Specialty Cheese Imports

Specialty cheese imports classify under HTS 0406 with tariff-rate quotas (TRQs) for many cheese types. Within-quota: typically 0-15% duty. Over-quota: punitive rates 15-50%+. Section 122 stacks on non-USMCA. USDA + FDA dual oversight.

This guide covers U.S. import tariff and compliance for specialty cheeses.

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

Cheese HTS 0406. Specific subheadings by cheese type and processing.

Tariff stack and rates

Within TRQ: 0-15%. Over-quota: 15-50%+. Section 122 stacks on non-USMCA.

Country of origin considerations

EU dominant (Italy Parmesan, France Brie, Switzerland Gruyere). Some Mexican USMCA opportunities.

Regulatory overlay

USDA dairy import permits. FDA food facility registration. State sales restrictions on raw milk cheese.

Mitigation opportunities

TRQ allocation purchases. USMCA qualification on Mexican-produced cheese.

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.