Nutraceutical and Supplement Imports

Nutraceutical and dietary supplement imports classify primarily under HTS 2106.90.99 (food preparations) or 3004 (medicaments) depending on positioning. FDA DSHEA (Dietary Supplement Health and Education Act) governs labeling and claims. Section 122 stacks. India and China dominate ingredient supply.

This guide covers U.S. import tariff and compliance for nutraceuticals and supplements.

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

Dietary supplements HTS 2106.90.99 if food-positioned. HTS 3004 if drug-positioned. Specific subheadings by ingredient.

Tariff stack and rates

Base 0-7% + Section 122 (15% on non-USMCA). Section 301 if China-origin.

Country of origin considerations

India and China for active ingredients. U.S. for finished product. EU for premium.

Regulatory overlay

FDA DSHEA labeling and claims. cGMP compliance. New Dietary Ingredient (NDI) notification for novel ingredients. Country of origin marking.

Mitigation opportunities

EU origin avoids Section 301. USMCA qualification on Mexican-blended products.

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.