Sunscreen Imports

Sunscreen imports classify under HTS 3304.99 (other cosmetic preparations). Crucial: sunscreens are FDA-regulated as OTC drugs under the sunscreen drug monograph. Active ingredients must be on the FDA list. Section 122 stacks. Many EU and Korean sunscreens use ingredients not approved by FDA.

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

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

Sunscreens HTS 3304.99 (other cosmetic preparations). FDA classifies as OTC drug.

Tariff stack and rates

Base 0-2% + Section 122 (15% on non-USMCA).

Country of origin considerations

EU (L’Oreal, Beiersdorf), Korea, U.S. (J&J, P&G), Mexican USMCA.

Regulatory overlay

FDA OTC drug monograph compliance. Active ingredient must be GRASE (Generally Recognized as Safe and Effective). SPF testing per FDA standards. Hawaii and Florida reef-safe restrictions.

Mitigation opportunities

Verify active ingredients on FDA approved list before importing. State (HI, FL) reef-safe formulations.

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.