0405.20 - Dairy spreads:

This HTS subheading, 0405.20, encompasses "Dairy spreads." These are products primarily composed of milk fat, intended for direct consumption or use as a spread. Unlike pure butter, dairy spreads often incorporate additional ingredients such as vegetable oils, water, flavorings, or emulsifiers to achieve a softer texture, improved spreadability, or a modified fat content. The key distinction lies in their formulation and intended application as a spreadable product, which differentiates them from the more solid and concentrated form of butter.

This category is distinct from its sibling subheading, 0405.10, which specifically covers "Butter." Butter is defined by its composition, typically containing at least 80% milk fat by weight. Dairy spreads, while derived from milk fat, are formulated to be more easily spreadable at refrigeration temperatures and may contain a lower percentage of milk fat, often supplemented with other fats. The other sibling, 0405.90, covers "Other" fats and oils derived from milk that do not fit into the more specific categories of butter or dairy spreads.

The subcategories within 0405.20 further refine the classification based on the primary ingredients and intended use. The first subdivision typically addresses "Butter substitutes, whether in liquid or solid state," indicating products that mimic the appearance and function of butter but are not exclusively derived from milk fat and may contain significant amounts of vegetable oils. The "Other" subdivision would capture remaining dairy spreads that do not fall into the butter substitute category.