New CBP Guidance: Mixed Shipments with China Country of Origin Goods Face Tariffs & Trade Hurdles

On 02/03/2025 at 07:25 PM EST, U.S. Customs and Border Protection (CBP) provided guidance that confirms that shipments containing products with a China (including Hong Kong) Country of Origin will be subject to new tariffs and compliance measures. It is important to note that if a mixed shipment contains one product with a China Country of Origin it will affect the entire shipment, and make it ineligible for de minimis clearance.

The de minimis entry, under Section 321 of the Tariff Act of 1930, has allowed brands to ship low value goods to the United State without incurring tax, duties and fees. Under the new tariffs, Section 321 no longer applies to any shipment containing a product with a China Country of Origin.

What Does This Mean for Importers?

Under this guidance, any shipment importing into the US that includes a good with China Country of Origin —regardless of where it is shipping from —will be affected. Importers must ensure they are:

• Separating Goods – If you ship items with China Country of Origin, separate these from other products that are still eligible for de minimis entry.
• Preparing for Increased Tariffs – These additional costs could significantly impact pricing and margins.
• Staying Compliant with CBP Regulations – Proper documentation and classification with HTS codes up to 10 digits are critical to avoid delays, penalties, or shipment holds.
• Exploring Alternative Strategies – From including contract provisions that specify tariffs risk to diversify your supply chain, merchants should evaluate options to minimize disruption.

How to Stay Ahead

With evolving trade policies, staying informed and proactive is key. Merchants should work closely with trusted partners to ensure they comply with CBP regulations while maintaining a cost-effective import strategy.

Need help navigating these changes? Contact us today.