Soap Imports

Soap imports classify under HTS 3401 (soap, organic surface-active products). Bar soap HTS 3401.11; liquid soap HTS 3401.20. Section 122 stacks. FDA cosmetic regulations (no pre-approval but labeling and adulteration rules). Antimicrobial soaps face additional FDA OTC drug regulations.

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

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

Bar soap HTS 3401.11. Liquid soap HTS 3401.20. Soap-based skin care HTS 3401.30.

Tariff stack and rates

Base 0-2.6% + Section 122 (15% on non-USMCA). Limited Section 301.

Country of origin considerations

EU artisan (France, Italy), U.S. (mass-market), India (handmade), Mexico USMCA.

Regulatory overlay

FDA cosmetic regulations. FDA OTC drug regulations for antimicrobial claims. Triclosan banned in many products.

Mitigation opportunities

USMCA qualification on Mexican production. EU artisan supports First Sale.

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.