Essential Oil Imports

Essential oil imports classify under HTS 3301 (essential oils). Specific subheadings by botanical source. Section 122 stacks. FDA jurisdiction depends on claims (cosmetic, food, drug). Aromatherapy claims can trigger drug classification. France (lavender), Australia (tea tree), Madagascar (ylang-ylang) dominant.

This guide covers U.S. import tariff and compliance for essential oils.

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

Essential oils HTS 3301. Lavender HTS 3301.29. Tea tree HTS 3301.29. Citrus oils HTS 3301.12-19.

Tariff stack and rates

Base 0-3.7% + Section 122 (15% on non-USMCA).

Country of origin considerations

France (lavender, herbs), Australia (tea tree, eucalyptus), Madagascar, India, Brazil, U.S. (peppermint, etc.).

Regulatory overlay

FDA classification depends on claims and use. Cosmetic vs food vs drug. AAFCO for animal-related claims.

Mitigation opportunities

Cosmetic positioning avoids drug classification. 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.