Hand Sanitizer Imports

Hand sanitizer imports classify under HTS 3808.94 (disinfectants) or sometimes HTS 3304 depending on positioning. FDA classifies as OTC drug under tentative monograph. DOT hazmat for high-alcohol products. Section 122 stacks.

This guide covers U.S. import tariff and compliance for hand sanitizers.

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

Hand sanitizers HTS 3808.94. Some classify HTS 3401 if soap-based.

Tariff stack and rates

Base 0-5% + Section 122 (15% on non-USMCA).

Country of origin considerations

Surge in 2020-2022 from Mexico, China. Now stabilized; mainstream brands (Purell, Germ-X) dominant.

Regulatory overlay

FDA OTC drug compliance. Tentative final monograph for active ingredients. DOT hazmat (UN 1170 Class 3) for shipping.

Mitigation opportunities

USMCA qualification on Mexican-produced. Active ingredient compliance check before shipping.

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.