Cosmeceutical Imports

Cosmeceutical imports – products that bridge cosmetics and OTC drugs (sunscreens, anti-aging with active ingredients, acne treatments) – face dual FDA classification depending on claims. HTS 3304 (cosmetic preparations) typically applies. Section 122 stacks; Korean K-beauty heavy.

This guide covers U.S. import tariff and compliance for cosmeceuticals.

For SMB importers in this category, the practical questions are HTS classification, applicable Section 232/301/122 stacks, FTA opportunities, and regulatory overlay (FDA/USDA/EPA/CPSC where relevant).

HTS classification basics

Cosmetic preparations HTS 3304.99. OTC drug cosmetics may classify under HTS 3304 with FDA OTC drug monograph compliance.

Tariff stack and rates

Base 0-2% + Section 122 (15% on non-USMCA). Limited Section 301 for cosmetics from China.

Country of origin considerations

Korea (K-beauty), Japan, France, U.S. dominant. Limited China sourcing for premium products.

Regulatory overlay

FDA OTC drug monograph for products with active ingredients (sunscreen, acne, anti-microbial). Cosmetic ingredient labeling. INCI nomenclature.

Mitigation opportunities

KORUS preference for Korean-origin. USMCA qualification on Mexican production.

Frequently asked questions

What is the typical effective duty rate?

Depends on origin and HTS classification. China-origin: 22-42% effective when Section 301 + Section 122 stack. USMCA-qualifying Mexican production: often 0-3%. Vietnam, India, Korea: 15-17% with Section 122.

Can I qualify under USMCA?

Possible if production occurs in U.S., Mexico, or Canada and meets rules of origin (typically 60% RVC under transaction value or 50% net cost). USMCA-qualifying goods are exempt from Section 122.

Are IEEPA refunds available?

Yes – for entries between April 5, 2025 and February 24, 2026 that paid IEEPA duty. Filed through CBP’s CAPE portal. We file claims on contingency for filings above $50k.

What about Section 232 exposure?

Specific to product type. Steel and aluminum derivatives expansion brought some downstream products into scope. Component-level analysis identifies actual coverage.

How do you help with this category?

Tariff exposure assessment ($2,500-$7,500), classification audit, USMCA qualification, refund recovery, audit response. Independent of any customs brokerage.