PPE imports classify by product type. Surgical masks under HTS 6307.90. Disposable gloves under HTS 4015 (rubber) or 3926 (plastic). Gowns under HTS 6210. Face shields under HTS 9004 or 6307. FDA medical device classification varies by claim. Section 122 stacks; Section 301 heavy for China-origin PPE.
This guide covers U.S. import tariff and compliance for PPE.
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
Surgical masks HTS 6307.90.99. Nitrile gloves HTS 4015.19.10. Latex gloves HTS 4015.19.05. Surgical gowns HTS 6210.10.
Tariff stack and rates
Base varies (5-10%) + Section 122 (15%) + Section 301 (25% if China-origin). Effective 20-50%.
Country of origin considerations
China dominant for PPE. Vietnam, Malaysia, Cambodia growing. Mexican USMCA opportunities.
Regulatory overlay
FDA Class I/II medical device for medical-claim PPE. NIOSH N95 certification. ASTM standards.
Mitigation opportunities
Vietnam diversification. Mexican USMCA qualification. NIOSH-certified domestic 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.
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