How do current tariffs affect supplement ingredient costs in 2026?

Multiple tariff programs overlap for supplement imports in 2026. The Supreme Court struck down IEEPA-based tariffs on February 20, 2026, eliminating the country-specific reciprocal rates (including 145% on China). Two programs then applied: Section 301 tariffs on Chinese goods (7.5-25% depending on category) from the 2018-2019 trade actions, and a temporary 10% Section 122 import surcharge on most non-exempt imports, covering entries made February 24 through July 23, 2026; it terminates by operation of law at 12:01 a.m. EDT July 24, 2026 under its 150-day statutory limit. Inside that window a Chinese botanical extract could face 35%+ in combined duties; for entries on or after July 24, 2026 the Section 301 band applies together with the forced-labor Section 301 duties USTR finalized on July 23, 2026 (12.5% for Chinese goods, 10% for India, 10% net-of-MFN for the EU; in-transit goods loaded before the effective instant and entered before July 28, 2026 are excepted). Vitamins, amino acids, CoQ10, and certain minerals are exempt from the 2018-19 Section 301 lists and were exempt from Section 122; under the forced-labor action, coverage splits by HTS line: vitamins (2936) and many mineral salts are exempt as entered, while amino acids (2922) and CoQ10 (2914.62.00) are exempt only for pharmaceutical applications, so supplement-use imports of those carry its 10-12.5% duty. Check current HTS codes for your specific ingredients, as rates change frequently. Rates verified against CIT Slip Op 26-47, the Federal Circuit's June 11, 2026 stay order, CBP CSMS 67844987, and Fed Reg 91 FR 03824; re-checked July 21, 2026: the stay remains in effect, no merits decision has issued, and no Congressional extension legislation was pending; forced-labor final action verified July 24, 2026 against the pre-publication USTR notice (Dockets USTR-2026-0265/0266). Verify at usitc.gov before making procurement decisions. Section 122 legal-status note: on May 7, 2026 the U.S. Court of International Trade ruled Section 122 unlawful (Slip Op. 26-47, Burlap & Barrel / Oregon v. Trump consolidated) with a permanent injunction limited to the named plaintiff importers; on June 11, 2026 the U.S. Court of Appeals for the Federal Circuit granted a stay pending appeal, so CBP collects the 10% surcharge from all importers (including the plaintiffs) through the end of the entry window while the merits appeal proceeds.

Are vitamin and mineral imports exempt from supplement tariffs?

Many common supplement ingredients have exemptions from the earlier tariff programs. Vitamins, amino acids, CoQ10, and certain minerals are exempt from the 2018-19 Section 301 lists and were exempt from the Section 122 surcharge (which covered entries February 24 through July 23, 2026 and terminated by operation of law July 24, 2026). The forced-labor Section 301 duties effective July 24, 2026 are a separate layer with per-line exemptions: vitamins (2936) and many mineral salts are exempt as entered, while amino acids (2922) and CoQ10 (2914.62.00) are exempt only for pharmaceutical applications, so supplement-use imports of those are covered at 10-12.5% by origin. Botanical extracts and most specialty ingredients have no exemptions in these programs and face the full stack, though a few specialty classifications are exceptions (for example animal-derived chondroitin sulfate at 3001.90 and certain 3002.90 culture lines, which the forced-labor action exempts as entered). Always verify the current rate for your specific ingredient's HTS code through the USITC Harmonized Tariff Schedule, as exemptions can be modified or revoked.

How are supplement manufacturers adapting to tariff changes?

Manufacturers are responding through several strategies: diversifying sourcing away from China toward India, Vietnam, and domestic suppliers; stockpiling key ingredients before announced tariff increases; renegotiating supplier contracts with tariff-sharing clauses; reformulating products to use ingredients with lower tariff classifications; and in some cases, absorbing costs rather than raising prices. The India trade deal (early 2026) created new sourcing opportunities. Brands should ask their manufacturers directly about tariff exposure and mitigation strategies for each ingredient in their formulations.

Which specific supplement ingredients are exempt from tariffs in 2026?

Under the 2025 Annex II exemptions, the following supplement ingredients are exempt from reciprocal tariffs: letter vitamins (B6, B12, C, folic acid, niacin), major minerals, CoQ10, quercetin, chondroitin, glutathione, EPA, DHA, common amino acids, and stevia. Stevia is the only botanical with a full exemption. Turmeric, ginger, cinnamon, green tea, and fenugreek are exempt in their raw powder or leaf form but their concentrated extracts remain subject to full tariff rates. Ashwagandha, elderberry, ginseng, black cohosh, boswellia, and most other medicinal herbs are not exempt in any form. Important update: those statuses cover the earlier programs, and the forced-labor Section 301 duties effective July 24, 2026 add their own per-line split. Under that action's U.S. Note 52, vitamins (2936), many mineral salts, and raw tea/spice forms (tea, cinnamon, ginger, turmeric) stay exempt as entered; amino acids, CoQ10, quercetin, glutathione, and 3913 chondroitin lines are exempt only for pharmaceutical applications, so supplement-use imports of those carry 10-12.5% by origin; and unlisted lines (stevia, EPA, DHA, botanical extracts, medicinal herbs) are covered. Chondroitin splits by classification: animal-derived bulk chondroitin sulfate classified at 3001.90 is exempt as entered under Note 52(b), per the Court of International Trade and CBP classification rulings for dietary-supplement chondroitin. The American Herbal Products Association is currently advocating for extract exemptions. Verify your specific ingredient's HTS code with a customs broker, as exemption status can change.

Are turmeric supplements exempt from tariffs?

It depends on the form. Turmeric powder (ground root) was added to the Annex II exemption list in November 2025, making it exempt from reciprocal tariffs. However, turmeric extract (concentrated curcuminoids, typically classified under HTS 1302.19) is not exempt and faces Section 301 tariffs of 7.5-25%, plus the 10% Section 122 surcharge on entries made February 24 through July 23, 2026 (the surcharge terminated by operation of law July 24, 2026), plus the 12.5% forced-labor Section 301 duty on Chinese-origin entries on or after July 24, 2026. The raw-vs-extract split carries into the forced-labor action too: raw turmeric powder (0910.30) is in that action's exempt-as-entered list, while turmeric extract (1302.19) is not. This distinction matters because most supplement formulations use standardized turmeric extracts (such as 95% curcuminoids), not raw turmeric powder. If your formulation uses turmeric extract, do not assume it shares the exemption of the raw form. Check the specific HTS classification with your customs broker.

How much do tariffs add to supplement costs in 2026?

Combined tariff rates vary significantly by ingredient category and origin. For non-exempt Chinese botanicals entered February 24 through July 23, 2026, combined duties range from approximately 17.5-35% (Section 301 at 7.5-25% plus Section 122 at 10%); for entries after that window the Section 122 layer terminates by operation of law and the stack becomes the 7.5-25% Section 301 band plus the 12.5% forced-labor Section 301 duty (roughly 20-37.5% combined). 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 (pharmaceutical-use-only lines), and unlisted lines like stevia, EPA, and DHA 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, during the IEEPA tariff era (April 2025 through February 2026), UNPA estimated effective rates of 55-70% for many dietary ingredients. The Supreme Court struck down those rates in February 2026. Real-world impact for brands has been 5-10% COGS increases and 10-15% retail price increases. India-sourced botanicals face 18% permanent duty, down from 50% under the previous escalated rate.

Tariff Snapshot for Supplement Sourcing in 2026

Last reviewed: July 24, 2026 | Next review: August 14, 2026

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

Section 301 investigations: July 2026 update

USTR Section 301 public comment periods for two new investigations (structural excess capacity in 16 economies and forced labor in 60 economies) closed April 15, 2026; public hearings were held April 28 through May 1 (forced labor) and May 5 through May 8 (excess capacity). 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) to 12.5 percent (all others) across the 60 economies, which include major supplement-ingredient origins such as China, India, and Vietnam. The written-comment window closed July 6, 2026 and public hearings were held July 7 through July 9, 2026at 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. Rate figures on this page now apply this layer as a date-gated, per-HTS-line split: entries on or after July 24, 2026 carry the forced-labor duty on covered lines, while Note 52-exempt lines (vitamins 2936, many mineral salts, raw tea and spice forms) stay at their base rate. The in-transit exception keys on lading date and is noted in prose. The excess-capacity investigation (covering “processed food and beverages” among about 20 sectors) has not yet produced a proposed action. Confirm your specific HTS classification and any Annex exemption with a licensed customs broker. Snapshot confirmed against official sources on July 24, 2026.

Supplement imports face three overlapping tariff programs in 2026: Section 301 tariffs on Chinese goods at 7.5 to 25 percent by ingredient category, a temporary 10 percent Section 122 import surcharge covering entries February 24 through July 23, 2026 (it terminates by operation of law at 12:01 a.m. EDT July 24, 2026), and new Section 301 investigations covering “processed food and beverages” among other sectors (source: USTR Section 301 schedules and Section 122 proclamation). A Chinese botanical extract entered inside the surcharge window can face roughly 35 percent or more in combined duties; entries on or after July 24, 2026 carry the Section 301 band plus the 12.5 percent forced-labor Section 301 duty finalized July 23, 2026. Vitamins, amino acids, and CoQ10 are exempt from the earlier two programs; under the forced-labor action vitamins stay exempt as entered, while amino acids and CoQ10 are covered for supplement use (their chemical exemptions are pharmaceutical-use-only). About 80 percent of raw nutraceutical ingredients originate from China according to NutraIngredients industry reporting.

This page is a dated snapshot confirmed against official government sources on July 24, 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) covers entries made February 24 through July 23, 2026 and terminates 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. Importers may be eligible for refunds.
A temporary Section 122 import surcharge (10% collected by CBP) covers entries made February 24 through July 23, 2026 and terminates by operation of law at 12:01 a.m. EDT July 24, 2026 (as of July 21, 2026 no extension had been enacted). It is additive to existing Section 301 duties inside that window; entries after it carry no Section 122 surcharge. Vitamins, amino acids, and CoQ10 are exempt.
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.
In March 2026, USTR launched new Section 301 investigations into excess capacity (16 economies, ~20 sectors including 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, CoQ10, extracts, and finished preparations covered for supplement use); 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 that were verifiable from official government sources on July 24, 2026.

Program	Official Status	Why It Matters
Section 301 China tariffs	Active for covered tariff lines. USTR continues to direct importers to determine coverage by tariff list, HTS classification, and exclusion status.	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 face the general Section 122 surcharge of 10 percent on entries made February 24 through July 23, 2026 (it terminates by operation of law July 24, 2026) plus Section 301 duties of 7.5 to 25 percent by product.	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). 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). IEEPA tariffs ended February 24, 2026. Importers who paid IEEPA duties may be eligible for refunds via CBP.	Country-specific IEEPA rates from 2025 (per SCOTUS Learning Resources v. Trump, rates had peaked at 145 percent on China) are no longer in effect. Do not use 2025 IEEPA rates for current cost planning.
Section 122 surcharge	According to the February 2026 White House proclamation (Proclamation 11012, 91 FR 03824), a temporary import surcharge was imposed for up to 150 days, covering entries February 24 through July 23, 2026 and terminating by operation of law at 12:01 a.m. EDT July 24, 2026 (no extension enacted as of July 21, 2026). CBP collects it at 10 percent through the end of that entry window (CBP CSMS 67844987). A 15 percent rate was announced on February 22 but no formal proclamation has been issued for the increase. On May 7, 2026, the U.S. Court of International Trade ruled Section 122 unlawful (Slip Op. 26-47, Burlap & Barrel / Oregon v. Trump consolidated; Court Nos. 26-01472 + 26-01606), holding that the statute’s balance-of-payments prerequisite was not satisfied. The court issued a permanent injunction LIMITED to the named plaintiff importers (Burlap & Barrel, Basic Fun!, State of Washington); CBP continues collection for all non-party importers. DOJ filed notice of appeal to the U.S. Court of Appeals for the Federal Circuit on May 8, 2026. On June 11, 2026 the Federal Circuit granted a stay pending appeal, so CBP continues collecting the surcharge from all importers (including the named plaintiffs) while the appeal proceeds.	This is additive to existing Section 301 duties inside its entry window. It is temporary by statute, so procurement teams should treat it as a dated variable rather than a permanent baseline. Vitamins, amino acids, and CoQ10 are exempt. The May 2026 ruling against the surcharge is stayed on appeal, so CBP collects through the end of the window; the surcharge terminates by operation of law at 12:01 a.m. EDT July 24, 2026, with no Congressional extension enacted as of July 21, 2026.

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. Under the earlier programs, certain ingredient categories were exempt from both Section 301 tariffs and the Section 122 surcharge entirely, while non-exempt categories faced combined duties of approximately 17.5 to 35 percent for entries inside the surcharge's February 24 to July 23, 2026 window. For entries on or after July 24, 2026 the forced-labor Section 301 duties (10 to 12.5 percent by origin) apply on top of the base band for covered lines (vitamins and raw spice forms stay exempt as entered, while amino acids, CoQ10, extracts, and finished preparations are covered for supplement use), depending on their HTS classification.

July 24, 2026 update: the new forced-labor Section 301 duties (12.5% China, 10% India, 10% all-in EU) are a separate layer with their own per-HTS-line exemptions, IN ADDITION to the statuses shown (which reflect the earlier programs: 2018–19 Section 301 lists, Section 122, and the 2025 Annex II). Each row's legal-basis note carries its forced-labor (FL) status: vitamins and raw tea/spice forms are exempt as entered, while amino acids, CoQ10, extracts, and finished preparations are covered for supplement use. Verify your HTS line (Dockets USTR-2026-0265/0266).

Ingredient	Status	Legal Basis	HTS Chapter
Exempt from reciprocal tariffs
Vitamin C (ascorbic acid)	Exempt	Section 301 exclusion + Annex II + Section 122 exempt; FL action (Jul 24, 2026): exempt as entered (2936, Note 52(b))	2936
Vitamin D	Exempt	Section 301 exclusion + Annex II + Section 122 exempt; FL action (Jul 24, 2026): exempt as entered (2936, Note 52(b))	2936
Vitamin B12	Exempt	Section 301 exclusion + Annex II + Section 122 exempt; FL action (Jul 24, 2026): exempt as entered (2936, Note 52(b))	2936
Folic acid	Exempt	Section 301 exclusion + Annex II + Section 122 exempt; FL action (Jul 24, 2026): exempt as entered (2936, Note 52(b))	2936
Niacin (Vitamin B3)	Exempt	Section 301 exclusion + Annex II + Section 122 exempt; FL action (Jul 24, 2026): exempt as entered (2936, Note 52(b))	2936
Coenzyme Q10	Exempt	Annex II + Section 122 exempt; FL action (Jul 24, 2026): covered for supplement use — 2914.62.00 (the CoQ10/ubidecarenone line) and the neighboring 2914.69 quinone lines are pharmaceutical-use-only under Note 52(e); a 2936 entry would be exempt — verify your line	2914.62 / 2936 (line-specific)
Quercetin	Exempt	Annex II; FL action (Jul 24, 2026): covered for supplement use (2932 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; successor line 3001.90.0190), and 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	Annex II; FL action (Jul 24, 2026): covered for supplement use (2930 lines pharmaceutical-use-only under Note 52(e))	2930
EPA (eicosapentaenoic acid)	Exempt	Annex II; FL action (Jul 24, 2026): covered (1504 not listed)	1504
DHA (docosahexaenoic acid)	Exempt	Annex II; FL action (Jul 24, 2026): covered (1504 not listed)	1504
Amino acids (lysine, etc.)	Exempt	Section 301 exclusion + Section 122 exempt; FL action (Jul 24, 2026): covered for supplement use (2922 lines pharmaceutical-use-only under Note 52(e))	2922/2930
Stevia	Exempt	Annex II (only botanical with full exemption); FL action (Jul 24, 2026): covered (1302 not listed)	1302
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) Unclearextract(1302.19)
Not exempt (full tariff exposure)
Ashwagandha	Not exempt	Section 301. Not in Annex II. AHPA advocacy ongoing. 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. Not in Annex II. AHPA advocacy ongoing. FL action: covered (1301/1302 not listed)	1301/1302
Bacopa	Not exempt	Section 301. Not in Annex II. AHPA advocacy ongoing. FL action: covered (1211/1302 not listed)	1211/1302
Psyllium	Not exempt	Section 301. Not in Annex II. AHPA advocacy ongoing. FL action: covered (1211 not listed)	1211
Mushroom supplements	Not exempt	Section 301. Not in Annex II. FL action: covered (2106 not listed)	2106
Probiotic ingredients	Not exempt	Check specific HTS classification. Generally not exempt. FL action: generally covered; certain 3002.90 culture/ferment lines are exempt as entered — verify your line	2106/3002
Fish oil	Not exempt	Section 122 non-exempt unless under specific HTS lines. EPA/DHA (purified) are exempt individually. 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 (pre-publication FRN, Dockets USTR-2026-0265/0266). AHPA botanical extract advocacy is ongoing. Exemption status can change. Verify your specific HTS code with a licensed customs broker before making sourcing commitments. Data verified 2026-07-24.

This split matters for product development. A multivitamin built primarily on exempt vitamins and minerals has a very different cost profile than a botanical blend heavy on turmeric and ashwagandha. Knowing which category your key ingredients fall into is the first step toward an accurate landed-cost model.

New Section 301 Investigations (March 2026)

On March 11-12, 2026, USTR announced two new Section 301 investigations. Neither targets dietary supplements by name, but both cover the supply chain that supplements depend on.

Excess Capacity Investigation

USTR is investigating structural excess capacity in manufacturing sectors across 16 economies including China, India, the EU, Vietnam, and Japan. The investigation covers approximately 20 sectors. “Processed food and beverages” is among them. Dietary supplements classify under this heading for trade purposes. Public hearings were held May 5 through May 8, 2026 at the U.S. International Trade Commission.

Forced Labor Investigation

According to the USTR forced labor Section 301 fact sheet (March 12, 2026), a separate investigation covers 60 economies that collectively represent over 99 percent of U.S. imports in 2024, regarding enforcement of forced labor import prohibitions. China, India, and Vietnam, the three primary supplement ingredient sourcing regions, are all under investigation. The International Labour Organization estimates 28 million people globally are in forced labor. Public hearings were held April 28 through May 1, 2026. On June 2, 2026, USTR made findings and proposed additional Section 301 duties of 10 to 12.5 percent across these economies; the comment window closed July 6, 2026, and public hearings on the proposed action were held July 7 through July 9, 2026, at the U.S. International Trade Commission.

What this means for supplement brands

As of July 24, 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.

Legal analysts had characterized these investigations as proceeding on a compressed, accelerated schedule (Troutman Pepper, March 2026), and the forced-labor track bore that out with final action taken on July 23, 2026, one day before the Section 122 surcharge terminated by operation of law. In practice a brand sees the surcharge drop away and the new Section 301 duties arrive at the same July 24, 2026 entry instant. Legal analysts also note that USTR has framed Section 301 as a “more durable, litigation-resistant legal foundation” for trade measures following the Supreme Court's invalidation of IEEPA tariffs (Troutman Pepper, March 2026).

Sources: USTR Fact Sheets, March 11-12, 2026; USTR forced-labor findings and proposed action, June 2, 2026; Federal Register notice 2026-11296, June 5, 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 Executive Order moved 57 botanical commodity codes to Annex II, making them fully exempt from reciprocal tariffs. The American Herbal Products Association (AHPA) secured these exemptions after sustained advocacy. The critical distinction is between raw botanical forms and concentrated extracts.

The raw-versus-extract distinction is critical. Turmeric powder (root form) is exempt. Turmeric extract (concentrated curcuminoids) is not. Green tea leaf is exempt, but concentrated polyphenol extract is not. If your formulation uses extracts, do not assume your ingredient shares the exemption status of the raw form. Verify your specific HTS code. See the ingredient table above for form-dependent exemption status.

AHPA is currently meeting with Congress, USTR, and the Department of Commerce to advocate for extending Annex II exemptions to herbal extracts and specialized manufacturing equipment. These exemptions are not yet confirmed. Monitor AHPA.org for updates.

Source: AHPA, White House Annex II, NutraIngredients (Nov 2025), SupplySide (2026).

How Tariff Costs Have Changed Since 2025

The tariff landscape for supplement ingredients has shifted dramatically since 2025. During the IEEPA tariff era (April 2025 through February 2026), UNPA President Loren Israelsen estimated the effective tariff rate at 55 to 70 percent for a large number of dietary ingredients (SupplySide, April 3, 2025). China faced a 125 percent reciprocal rate. Combined duties on some herbal raw materials exceeded 100 percent.

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% (all countries)	Entries Feb 24 – Jul 23, 2026; terminates by law 12:01 a.m. EDT Jul 24, 2026
New Section 301 (excess capacity + forced labor)	Forced labor: 12.5% China, 10% India, 10% net-of-MFN EU (final Jul 23, 2026); excess capacity: none yet	Active (entries on or after Jul 24, 2026; in-transit exception through Jul 27; Annex II chemical exemptions pharmaceutical-use-only)

For non-exempt Chinese botanicals entered February 24 through July 23, 2026, the combined duty is approximately 17.5 to 35 percent (Section 301 at 7.5-25% plus Section 122 at 10%); for later entries the stack is the Section 301 band plus the 12.5 percent forced-labor Section 301 duty finalized July 23, 2026 (roughly 20 to 37.5 percent combined for covered extracts). Ingredients exempt under the earlier programs faced 0 percent from them; under the forced-labor action, vitamins and raw spice forms stay exempt as entered, while amino acids, CoQ10, and other pharmaceutical-use-only chemical lines carry its 10-12.5 percent layer by origin on supplement-use imports. That compares against the 55-70 percent effective rate of the IEEPA era, but still substantial enough to affect product pricing. Real-world impact for brands has been 5 to 10 percent COGS increases and 10 to 15 percent retail price increases.

Sources: UNPA/SupplySide (April 2025), USTR, Troutman Pepper (March 2026). IEEPA-era figures are historical context, not current rates.

India Sourcing: Relief and Disruption

A February 2026 trade deal reduced tariffs on Indian imports from 50 percent to 18 percent permanent duty. This landed within the industry-predicted range of 15-20 percent (NutraIngredients, February 4, 2026). For brands sourcing turmeric, ashwagandha, or boswellia from India, the rate reduction is meaningful.

The relief comes with a complication. Indian farmers have begun transitioning from supplement-essential crops to alternatives less affected by tariffs. Industry expert Anand Swaroop noted that these decisions are based on planting cycles spanning months or even years. The affected crops include turmeric, black pepper, amla, ashwagandha, psyllium husk, and boswellia (NutraIngredients, February 2026).

Some price relief may follow as new contracts under the 18 percent rate take effect, but the size and timing are uncertain. Supply normalization also depends on farming cycles reversing, which takes longer. 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 are not just a financial issue. They are creating quality pressure across the industry. According to NutraIngredients reporting (January 2026), industry sources describe a trend called “skimpflation”: brands reformulating products with lower-potency ingredients to offset tariff-driven cost increases. A turmeric supplement with 20 percent curcuminoids may outsell the 95 percent version, but the health evidence sits with the higher concentration.

Independent testing confirms the quality gap is real. NutraIngredients (March 2026) reported that of 44 popular supplements purchased anonymously from Amazon, approximately half failed basic label accuracy standards, and 22 of the 44 contained 0 to 3 percent of their listed active ingredients.

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 COAstandards as the original. As Robert Marriott of the American Herbal Products Association noted, “Many companies will make difficult decisions about product pricing, business viability, and sourcing options” (SupplySide, April 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 NutraIngredients and Nutritional Outlook reporting, industry sources estimate that 80 percent or more of raw nutraceutical ingredients originate from China. For most botanicals, replacing Chinese supply with domestic alternatives is not realistic at scale. So how are companies responding?

Alternative sourcing regions: Companies are shifting to India, Southeast Asia, and South America for ingredients where qualified suppliers exist.
India trade deal (source: NutraIngredients, February 2026): a bilateral agreement rolled tariffs on Indian imports to 18 percent and exempted key botanicals. This gave companies with existing Indian supplier relationships a meaningful cost advantage.
Speed depends on preparation: Companies that maintained backup supplier relationships can pivot in 60-90 days. Companies that abandoned alternative sourcing during lower-tariff periods face 6-12 months to re-qualify new suppliers, complete COA reviews, and validate identity testing.
Margin compression is widespread: Most companies absorbed the 2025-2026 tariff costs to keep customers rather than passing them through to pricing. The extent of margin impact varies widely by product category and ingredient sourcing, but the pressure is not sustainable long-term.
Smaller firms are hit hardest: They lack the volume to renegotiate supplier contracts and the cash reserves to absorb cost increases while waiting for trade policy to stabilize.

Source: NutraIngredients, January 2026 and February 2026 reporting.

Real example: Whey Protein Isolate

Whey protein isolate hit record prices above $11 per pound, or roughly $24,000 per metric ton, according to CollagenSei commodity data, Vespertool, and Hoard's Dairyman as of early 2026. Suppliers have sold forward well into 2026, and both suppliers and retailers treat current pricing as the new baseline. Climate change affecting dairy-producing regions is a structural cost driver here, not just tariffs. If your formulation depends on whey, budget for current spot prices, not historical averages.

What Brands Can Responsibly Infer

The following are operational implications, not legal advice:

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; the Note 52 exemption tables are mapped per HTS line on this page, with vitamins and many mineral salts exempt as entered and pharmaceutical-use-only chemical lines covered for supplement use).

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?

Primary Sources Checked

Source check completed on July 24, 2026. Re-check before relying on this page for a live procurement or pricing decision.

Estimate duties for your ingredient list

Tariff exposure depends on ingredient category, origin country, and the current surcharge stack. Our free tariff estimator models landed-duty ranges for your specific inputs. Try the tariff estimator →

Duty is only part of what a shipment costs. The landed cost calculator adds the government entry fees (MPF, HMF), freight, and broker charges on top of the duty stack. Estimate your full landed cost →

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)

Stay informed

Regulatory updates, new manufacturer assessments, and tool launches. No spam.