How do current tariffs affect supplement ingredient costs in 2026?

Tariff programs have separate rules. The Supreme Court invalidated IEEPA tariffs on February 20, 2026. The temporary Section 122 surcharge covered non-exempt entries from February 24 through July 23, 2026. Older China Section 301 duties remain at 7.5% or 25% on listed goods, in addition to MFN duty. The forced-labor action adds a separate layer for entries from 12:01 a.m. ET July 24, 2026: 12.5% for China, 10% for India, and a 10% total floor for covered EU goods, net of MFN. Its Note 52 exemptions do not remove older China duties. For example, supplement-use glycine at 2922.49.43 has 4.2% MFN, 25% older China duty, and 12.5% forced-labor duty: 41.7% across those modeled layers. Vitamin A at 2936.21.00 has none of those duties. Classification, product-specific relief, antidumping/countervailing duties and fees require separate checks. Confirm the specific HTS line, origin, use and entry date with a licensed customs broker.

Are vitamin and mineral imports exempt from supplement tariffs?

An exemption from one tariff program does not exempt an ingredient from every program. Vitamin lines under 2936 are absent from the older China lists and are exempt from the forced-labor layer under Note 52(b). Some mineral salts are exempt from that newer layer but still carry older China duties: magnesium sulfate at 2833.21.00 has 3.7% MFN plus 25% older Section 301 duty. The Note 52(e) exemptions for listed amino acids and CoQ10 require pharmaceutical use, so supplement-use entries remain covered by the newer layer. Historical reciprocal-tariff Annex II exemptions do not cancel these duties. Check the exact HTS line and use, not only the ingredient category.

How are supplement manufacturers adapting to tariff changes?

NutraIngredients reporting from January and February 2026 describes three responses. An ingredient executive said most companies had been absorbing the 2025 tariff costs, with 40% to 60% margin declines. Some brands reshaped formulas, which a supplier executive called "skimpflation". Some suppliers diversified by selling to more overseas markets, especially Southeast Asia. For sourcing, Indian-origin goods now carry MFN duty plus the 10% forced-labor Section 301 duty on covered lines; the 18% rate announced under the February 2026 framework ended with the IEEPA duties. Ask your manufacturer about tariff exposure for each ingredient in your formulation.

Which specific supplement ingredients are exempt from tariffs in 2026?

For the China, India and EU origins modeled here, check each program separately. Vitamin lines under 2936 are exempt from the forced-labor layer under Note 52(b); listed amino acids and CoQ10 have pharmaceutical-use conditions under Note 52(e), so supplement-use entries are covered. Raw tea and turmeric can be exempt from that new layer while still carrying older China Section 301 duties. Chondroitin is classification-dependent: 3001.90.01 is exempt under Note 52(b), while 3913.90.20/.50 have pharmaceutical-use restrictions. Historical reciprocal Annex II status does not establish a current exemption. Other origins can have separate country-specific exceptions. Have a customs broker check the exact line, origin, use and entry date.

Are turmeric supplements exempt from tariffs?

It depends on the form, origin and tariff program. Chinese raw turmeric entered at 0910.30.00 has Free MFN and an older 7.5% Section 301 duty. Note 52(b) exempts it from the newer forced-labor layer, but does not remove that older duty. If a Chinese extract is entered at 1302.19.91, its modeled stack is Free MFN plus 7.5% older Section 301 plus 12.5% forced-labor duty, or 20%. During the closed Section 122 window the same covered extract example instead had a 17.5% stack. The 2025 reciprocal Annex II exemption is historical. These examples do not classify your product or include other duties and fees; confirm the exact HTS line with a customs broker.

How much do tariffs add to supplement costs in 2026?

Combined tariff rates vary significantly by ingredient category and origin. For China, the modeled current botanical band is 7.5-43.5% across MFN and the two Section 301 layers. Raw green tea at 0902.10.90 retains its older 7.5% duty but is exempt from the new layer. Covered extracts at 1302.19.91 and 1302.19.41 total 20% and 21%; chilled/frozen ginseng at 1211.20.15 totals 43.5%. During the closed Section 122 window, those covered extract and ginseng examples instead totaled 17.5%, 18.5% and 41%. A category range is not a classification or an estimate of all payable duties. On July 23, 2026 USTR took final action in the forced-labor Section 301 investigation (10-12.5% tiers; 12.5% China, 10% India, 10% net-of-MFN EU); the additional duties apply to entries on or after 12:01 a.m. eastern time July 24, 2026, with per-line exemptions: vitamins (2936) remain exempt as entered, while amino acids, CoQ10, quercetin, glutathione and steviol glycosides (pharmaceutical-use-only lines) and unlisted fish oils under heading 1504 carry the forced-labor layer on supplement-use imports. Chondroitin is form-dependent: animal-derived bulk chondroitin sulfate at 3001.90 is exempt as entered, while 3913 chondroitin lines are pharmaceutical-use-only. For context, in April 2025 UNPA's president put the effective tariff rate for a large number of dietary ingredients at between 55% and nearly 70% under the IEEPA tariffs. The Supreme Court struck down those tariffs in February 2026. India-sourced botanicals carry no reciprocal duty: the 18% rate announced under the February 2026 US-India framework rode Executive Order 14257, and Executive Order 14389 (91 FR 9437, February 25, 2026) ended the IEEPA additional ad valorem duties imposed under that order. Indian-origin botanicals now carry MFN duty (Free or 1% on the common extract lines 1302.19.91 and 1302.19.41; Free on turmeric at 0910.30.00 and dried medicinal plants at 1211.90.89) plus the 10% forced-labor Section 301 duty on covered lines for entries on or after July 24, 2026.

Tariff Snapshot for Supplement Sourcing in 2026

Recorded sources last checked on October 5, 2026. 47 of 53 recorded claims have no open issue recorded. Source check due November 4, 2026.

By Greg Huang, founder since 2009 in the dietary supplement and nutrition industry

Section 301 investigations: where they stand

Written comments in USTR's two new Section 301 investigations (structural excess capacity in 16 economies and forced labor in 60 economies) were due April 15, 2026. Forced-labor hearings were held April 28 and 29; excess-capacity hearings were scheduled to begin May 5 and continue as necessary until May 8. On June 2, 2026, USTR made findings in the forced-labor cases and proposed additional Section 301 duties of 10 percent (economies with forced-labor import prohibitions or reciprocal trade commitments) and 12.5 percent (all others) across the 60 economies, which include China, India, and Vietnam. Written comments were due July 6, 2026, and public hearings on the proposed actions were held July 7 through July 9, 2026, at the U.S. International Trade Commission. On July 23, 2026 USTR took final action imposing the tiered duties across the 60 economies; the additional duties apply to entries on or after 12:01 a.m. eastern time July 24, 2026 (goods loaded and in transit before that instant and entered before July 28, 2026 are excepted), and Annexes I and II of the Notice list product exemptions. Lines that U.S. note 52 exempts (vitamins under 2936, many mineral salts, raw tea and spice forms) are exempt from this layer as entered, but can still carry older China Section 301 duties. The excess-capacity investigation, whose initiation fact sheet lists “processed food and beverages” among 20 illustrative sectors, has no proposed action yet. Confirm your specific HTS classification and any Annex exemption with a licensed customs broker. Snapshot sources checked on October 5, 2026.

Supplement imports met three tariff programs in 2026: older Section 301 duties on Chinese goods at 7.5 or 25 percent depending on the HTS line, a temporary 10 percent Section 122 import surcharge on entries February 24 through July 23, 2026 (it terminated by operation of law at 12:01 a.m. EDT July 24, 2026), and the forced-labor Section 301 duties on entries from July 24, 2026 (12.5 percent for China, 10 percent for India). Sources: the U.S. tariff schedule, the Section 122 proclamation and the Federal Register. Each program has its own exemptions. Glycine imported from China at HTS 2922.49.43 has 4.2 percent MFN duty plus 25 percent older Section 301 duty and 12.5 percent forced-labor duty for supplement use. That is 41.7 percent across the modeled layers, before any other duties or fees. Vitamin A at 2936.21.00 has none of those duties. The U.S. supplement industry imports 80 percent of its raw ingredients from China, according to May 2025 reporting by NutraIngredients.

This page is a dated snapshot. Its recorded official government sources were checked on October 5, 2026. If you are reviewing ingredient sourcing risk, confirm the exact HTS classification, country of origin, and any applicable exclusions with a licensed customs broker. Multiple trade programs can apply to the same shipment.

The short answer

The Supreme Court struck down IEEPA tariffs on February 20, 2026. The country-specific rates from 2025 (145% China, etc.) are no longer in effect. Section 301 tariffs on China remain in effect and were NOT affected by the IEEPA ruling. A temporary Section 122 import surcharge (10% collected by CBP) covered entries made February 24 through July 23, 2026 and terminated by operation of law at 12:01 a.m. EDT July 24, 2026.

Dietary supplement manufacturers must comply with 21 CFR Part 111 (Current Good Manufacturing Practice for dietary supplements). This includes requirements for personnel, facilities, equipment, production, laboratory operations, and record-keeping.

Key Takeaways

The Supreme Court struck down IEEPA tariffs on February 20, 2026. The country-specific rates from 2025 (145% China, etc.) are no longer in effect. CBP processes refunds of IEEPA duties for importers of record through CAPE declarations.
A temporary Section 122 import surcharge (10% collected by CBP) covered entries made February 24 through July 23, 2026 and terminated by operation of law at 12:01 a.m. EDT July 24, 2026, with no extension enacted. It was additive to existing Section 301 duties inside that window; entries after it carry no Section 122 surcharge. Under the forced-labor Section 301 duty in effect since July 24, 2026, vitamins are exempt as entered, while amino acids and CoQ10 are exempt only for pharmaceutical use.
Section 301 tariffs on China remain in effect and were NOT affected by the IEEPA ruling. These are product-specific; confirm applicability by tariff list, HTS classification, and any active exclusions. Active China Section 301 product exclusions run through November 9, 2026.
In March 2026, USTR launched new Section 301 investigations into excess capacity (16 economies; an illustrative list of 20 sectors includes processed food and beverages) and forced labor (60 economies). On July 23, 2026 USTR took final action in the forced-labor cases (12.5% China, 10% India, 10% net-of-MFN EU); the additional duties apply to entries on or after July 24, 2026 with per-line Annex II exemptions (vitamins and raw spice forms exempt as entered; amino acids and CoQ10 covered for supplement use; extracts and finished preparations covered); the excess-capacity case has no proposed action yet. Confirm your HTS code and any Annex exemption.
Do not use a generic “45%+” assumption for every supplement ingredient. The correct landed-cost analysis depends on classification, origin, and which tariff programs stack for that SKU.

Official Tariff Programs to Check

These are the trade actions verifiable from official government sources checked on October 5, 2026.

Program	Official Status	Why It Matters
Section 301 China tariffs	Active for covered tariff lines. Coverage turns on the 8-digit HTS subheading in the USITC China Tariffs list and on any product exclusion in U.S. note 20; active exclusions run through November 9, 2026.	These duties are not uniform across all supplement inputs. Some products face additional duty and others do not, depending on how they are classified.
China reciprocal tariff rate	According to the White House executive order issued in May 2025, the heightened China-specific rate was suspended and a 10 percent ad valorem rate was kept in force during the suspension period. A later White House fact sheet described that 10 percent rate as remaining in place through November 10, 2026. However, the Supreme Court’s IEEPA ruling (February 20, 2026) invalidated the legal authority under which this reciprocal rate was imposed. Chinese goods faced the general Section 122 surcharge of 10 percent on entries made February 24 through July 23, 2026 (it terminated by operation of law July 24, 2026) plus older Section 301 duties of 7.5 or 25 percent by product. Since July 24, 2026, covered Chinese goods carry the 12.5 percent forced-labor Section 301 duty instead of the surcharge.	The November 10, 2026 date is from the pre-ruling IEEPA framework. For cost planning, the operative date is July 24, 2026 (Section 122 expiration and the start of the forced-labor duties). Do not plan around the November date.
IEEPA tariffs (ended)	Struck down by the Supreme Court on February 20, 2026 (Learning Resources, Inc. v. Trump). Executive Order 14389 of February 20, 2026 ordered that the IEEPA duties no longer be in effect or collected. CBP processes refund requests for IEEPA duties from importers of record and their customs brokers through CAPE declarations in ACE.	Country-specific IEEPA rates from 2025 are no longer in effect. Per Learning Resources v. Trump, the reciprocal rate on Chinese goods reached 125 percent, which brought the total effective rate on most Chinese goods to 145 percent. Do not use 2025 IEEPA rates for current cost planning.
Section 122 surcharge	The February 2026 White House proclamation (Proclamation 11012, 91 FR 9339) imposed a temporary 10 percent surcharge for entries February 24 through July 23, 2026. Its entry window ended at 12:01 a.m. EDT July 24, 2026. On May 7, 2026, the U.S. Court of International Trade ruled the surcharge unlawful (Slip Op. 26-47, State of Oregon v. United States), with an injunction limited to the named importer plaintiffs. On June 11, 2026, the Federal Circuit granted a stay of that injunction pending appeal, allowing collection during the remaining entry window. That historical stay did not extend the proclamation’s July 24 termination date.	The surcharge was additive to existing Section 301 duties within its entry window. Vitamins under 2936, CoQ10 at 2914.62.00 and many 2922 amino-acid lines were exempt under U.S. note 2(aa)(ii); glycine at 2922.49.43 was not. Entries on or after July 24, 2026 carry no Section 122 surcharge under this proclamation. The separate forced-labor Section 301 action must be checked for those entries.
Section 301 forced-labor duties	Final action July 23, 2026, published at 91 FR 47318. Additional duties of 12.5 percent for China and 10 percent for India apply to entries on or after 12:01 a.m. eastern time July 24, 2026, on top of any older Section 301 duty. U.S. note 52 lists the exempt lines.	Vitamin lines under 2936 are exempt as entered. Listed amino acids and CoQ10 are exempt only for pharmaceutical use, so supplement-use entries pay the duty. Botanical extracts under 1302.19 from China or India are covered.

How Tariffs Affect Different Ingredient Categories

The guide above warns against using a generic 45 percent or more assumption. Here is what to use instead. Not every supplement ingredient faces the same tariff exposure. Check MFN duty, older China Section 301 duties, and the newer forced-labor layer separately. For example, magnesium sulfate at 2833.21.00 is exempt from the new layer but retains its older 25 percent China duty plus 3.7 percent MFN. The expired Section 122 surcharge and the historical reciprocal-tariff exemptions have separate rules. Current rates depend on the ingredient's origin, use, entry date and HTS classification.

Historical table: these statuses describe the 2025 reciprocal-tariff Annex II, a program invalidated in February 2026. They do not establish an exemption from older China Section 301 duties or the newer forced-labor layer. For example, raw tea can be exempt from the new layer while retaining an older 7.5% China duty. Check the current rate matrix and each program's rules for your HTS line, origin and use.

Ingredient	Status	Legal Basis	HTS Chapter
Was exempt under the reciprocal-tariff program (invalidated February 20, 2026 — historical status)
Vitamin C (ascorbic acid)	Exempt	2936 vitamin lines are absent from the older China lists; historical reciprocal Annex II and Section 122 exemptions; FL action (Jul 24, 2026): exempt as entered (2936, Note 52(b))	2936
Vitamin D	Exempt	2936 vitamin lines are absent from the older China lists; historical reciprocal Annex II and Section 122 exemptions; FL action (Jul 24, 2026): exempt as entered (2936, Note 52(b))	2936
Vitamin B12	Exempt	2936 vitamin lines are absent from the older China lists; historical reciprocal Annex II and Section 122 exemptions; FL action (Jul 24, 2026): exempt as entered (2936, Note 52(b))	2936
Folic acid	Exempt	2936 vitamin lines are absent from the older China lists; historical reciprocal Annex II and Section 122 exemptions; FL action (Jul 24, 2026): exempt as entered (2936, Note 52(b))	2936
Niacin (Vitamin B3)	Exempt	2936 vitamin lines are absent from the older China lists; historical reciprocal Annex II and Section 122 exemptions; FL action (Jul 24, 2026): exempt as entered (2936, Note 52(b))	2936
Coenzyme Q10	Exempt	Listed in Annex II and on the Section 122 exempt list at 2914.62.00, the HTS line named for Coenzyme Q10; no older China-list duty. FL action (Jul 24, 2026): covered for supplement use, because Note 52(e) lists 2914.62.00 and the neighboring 2914.69 quinone lines for pharmaceutical applications only	2914.62
Quercetin	Exempt	Listed in Annex II at 2932.99.61, where CBP classifies quercetin dihydrate (NY L88698); no older China-list duty. FL action (Jul 24, 2026): covered for supplement use (2932.99 lines pharmaceutical-use-only under Note 52(e))	2932
Chondroitin	Exempt	Annex II; FL action (Jul 24, 2026): FORM-DEPENDENT — animal-derived bulk chondroitin sulfate for dietary supplements classifies at 3001.90 (CIT Slip Op. 05-48; CBP R02835), and the eight-digit subheading 3001.90.01 is Note 52(b)-exempt as entered; forms classified under 3913.90.20/.50 are Note 52(e)-listed (pharmaceutical applications only) and covered for supplement use — verify your line	3001.90 / 3913 (form-specific)
Glutathione	Exempt	Listed in Annex II at 2930.90.49, where CBP classifies L-glutathione reduced (NY N272128). Older China list: 9903.88.03 (+25%). FL action (Jul 24, 2026): covered for supplement use (2930.90 lines pharmaceutical-use-only under Note 52(e))	2930
EPA (eicosapentaenoic acid)	Exempt	Listed in Annex II at 2916.19.50, where CBP classifies purified EPA ethyl ester (icosapent ethyl, NY N298124); no 1504 fish-oil line was listed. Older China list: 2916.19.50 at 9903.88.03 (+25%). FL action (Jul 24, 2026): covered for supplement use (2916.19.50 pharmaceutical-use-only under Note 52(e); 1504 not listed)	2916.19 / 1504 (form-specific)
DHA (docosahexaenoic acid)	Exempt	Listed in Annex II at 2916.19.50, where CBP classifies DHA ethyl ester (NY 869683); no 1504 fish-oil line was listed. Older China list: 2916.19.50 at 9903.88.03 (+25%). FL action (Jul 24, 2026): covered for supplement use (2916.19.50 pharmaceutical-use-only under Note 52(e); 1504 not listed)	2916.19 / 1504 (form-specific)
Amino acids (lysine, etc.)	Exempt	Historical reciprocal Annex II and Section 122 exemptions covered lysine (2922.41.00) and several other 2922.49 lines, but not glycine (2922.49.43); older China Section 301 duties must be checked separately (glycine 2922.49.43 carries 25%); FL action (Jul 24, 2026): covered for supplement use (2922 lines pharmaceutical-use-only under Note 52(e))	2922/2930
Stevia	Exempt	Listed in Annex II at 2938.90.00, where CBP classifies stevia leaf extract (NY N051978), from April 2025 until the reciprocal tariffs ended in February 2026; no 1302 extract line and no 1212 dried-leaf line was listed. No older China-list duty on 2938.90.00. FL action (Jul 24, 2026): covered for supplement use (2938.90.00 pharmaceutical-use-only under Note 52(e); 1302 not listed)	2938.90 / 1302 (form-specific)
Historical Annex II: form-dependent (raw exempt, extract not exempt)
Turmeric Exemptpowder (root form)(0910.30) Not exemptextract (curcuminoids)(1302.19)
Green and black tea Exemptleaf and powder(0902) Not exemptconcentrated polyphenol extract(1302.19)
Ginger Exemptroot and powder(0910) Not exemptextract (gingerols)(1302.19)
Cinnamon Exemptbark and powder(0906) Not exemptextract(1302.19)
Fenugreek Exemptseed(0910) Not exemptextract(1302.19)
Not exempt under historical Annex II
Ashwagandha	Not exempt	Section 301. Not listed in Annex II. FL action: covered (1211/1302 not listed)	1211/1302
Elderberry	Not exempt	Section 301. Not in Annex II. FL action: covered (1302 not listed)	1302
Ginseng	Not exempt	Section 301. Not in Annex II. FL action: covered (1211/1302 not listed)	1211/1302
Black cohosh	Not exempt	Section 301. Not in Annex II. FL action: covered (1211 not listed)	1211
Boswellia	Not exempt	Section 301 (1301.90.91 at 9903.88.15, +7.5%). Not listed in Annex II. FL action: covered for China, India and EU origin; Note 52(j) exempts Boswellia (1301.90.91) only for certain named origins, such as Malaysia and Taiwan	1301/1302
Bacopa	Not exempt	Section 301. Not listed in Annex II. FL action: covered (1211/1302 not listed)	1211/1302
Psyllium	Not exempt	Section 301 (1211.90.89 at 9903.88.03, +25%). Not listed in Annex II (no 1211 line was listed). FL action: covered for China, India and EU origin; Note 52(j) exempts psyllium seed husks (1211.90.89) only for certain named origins, such as Malaysia and Taiwan	1211
Mushroom supplements	Not exempt	Section 301. Not listed in Annex II. FL action: covered (Note 52(c) lists 2106.90.99 only for acai beverage preparations)	2106
Probiotic ingredients	Not exempt	Annex II did not list 2106.90.99 or the 1901.90 lines where CBP has classified probiotic powders (HQ H253254); it did list 3002.90.10 (ferments) and 3002.90.52. Older China list: 2106.90.99 at 9903.88.15 (+7.5%). FL action: 2106.90.99 covered; 3002.90.10 and 3002.90.52 exempt as entered under Note 52(b), so verify your line	1901/2106/3002
Fish oil	Not exempt	Not listed in Annex II or on the Section 122 exempt list (no 1504 line). Purified EPA and DHA ethyl esters classify at 2916.19.50 (CBP NY N298124, NY 869683), which both lists covered. Older China list: 1504.20.60 at 9903.88.03 (+25%). FL action: covered (1504 not listed)	1504

Source: Annex II exemptions (April 2025, expanded November 2025), NPA, AHPA. Forced-labor Section 301 layer: USTR final action, July 23, 2026, published at 91 FR 47318 (July 28, 2026), Dockets USTR-2026-0265/0266. Exemption status can change. Verify your specific HTS code with a licensed customs broker before making sourcing commitments. Data verified 2026-10-05.

This split matters for product development. A Chinese-origin multivitamin input built on vitamin lines under 2936 carries no China Section 301 duty, while turmeric and ashwagandha extracts under 1302.19 carry both Section 301 layers. Knowing which category your key ingredients fall into is the first step toward an accurate landed-cost model.

New Section 301 Investigations (March 2026)

USTR initiated two new sets of Section 301 investigations on March 11 and March 12, 2026. Neither initiation notice names dietary supplements. The forced-labor action now reaches products of the investigated economies, and the excess-capacity sector list includes processed food and beverages.

Excess Capacity Investigation

USTR is investigating structural excess capacity in manufacturing sectors across 16 economies including China, India, the EU, Vietnam, and Japan. Its initiation fact sheet gives an illustrative list of 20 sectors, and “processed food and beverages” is among them. The notice scheduled public hearings at the U.S. International Trade Commission to begin May 5, 2026 and continue as necessary until May 8. The investigation has no proposed action yet.

Forced Labor Investigation

According to USTR's forced-labor fact sheet, the 60 investigations initiated March 12, 2026 focus on 60 top U.S. trading partners, “collectively covering more than 99% of U.S. imports in 2024,” and concern the enforcement of forced-labor import prohibitions. China, India, and Vietnam are among them. The International Labour Organization estimates that, as of 2021, 28 million people globally are in forced labor, an increase of 2.7 million since 2016. Public hearings were held April 28 and 29, 2026. On June 2, 2026, USTR made findings and proposed additional Section 301 duties of 10 to 12.5 percent across these economies; written comments were due July 6, 2026, and public hearings on the proposed actions were held July 7 through July 9, 2026, at the U.S. International Trade Commission.

What this means for supplement brands

As of October 5, 2026, the forced-labor investigation has reached final action: on June 2, 2026 USTR proposed additional Section 301 duties of 10 percent (economies with forced-labor import prohibitions or reciprocal trade commitments) to 12.5 percent (all others), the comment window closed July 6, public hearings were held July 7 through 9, 2026, and on July 23, 2026 USTR took final action imposing the tiered duties. The additional duties apply to entries on or after 12:01 a.m. eastern time July 24, 2026 (goods loaded and in transit before that instant and entered before July 28, 2026 are excepted), and Annexes I and II of the Notice list product exemptions. The excess-capacity investigation has no proposed action yet. These duties are additive to existing Section 301 duties; the Section 122 surcharge terminated by operation of law before they took effect, so the two never stack. Brands sourcing heavily from China or India should monitor the exemption mapping and confirm their HTS codes with a customs broker.

In March 2026, the law firm Troutman Pepper described the investigations as running on “relatively compressed timelines” and expected USTR “to move quickly once the records are developed.” Final action in the forced-labor investigations came on July 23, 2026, the day before the Section 122 surcharge terminated by operation of law. In practice a brand sees the surcharge drop away and, on covered lines, the new Section 301 duties arrive at the same July 24, 2026 entry instant. Troutman Pepper reads the investigations, because Section 122 is time-limited, as “an effort to build a more durable, litigation-resistant legal foundation for long-term trade measures.”

Sources: Federal Register notices 2026-05214 and 2026-05151 (March 17, 2026), 2026-11296 (June 5, 2026) and 2026-15181 (July 28, 2026); USTR fact sheets, March 2026; Troutman Pepper, March 16, 2026. See Primary Sources Checked below.

Botanical Exemption Details

Not all botanicals face the same tariff exposure. A November 2025 order moved 57 commodity codes that AHPA members import against into Annex II, fully exempting them from the reciprocal tariffs then in force; AHPA credits its own advocacy. Read that as history: the reciprocal-tariff program rested on IEEPA, which the Supreme Court held does not authorize tariffs (decided February 20, 2026). What survives is the distinction the exemptions drew, between raw botanical forms and concentrated extracts, because the July 2026 forced-labor action draws the same line.

That raw-versus-extract split is the part still worth planning around. Raw turmeric (0910.30) and tea leaf sit in the forced-labor action's exempt-as-entered list; concentrated curcuminoid and polyphenol extracts (1302.19) do not. If your formulation uses extracts, do not assume it shares the raw form's status. Verify your specific HTS code. See the ingredient table above for form-dependent status.

The gaps AHPA reported in December 2025 show how narrow the old exemptions were: ashwagandha was “not found anywhere in the executive orders.” A separate November 2025 annex offered relief only through a bilateral trade agreement, and its entry for “other” vegetable extracts covered only four specific extracts.

Source: SupplySide Supplement Journal, “AHPA’s initial tariff relief success, ongoing efforts” (December 19, 2025); White House Annex II; U.S. tariff schedule, chapter 99, U.S. note 52; Learning Resources, Inc. v. Trump, No. 24-1287 (Feb 20, 2026).

How Tariff Costs Have Changed Since 2025

The tariff landscape for supplement ingredients has shifted dramatically since 2025. In April 2025, at the start of the IEEPA tariff era, UNPA President Loren Israelsen put the effective tariff rate for a large number of dietary ingredients at between 55 percent and nearly 70 percent (SupplySide, April 3, 2025). The reciprocal rate on Chinese goods then reached 125 percent, which brought the total effective tariff rate on most Chinese goods to 145 percent (Learning Resources, Inc. v. Trump).

The Supreme Court struck down IEEPA tariffs on February 20, 2026 (Learning Resources, Inc. v. Trump). Those rates are no longer in effect. The current regime is lower but still significant.

Program	Rate	Status
IEEPA reciprocal tariffs	10 to 125 percent by country	Struck down (Feb 2026)
Section 301 (China)	7.5-25% by HTS code	Active
Section 122 surcharge	10% on products of any country, with listed exemptions	Entries Feb 24 – Jul 23, 2026; terminated by law 12:01 a.m. EDT Jul 24, 2026
Section 301 forced labor (2026)	12.5% China, 10% India, 10% net-of-MFN EU (final Jul 23, 2026)	Active (entries on or after Jul 24, 2026; in-transit exception through Jul 27; some U.S. note 52 chemical exemptions are pharmaceutical-use-only)
Section 301 excess capacity (2026)	None proposed	Investigation open; no proposed action

Current Chinese botanical examples range from 7.5 percent for green tea at 0902.10.90 to 43.5 percent for chilled or frozen ginseng at 1211.20.15 across MFN and the two Section 301 layers. The common extract lines 1302.19.91 and 1302.19.41 total 20 and 21 percent. During the closed Section 122 window, those extract and ginseng examples instead totaled 17.5, 18.5 and 41 percent. An exemption from the new layer does not erase older China duties. These examples exclude other duties and fees; they should not be used as a rate for every botanical.

Sources: UNPA via SupplySide (April 3, 2025); Learning Resources, Inc. v. Trump (February 20, 2026); U.S. tariff schedule (current release); Federal Register. IEEPA-era figures are historical context, not current rates.

India Sourcing: Relief and Disruption

A February 2026 framework trade deal was announced as cutting tariffs on Indian imports from 50 percent to 18 percent (NutraIngredients, February 4, 2026). That 18 percent rate is no longer operative: it rode Executive Order 14257, and Executive Order 14389 (91 FR 9437, February 25, 2026) ended the IEEPA duties imposed under that order. Indian-origin ingredients now carry MFN duty (Free or 1 percent on the common extract lines 1302.19.91 and 1302.19.41; Free on turmeric at 0910.30.00, dried medicinal plants at 1211.90.89 and gum resins at 1301.90.91) plus the 10 percent forced-labor Section 301 duty on covered lines for entries on or after July 24, 2026. For brands sourcing turmeric, ashwagandha, or boswellia from India on those lines, today's duty stack is lower than either the 50 percent peak or the framework's announced 18 percent.

The same February 2026 reporting flagged a complication. Shaheen Majeed, global CEO and managing director of Sabinsa, said Indian farmers had begun moving from supplement-essential crops to crops less affected by tariffs, and that those decisions were based on planting cycles that span months or even years. The crops he named are turmeric, black pepper, amla, and ashwagandha (NutraIngredients, February 4, 2026). Psyllium husk and boswellia sit in a different bucket: AHPA said it had been working with U.S. federal agencies and the Embassy of India on tariffs on those, which is not the same as farmers moving away from them.

Lower duties do not automatically mean normal supply. Availability depends on planting cycles, and Majeed said a tariff reduction could help “but it won’t be immediate.” Brands sourcing these ingredients from India should confirm current availability and lead times directly with their suppliers.

How Tariff Pressure Is Affecting Product Quality

Tariff costs can also create quality pressure. In NutraIngredients reporting (January 9, 2026), a supplier executive used the term “skimpflation” for brands reshaping product formulas as tariff costs rose. The article gives turmeric at 20 percent versus 95 percent curcuminoids as an example. It does not establish a health-benefit comparison between those concentrations.

Separately, NutraIngredients (March 3, 2026) reported that a company's testing of some 44 popular supplements sold on Amazon in the prior year found that roughly half failed to meet basic label accuracy standards. These are the company's reported sample results. They do not establish a market-wide failure rate or show that tariffs caused the label failures.

When your manufacturer changes ingredient sources to manage tariff costs, the risk is not just price. It is potency, purity, and whether the new source passes the same identity testing and COA standards as the original. As Robert Marriott, then director of regulatory affairs at the American Herbal Products Association, put it, “Many companies in many industries, dietary supplements and elsewhere, are going to have to make difficult, sometimes impossible, decisions about price of their products, their ability to continue in business and what options they have in terms of sourcing” (SupplySide, April 17, 2025).

This is why independent verification matters more in a high-tariff environment. If your manufacturer is switching suppliers, ask for fresh Certificates of Analysis from a third-party lab, not just the new supplier's documentation.

How Manufacturers Are Adapting

According to May 2025 NutraIngredients reporting, the U.S. supplement industry imports 80 percent of its raw ingredients from China. AHPA describes many essential botanicals as not available domestically, now officially recognized as “unavailable natural resources” (SupplySide, December 19, 2025). So how are companies responding?

Selling to new markets: NutraIngredients reported that 2025 tariffs pushed supplement companies to diversify by selling to more overseas markets, especially Southeast Asia.
India duty drop: the February 2026 framework deal's announced 18 percent rate was terminated with the IEEPA duties it rode (Executive Order 14389, 91 FR 9437, February 25, 2026), and Indian-origin ingredients now enter at MFN duty plus the 10 percent forced-labor Section 301 duty on covered lines. A covered line from China carries 12.5 percent plus any older Section 301 duty instead.
Speed depends on preparation: Cepham CEO Anand Swaroop said companies that maintain supplier relationships can pivot within 60 to 90 days, while those who abandoned Indian sourcing entirely face 6 to 12 months to re-qualify suppliers and rebuild trust.
Margin compression: Suresh Lakshmikanthan of Natural Remedies said most companies had been absorbing the 2025 tariff costs, resulting in 40% to 60% margin declines. That is one executive's account, not a measured industry figure.
Inventory buffers: one mushroom-ingredient supplier said it did not have the capacity, financing or warehousing to pull six to 12 months of inventory forward as large retailers could.

Source: NutraIngredients, January 2026 and February 2026 reporting.

Real example: Whey Protein Isolate

Whey protein isolate reached $11 per pound, or $24,250 per metric ton, a level “never seen before in the market,” Vesper reported on 20 November 2025. U.S. producers had already sold forward well into 2026, and Vesper ties the shortage to demand from GLP-1 medication users. If your formulation depends on whey, budget for current spot prices, not historical averages.

What Brands Can Responsibly Infer

Operational implications for brand owners:

Rebuild landed-cost models at the SKU level rather than applying a single tariff percentage across an entire ingredient catalog.
Ask manufacturers and suppliers to identify the HTS code and declared country of origin for the materials that drive the most margin risk.
When you qualify alternate suppliers, preserve fresh COAs, identity testing, and documented change control so cost pressure does not weaken quality controls.
Confirm the Section 122 surcharge dropped off your entries dated July 24, 2026 or later, and price in the forced-labor Section 301 duties that apply to entries from that same instant (10-12.5% tiers; vitamins and many mineral salts are exempt as entered under U.S. note 52, while pharmaceutical-use-only chemical lines are covered for supplement use).
Check whether an active China Section 301 product exclusion covers your HTS line; those exclusions run through November 9, 2026.

Quality control reminder: If you change ingredient suppliers or origins, refresh your lot-level review, COA checks, and any required identity or stability work before assuming the new source is equivalent.

Questions to Ask Suppliers Now

What HTS code and declared country of origin are you using for this material today?
Which of your core inputs are currently sourced from China, and which have active non-China alternatives?
Now that the Section 122 surcharge terminated on July 24, 2026, how quickly will your pricing reflect its removal?
If you switch source countries, what new testing, documentation, or change-control steps will you complete before release?
Which of your inputs carry the forced-labor Section 301 duty, and which U.S. note 52 exemptions, if any, do you claim at entry?

Primary Sources Checked

Recorded sources checked on October 5, 2026. Re-check before relying on this page for a live procurement or pricing decision.

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Greg Huang, founder since 2009 in the dietary supplement and nutrition industry

Founder of Inventory Ready. Previously founded and operated multiple consumer brands in the dietary supplement and nutrition industry since summer 2009.

Concepts Covered

Ingredient Sourcing MOQ (Minimum Order Quantity)Lead Time HTS Code (Harmonized Tariff Schedule)COA (Certificate of Analysis)

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