US Tariffs 2026 and Landed Cost: the numbers behind a China-origin eye-care shipment

Market Entry

The 800-dollar de minimis relief ended for Chinese-origin goods in May 2025, and from 24 July 2026 a further 12.5% Section 301 duty applies to China mainland and Hong Kong. Read this before you quote: it sets the effective duty band, the real MoCRA compliance cost, and the cost lines beyond duty that decide whether a 3,000-unit private label eye care run pays.

Why landed cost is no longer a figure you can estimate

For decades it was enough to estimate the FOB, add freight and insurance and apply a buffer. For private label eye care into the US that calculation no longer holds.

The de minimis exemption ended first for China and Hong Kong on 2 May 2025 and for all other origins on 29 August 2025, so a 200-unit sample that once arrived duty-free now enters like any other order. The Merchandise Processing Fee sits at 0.3464% in FY2026 with a minimum of USD 33.58 and a maximum of USD 651.50 per entry, and the Harbor Maintenance Fee is charged at 0.125% on sea freight with no ceiling. On a small shipment the MPF minimum can exceed the duty itself.

The number you present to your buyer therefore has to be landed cost per unit, not FOB plus a round percentage. On a modelled 3,000-unit run, USD 1.60 of a USD 3.70 landed cost is factory price, which is 43%. Everything negotiated at sourcing multiplies through the total instead of sitting inside the factory invoice.

Three things follow for eye patches, eye masks and eye creams. Duty applies to entered value, not retail margin, and on low-value, high-volume items the gap between the two is well under half. These formats are made under ISO 22716 or GMPC, and customs authorities and marketplaces increasingly ask for that production evidence. The compliance work does not happen at the port; it happens in your own documentation.

What actually changed in the 2026 tariff picture

On 20 February 2026 the US Supreme Court held 6 to 3 that IEEPA does not authorise tariffs, and the replacement layers moved on a much shorter clock.

The Court decision removed the IEEPA-based tariffs and opened a refund process covering roughly USD 164.7 billion already collected. A 10% across-the-board surcharge under Section 122 of the Trade Act of 1974 replaced it, but its 150-day statutory limit expired on 24 July 2026. From that same date, 00:01 Eastern Time, USTR applied a forced-labour Section 301 action across 60 economies covering more than 99.4% of US imports, with China mainland and Hong Kong in the flat 12.5% tier.

The transition window was about four days: goods loaded before 00:01 ET on 24 July 2026 and entered before 00:01 ET on 28 July 2026 escaped the new duty. For a factory in the Pearl River Delta that fixed the second-half shipping calendar. Afterwards, two stacking rules apply: the new 301 duty stacks fully on the 2018 lists but not with Section 232, so goods already carrying a 232 duty are excluded.

Duty stacking: two scenarios and what each one costs you

Not all China-origin cosmetics carry the same load, and the gap between the two documented scenarios is measured in percentage points of entered value.

The base MFN rate on Chapter 33 is free, and the 2018 Section 301 lists remain in place, at 7.5% for List 4A and 25% for List 3. The Federal Circuit upheld both on 25 September 2025, so those duties are not part of the IEEPA refund wave. On top sits the 12.5% forced-labour duty from 24 July 2026, giving modelled outcomes of roughly 20% in List 4A and roughly 37.5% in List 3.

That 17.5-point spread is the most under-managed variable in a low-unit-price category. On a 3,000-unit run at USD 3.70 landed cost the difference is USD 194.25, or about USD 0.065 per unit, which against a retail line at USD 9.99 is enough to erase the margin. Ask the broker for the rate applying to your article and shipping date rather than accepting an industry average.

We could not confirm from a public source whether the 10-digit codes under HTS 3304 sit in List 4A, so treat these as a band and verify the code with a customs broker or a CBP binding ruling. Two charges sit on every entry: MPF at 0.3464% with a floor of USD 33.58 and a ceiling of USD 651.50, and HMF at 0.125% on ocean freight. If your supplier invoices CIF with freight folded into the unit price, you pay duty on freight and lose a base worth 5-15%.

MoCRA: compliance cost that never appears on an invoice

FDA charges nothing for cosmetic facility registration or product listing, but the obligations around them are strict and time-bound.

Under MoCRA section 607 FDA charges no user fee for cosmetic facility registration or product listing, and Cosmetics Direct is free, so any fee quoted is a third-party service or U.S. Agent fee. Plan around renewal, which is biennial with the 2026 window running from 1 October to 31 December 2026 and no grace period, and annual product listing updates. FDA has signalled it may introduce cosmetic user fees by rulemaking.

The reporting obligations are the real burden. A serious adverse event must be reported within 15 business days, and further material medical information in the following year falls in the same window. Records are kept six years, or three for exempt small businesses. A safety-substantiation dossier, a toxicological risk assessment, typically costs USD 300 to USD 2,000 per formula.

Classification is decided by claims, which is where eye care brands create their own problems. Cosmetic claims covering hydration, soothing or temporary smoothing of appearance keep the product in the cosmetic path; a claim that the product treats disease or alters structure or function moves it to the OTC drug path, requiring an NDC and listing under 21 CFR 207, and DailyMed already lists eye masks there. The small-business exemption at USD 1 million average annual US sales is unavailable to products that regularly contact the eye's mucous membrane, which covers most eye patches and serums.

Valuation, recovery and the risks that stop a shipment

Three lawful levers reduce duty, and three mistakes routinely cost more than the duty itself.

The first lever is valuation discipline: freight and insurance must be separately itemised to stay out of the dutiable value, and a CIF invoice folding freight into the unit price gives up a base worth 5-15%. The second is the First Sale rule, valuing goods at the factory-to-middleman price where that is a bona fide sale. The third is duty drawback, recovering up to 99% of duties on re-export or destruction, plus FTZ admission for deferred payment.

Declaration errors carry penalties under 19 U.S.C. 1592 of up to two times lost revenue for negligence, four times for gross negligence and eight times for fraud, with possible criminal referral. The defence is a documented reasonable-care file on classification, valuation and origin. Transshipment changes nothing by itself: substantial transformation is required, CBP pursues it actively, and the Mexican route only yields 0% if it genuinely meets USMCA rules.

The most severe risk for China-origin sourcing is UFLPA. The rebuttable presumption requires the importer to rebut it with clear and convincing evidence, with no de minimis exception and only 30 days to answer a detention notice. Finished cosmetics are not a named enforcement priority, but any chemical input, packaging input or intermediate tracing to a high-priority sector such as cotton, polysilicon, aluminium, steel, PVC or caustic soda can taint the whole container.

How to quote a private label eye care run into the US

Volume moves the unit price more than any tariff point, and the one-off charges decide whether a first order is profitable.

Per-unit cost for private label ODM from Guangdong falls sharply with MOQ: USD 6.90-8.50 at 500 units, USD 5.20-6.40 at 1,000 units, a fall of 22-25%, and USD 3.85-4.65 at 5,000 units, a fall of 44-46% from the smallest band. Those are FOB Shenzhen figures before freight and duty. Budget at the top of each band while the spec is open; the bottom becomes reachable once the data sheet is frozen.

Composition matters as much as the total. Raw material runs USD 1.80-3.50, labour USD 0.45-0.75, packaging USD 1.20-2.80, compliance testing USD 0.30-0.65 and tooling or development one-offs USD 1,500-8,000. On a small first order the amortised one-offs are most often missed, and clean-beauty actives can add USD 0.90-1.80 per unit of raw material cost.

Before the first pallet ships: confirm the 10-digit HTS code and rate with a broker or binding ruling; apply the loaded-before and entered-before rule to your actual booking dates; itemise freight and insurance; assemble the UFLPA traceability file; confirm the facility registration renewal falls inside 1-31 October 2026; and fix the claim wording so the cosmetic or OTC route is chosen deliberately.

FAQs

Sources: USITC, Harmonized Tariff Schedule of the United States (2026 HTSUS, Revision 19)； USTR, final action notice on the forced-labour Section 301 investigation (2026-07-23)； Presidential Memorandum of 23 July 2026, Federal Register / govinfo； U.S. Supreme Court, Learning Resources, Inc. v. Trump, No. 24-1287, decided 2026-02-20； U.S. Court of Appeals for the Federal Circuit, ruling of 2025-09-25 upholding Lists 3 and 4A； U.S. CBP, customs user fees for FY2026 (MPF 0.3464%, HMF 0.125%)； FDA, MoCRA obligations: facility registration, product listing, adverse-event reporting； DailyMed, National Library of Medicine drug label database (NDC 84168-005 eye mask listing)； Euromonitor International, US cosmetics market size 2025 (USD 126.3bn, +1.5%)