alcohol control and halal certification at the product-development stage.
Does KORUS make soy sauce and gochujang duty-free?
Soy sauce classifies under HS 2103.10 and other seasonings like gochujang and doenjang under HS 2103.90. The US base tariff is about 3% for soy sauce and about 6.4% for other sauces, but under the Korea-US FTA both are duty-free. It is not automatic; the US importer must meet the origin requirement and claim the preference, so lining up a certificate of origin returns as price competitiveness.
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