Amazon FBA Import Duty 2026: What Sellers Actually Pay

Amazon Is Not Automatically the Importer of Record

CBP collects duty from the importer of record — the party named on the entry. Amazon FBA does not automatically become IOR when goods arrive at a fulfillment center. In the typical seller-import model, you (or your US entity) are the IOR: you post the bond if the shipment is over $2,500 or PGA-regulated, you classify the goods, and you pay the duty. Some sellers use a third-party IOR service or a US buyer of record; that is a contract choice, not an Amazon default.

If you are a first-time IOR, start with the first-time importer guide: Form 5106, a single-entry or continuous bond, and a licensed broker filing through ACE. Keep the commercial invoice, packing list, bill of lading, and CBP Form 7501 for five years. Those records are what later IEEPA refund or duty drawback claims are built from.

The 2026 Duty Stack on FBA Inventory

Treat FBA inbound like any other commercial import:

1. MFN / column-1 duty from the HTS line (often Free on electronics, 10–20% on many apparel lines).
2. Section 301 forced-labor tariff — 10% standard or 12.5% for the higher-tier list (China, Vietnam, Brazil, and other named economies). This replaced the expired 10% Section 122 rate on July 24, 2026.
3. China Section 301 (7.5–100% by list) if origin is China or Hong Kong (EO 13936 treats HK as CN).
4. Section 232 if the heading is covered: 50% on articles wholly of steel/aluminum/copper (25% on derivatives; no forced-labor stack on the metal content); 25% auto 232 on 8702/8703/8704; 25% semiconductor 232 on 8541/8542 that does stack with forced-labor; 25% or 100% UAS 232 on 8806 as of September 3, 2026.
5. EU-US deal: most EU-origin goods pay a 15% all-inclusive ceiling (July 1, 2026). Aircraft 8802/8803 from the EU are MFN-only as of September 1, 2026.

USMCA zeros the forced-labor layer on qualifying Mexican or Canadian goods — except Canadian autos and furniture under Section 338 (50%, USMCA-blind, effective August 22, 2026). KORUS and AUSFTA zero MFN only; they do not cancel forced-labor or 232.

Worked Examples: $10,000 of FBA Inventory

These are calculator-style estimates, not a broker invoice.

• Vietnamese phone cases, HTS ~3926, 0% MFN: Vietnam is in the 12.5% forced-labor tier. Duty ≈ $1,250. No China 301.
• Chinese electronics accessories with 25% China 301: 12.5% forced-labor + 25% 301 = 37.5% → about $3,750.
• Chinese steel hardware, wholly of steel: 50% Section 232 + 25% China 301 = 75%. Forced-labor does not stack on the metal content.
• German small appliances under the EU deal: 15% all-inclusive ceiling → $1,500, unless the HTS MFN is already 15% or higher (then MFN only).

On top of duty, budget the Merchandise Processing Fee (0.3464%, FY2026 min $33.58 / max $651.50 on formal entries) and 0.125% Harbor Maintenance Fee on ocean arrivals. Amazon's inbound placement and prep fees are separate and are not customs charges.

Declared Value, First Sale, and What Amazon Sees

CBP duty is calculated on customs value — generally the price actually paid or payable for the goods when sold for export to the United States, plus certain assists and packing. FBA referral fees, Amazon storage, and the price you later list at on the retail page are not the customs value.

A factory invoice of $8 and a $28 Amazon list price is normal. Declaring $8 when you actually paid $8 is correct; declaring $8 when you paid $18 is not. CBP can examine FBA inbound like any other entry. Mis-valuation and HTS shopping to stay under a rate are the two fastest ways to turn a profitable ASIN into a penalty file.

If a supplier offers to 'undervalue the invoice for customs,' that is a request to file a false entry. Decline it.

Prep, Labeling, and Re-boxing Do Not Reclassify the Good

FBA prep — poly-bagging, FNSKU labels, inserting inserts, bundling two units — almost never changes the HTS heading. Classification follows the article's essential character, not the Amazon-ready packaging. A cotton t-shirt labeled for FBA is still a cotton t-shirt. A steel bracket in a retail box is still a steel article for Section 232.

Sets and kits are the exception: GRI 3 can classify a gift set by essential character or, if that fails, by the heading that occurs last. If you are building FBA bundles from separately imported components, classify (and pay) each inbound component on its own entry, then worry about the retail kit later.

IEEPA Refunds on 2025 FBA Inbound — and the Scam Wave

If you imported FBA inventory between April 2025 and February 2026 and paid IEEPA reciprocal duties, those IEEPA layers are refundable through CAPE. CBP's August 21, 2026 update to the Court of International Trade reported about $132.5 billion accepted for processing and $106.6 billion certified to Treasury. Phase 3 for finally liquidated entries is delayed (CBP August 25 filing; no new date). File as the IOR; Amazon will not file your CAPE declaration for you. Start with how to claim an IEEPA refund and the tariff-refunds hub.

Scam warning: there is no approved consumer 'tariff dividend' or $2,000 government check. Anyone asking you to pay a fee for a personal refund check is running a scam. Refunds of IEEPA duty go to the importer of record via ACH, not to Amazon customers as a stimulus payment. Master Plan's conversion path, if you want a licensed filer, is Tariff Recovery Today powered by Irongate — a filing team, not attorneys, and not legal advice.