The Real Cost of Importing From China in 2026 (Now That De Minimis Is Gone)
Key takeaways
De minimis is gone for good. As of 2026, every commercial shipment from China, regardless of value, requires formal or informal US customs entry. There is no more duty-free small-parcel channel.
The duty stack is now four layers deep: MFN base rate, Section 301 tariff, 10% Section 122 surcharge, and a 12.5% Section 301 forced-labor tariff added July 24, 2026. These stack additively, not interchangeably.
A typical non-escalated product now carries 30%+ in combined duty before freight, customs fees, or broker costs are even added.
Fixed customs fees hit small orders hardest. Consolidating into fewer, larger shipments can meaningfully cut your effective landed cost per unit.
First Sale Valuation, a legal method of declaring customs value at the factory price rather than the resale price, can offset a real share of the new duty burden for buyers sourcing through a Hong Kong intermediary.
Anyone who built a landed-cost spreadsheet for China sourcing in 2025 is now working from numbers that no longer reflect reality, and the gap is not a matter of a small adjustment here or there. Two of the assumptions that spreadsheet was built on have quietly stopped holding true, which means the old shortcut of taking the FOB price and adding a flat tariff percentage no longer produces a figure anyone can actually rely on.
The first change is that the $800 de minimis exemption, which for years let low-value shipments slip into the country duty-free, is gone. CBP closed the low-value clearance channel for commercial shipments in May 2026 and made the suspension indefinite by federal regulation on June 24 of that year. Every parcel, sample order, and small test batch that used to clear without incident now has to go through formal or informal customs entry, which means duties and processing fees now apply to shipments that previously cost nothing to bring into the country.
The second change is a little more subtle, and it is the one most buyers are getting wrong. After the Supreme Court struck down the administration's IEEPA tariff authority in February 2026, the government replaced it with a 10% Section 122 import surcharge. Then, on July 24, 2026, the US Trade Representative added a separate 12.5% Section 301 tariff tied to forced-labor enforcement, and it is easy to assume this second rate simply replaced the first. It did not. The two apply on top of one another, along with whatever Section 301 rate already applied to your product, and a long list of individual product categories, from batteries and semiconductors to gloves, graphite, and magnets, received their own separate rate increases on January 1, 2026, entirely independent of the changes above.
Most of what has been published on this topic stops at "tariffs went up, so budget more," which is closer to a warning than a working answer. What follows is a walk through exactly which fees stack, in what order, and how to rebuild a landed-cost number from the FOB price all the way to your warehouse door, using a full worked example along the way.
What changed with US-China trade policy in 2026?
Through 2025, most low-value shipments cleared duty-free under Section 321, including sample orders, small parcel test runs, and the sub-$800 splits some importers relied on to manage cash flow. That channel no longer exists. Every commercial shipment now requires a formal or informal customs entry, which brings with it duties, a Merchandise Processing Fee, and, for shipments arriving by ocean, a Harbor Maintenance Fee, all applied to goods that used to move through customs at no cost at all. Congress has since gone further and codified a full statutory repeal of Section 321 for commercial shipments, effective July 1, 2027, so this is not a temporary policy swing that might reverse. It is the new baseline for how trade with China works.
The duty stack itself has also grown more complicated, and a lot of buyers are still thinking of "the tariff" as a single number when it no longer works that way. As of August 2026, a typical Chinese-origin product carries four separate layers of duty:
MFN base rate: the standard duty tied to your product's 10-digit HTS classification, typically 0%–7% for most consumer goods (some categories, like apparel, run higher).
Section 301 tariff (base or escalated): the "China tech transfer" tariff dating back to 2018, at a base rate of 7.5%–25% depending on your product's List classification (1 through 4A). A number of specific categories got pushed sharply higher on January 1, 2026, see the table below.
Section 122 import surcharge: a flat 10%, introduced after the Supreme Court struck down the administration's broader IEEPA tariff authority in February 2026. Applies on top of MFN and Section 301, with an exception where Section 232 (steel/aluminum) rates take primacy.
Section 301 forced-labor tariff: a separate, additional 12.5%, effective July 24, 2026, unless your product is specifically exempted under Annex II.
These layers stack on top of one another rather than replacing each other, so a product carrying a 3.4% MFN rate, a 7.5% Section 301 base rate, the 10% Section 122 surcharge, and the 12.5% forced-labor tariff arrives at 33.4% in duty alone, and that is before freight, before customs fees, and before anything shows up on your broker's invoice.Which product categories saw the biggest tariff increases in 2026?
A few categories moved sharply on January 1, 2026, on top of everything above:
| Category | Section 301 rate (escalated) | Illustrative total stack* |
|---|---|---|
| Non-EV lithium-ion batteries | 25% (up from 7.5%) | ~38% |
| Semiconductors & silicon wafers | 50% | ~60% |
| Medical/surgical rubber gloves | 100% | ~113% |
| Natural graphite & permanent magnets | 25% | ~35% |
| Electric vehicles | 100% | 110%+ |
These figures include MFN, Section 301, and Section 122, and assume the product in question is not exempted from the forced-labor tariff under Annex II. Because every one of these numbers depends entirely on the exact 10-digit HTS code assigned to your product, the table is best read as a prompt to check your own classification rather than as a rate you can quote with confidence.
This is exactly the part that generic "tariffs went up" advice tends to skip. How much a given shipment is actually affected depends enormously on what is being imported, not simply on the fact that it is coming from China.
How do you calculate landed cost for Chinese imports in 2026?
Landed cost is everything it takes to get one unit from your supplier's factory floor to a sellable state in your warehouse. Here's the formula, and the stack behind it, in the order costs actually hit:
Landed cost per unit = FOB unit price + freight (allocated per unit) + duty stack + customs fees + broker & bond fees + last-mile/drayage
1. FOB price. What you pay your factory at the port of origin. This is the number most buyers already track, and the only one that hasn't changed.
2. Freight. As of August 2026, ocean freight from China is running $3,000–$5,500 per 40ft container to the US West Coast, and $4,200–$7,200 to the East Coast. August through October is peak season, so expect rates toward the higher end, plus a peak season surcharge of $500–$2,000 per container. Divide the container cost by units per container to get your per-unit freight allocation.
3. Duty stack. MFN rate + Section 301 (base or escalated, by product) + Section 122 surcharge (10%) + Section 301 forced-labor tariff (12.5%, unless exempted). This applies to the customs value of your goods, normally your FOB price, not freight or insurance (more on how to legally reduce this number below).
4. Merchandise Processing Fee (MPF). 0.3464% of customs value on formal entries (Entry Type 01, generally shipments over $2,500). The statutory floor and cap adjust periodically. Recent published figures put the floor around $32–$34 and the cap around $614–$651 per entry, so confirm the current number with your broker rather than relying on any single published figure. Informal entries (Entry Type 11, generally under $2,500) carry a flat automated fee instead, roughly $2.50–$10.
5. Harbor Maintenance Fee (HMF). 0.125% of cargo value, ocean shipments only. Air freight is exempt. No cap.
6. Broker & bond fees. A licensed customs broker filing a formal entry typically charges $125–$250; informal or low-value entries run $15–$75. You'll also need customs bond coverage: a Single Entry Bond (roughly $5 per $1,000 of value plus duty, $50 minimum) for occasional formal entries, or a Continuous Bond (roughly $500–$750 per year, covering up to $50,000 in duty liability) if you're importing regularly. The continuous bond is almost always the better deal past a handful of shipments a year.
7. Drayage and last-mile. Trucking the container from port to your warehouse or 3PL, highly variable by port and distance, but budget $400–$900 for a standard drayage move from a major coastal port.
Why order size matters more than it used to. These fixed fees don't scale with your shipment value, so they hit small orders disproportionately hard. A $100,000 bulk container absorbs its MPF and broker fee at well under 1% of value. A $100 parcel forced through the same entry process can see $30–$50 or more in fees alone, 30% to 50% overhead before duty is even applied. This is the real argument for consolidating into fewer, larger ocean shipments instead of frequent small parcels. It's not just about freight economics anymore, it's about which side of a fixed-fee cliff your order size lands on.
Worked example: a real landed-cost breakdown
Say you're importing silicone kitchen tools, one of the product categories where certification and material compliance genuinely matter, and squarely in the kind of goods a fractional sourcing team is managing day to day. Assume:
FOB price: $1.20/unit (paid to your Hong Kong intermediary, see First Sale note below)
Order size: 20,000 units, one 40ft container
HTS classification: MFN rate 2.1%, Section 301 base rate 7.5% (not on an escalated list, not Annex II exempt)
Freight: $4,200 (East Coast, peak season)
Customs value: $24,000 (20,000 × $1.20)
| Line item | Calculation | Cost |
|---|---|---|
| FOB total | 20,000 × $1.20 | $24,000.00 |
| Freight | flat, one container | $4,200.00 |
| MFN duty | 2.1% × $24,000 | $504.00 |
| Section 301 duty (base) | 7.5% × $24,000 | $1,800.00 |
| Section 122 surcharge | 10% × $24,000 | $2,400.00 |
| Section 301 forced-labor tariff | 12.5% × $24,000 | $3,000.00 |
| MPF | 0.3464% × $24,000 | $83.14 |
| HMF | 0.125% × $24,000 | $30.00 |
| Broker fee | flat, formal entry | $175.00 |
| Bond (allocated) | pro-rated continuous bond | $15.00 |
| Drayage | flat | $650.00 |
| Total landed cost | $36,857.14 | |
| Landed cost per unit | $36,857.14 ÷ 20,000 | $1.84 |
That's a 53% markup over FOB, not the 20-ish percent a single-line "add the tariff" estimate would suggest. The duty stack alone (MFN, Section 301, Section 122, and the forced-labor tariff) is 32.1% of customs value here, and that's on a product that isn't even on one of the sharply escalated lists. Anything that is, whether batteries, gloves, or semiconductors, lands dramatically higher.
Can you legally reduce your customs value? First Sale Valuation, explained
Here's the piece most landed-cost guides skip entirely, and it matters most for exactly the kind of multi-tier supply chain a Hong Kong sourcing arrangement typically involves.
Customs duty isn't assessed on whatever price you feel like declaring. It's assessed on "customs value," and by default that's the last sale price: what the US importer pays the seller immediately before the goods enter the US. If your factory sells to a Hong Kong intermediary, and the intermediary sells to you, the default customs value is the intermediary's price to you, which already includes their margin, admin costs, and any inland freight to the export port.
Under 19 U.S.C. 1401a, and affirmed in E.C. McAfee v. United States, importers in a genuine multi-tier supply chain can instead declare customs value based on the first sale, the factory's price to the intermediary, provided three conditions hold:
A bona fide sale at that first tier, with real transfer of title and risk.
Goods clearly destined for the US at the time of that first sale (established through US-specific packaging, labeling, or purchase orders).
Arm's-length pricing: if the factory and intermediary are related parties, you have to show the price wasn't distorted by that relationship.
In the example above, if the factory's actual price to the Hong Kong intermediary is $0.90 per unit (rather than the $1.20 the US buyer pays), declaring customs value on the $18,000 factory price instead of the $24,000 resale price cuts the duty bill from $7,704 to roughly $5,778, a savings of about $1,926 on this one container, before any volume scaling.
This isn't a loophole. It's an established, CBP-recognized valuation method, but it only works with clean documentation: separate factory and intermediary invoices, proof of payment at both tiers, bills of lading showing the US destination, and a defensible arm's-length pricing rationale, all retained for five years. It also requires structuring your supply chain contracts that way from the start, not retrofitting them after the fact. Note that legislation has been proposed, the Last Sale Valuation Act, that would eliminate this method. It's not law as of August 2026, but it's worth watching if you build a program around it.
For a buyer managing this alone, setting up dual-tier contracts and an audit trail is a lot to take on. For a sourcing partner already sitting between the factory and the buyer, it's close to the natural structure of the relationship.
Rebuilding your own landed-cost model: a checklist
Rebuilding your landed cost isn't a one-time exercise. The duty stack has changed more than once in the last eighteen months, and Congress's statutory repeal of Section 321 in mid-2027 means the rules will move again. A few things worth locking in now:
Confirm your full 10-digit HTS classification with your broker, not your supplier. Misclassification is the single most common cause of a landed-cost estimate blowing up after the fact, and it's now more expensive to get wrong. Consider a formal CBP Binding Ruling if there's any ambiguity.
Get your Incoterms explicit. Whether you're buying FOB or DDP changes who's absorbing this new fee stack, and confusion here is where margin quietly disappears.
Consolidate where you can. Fixed fees (MPF, broker, bond) barely move a bulk container's per-unit cost but can double a small parcel's. If you're still shipping frequent small batches, model what switching to fewer, larger shipments actually saves.
Ask whether First Sale Valuation applies to your supply chain. If goods pass through an intermediary before reaching you, this alone can offset a meaningful share of the new duty stack, but it has to be structured up front, with documentation, not claimed after the fact.
Model the full stack before you commit to volume, not after your container is already on the water.
Re-run the numbers per shipment, not per year. Rates have moved more than once since February 2026. Treat your landed cost as a living calculation, not a spreadsheet you built once.
This is the same discipline we build into every sourcing engagement: Western-standard landed cost reporting, DDP terms confirmed before your PO is placed, and no surprises between your factory floor and your warehouse door. If you want a second set of eyes on your numbers before your next order ships, that's exactly the kind of conversation a fractional sourcing team exists to have.
Frequently asked questions
Is de minimis really gone for all China imports in 2026? Yes. CBP closed the low-value (Section 321) clearance channel for commercial shipments and made the suspension permanent by federal regulation on June 24, 2026. Every commercial shipment now requires formal or informal customs entry regardless of value, and Congress has separately enacted a full statutory repeal effective July 1, 2027.
What is the current tariff rate on Chinese imports in 2026? There is no single rate. It depends on your product's HTS classification. A typical non-escalated product carries roughly 30%+ in combined duty (MFN plus Section 301 base rate plus the 10% Section 122 surcharge plus the 12.5% forced-labor tariff, if not exempt). Specific categories like batteries, semiconductors, and gloves carry much higher escalated Section 301 rates on top of that.
What's the difference between the Section 122 surcharge and the Section 301 forced-labor tariff? They're separate and they stack. The 10% Section 122 surcharge replaced the earlier IEEPA-based tariff after the Supreme Court struck down that authority in February 2026. The 12.5% Section 301 forced-labor tariff was added separately on July 24, 2026, and applies unless your product is exempted under Annex II. Neither one replaces the other.
How much does it cost to clear a small parcel from China now? Fixed government and broker fees (MPF, HMF, broker charges) don't scale down with shipment value, so they hit small parcels hardest. A $100 parcel can carry 30% to 50% or more in fee overhead alone, before duty. This is pushing many importers toward consolidated bulk ocean shipments instead of frequent small parcels.
What is First Sale Valuation and can I use it? It's a CBP-recognized method of declaring customs value based on the factory's price to an intermediary, rather than the intermediary's resale price to the US importer, in a genuine multi-tier supply chain. It requires a bona fide first sale, goods clearly destined for the US at that point, arm's-length pricing, and full supporting documentation retained for five years. It's most naturally set up when a sourcing partner already sits between your factory and your business.
Duty rates, freight costs, and customs fees change frequently and vary by product, port, and carrier. The figures above reflect published rates as of August 2026 and are illustrative. Always confirm current rates with your customs broker before finalizing a landed-cost estimate.
