De Minimis Is Gone: The Landed Cost of a China-Made Electric Toothbrush in 2026

Every shipment of Chinese-origin goods entering the United States now pays duty, regardless of declared value. The last of the flat-rate surcharges expired on July 24, 2026, and from that date normal tariff lines — MFN, Section 232 and Section 301 — reached postal shipments for the first time. For importers of electric toothbrushes and water flossers, landed cost has become a four-component stack that has to be calculated per HTS subheading rather than assumed.

How the rules changed, in sequence

May 2, 2025— the de minimis exemption was eliminated for China, Hong Kong and Macau. All shipments of Chinese-origin goods, regardless of value, became subject to duties and tariffs.

August 29, 2025— US de minimis was suspended globally. Every import incurs duty.

November 10, 2025— under the US–China agreement following the October 30, 2025 Trump–Xi meeting, China's retaliatory tariff on all US goods was held at 10%, in effect through November 10, 2026; it had previously stood at 125%.

February 24, 2026— the IEEPA-based 20% China tariff ended, replaced by the Section 122 global surcharge of 10%. That IEEPA rate had peaked at 145%, been cut to 30% on May 14, 2025, and to 20% on November 10, 2025.

July 23–24, 2026— USTR finalised the Section 301 forced-labor tariff, effective July 24 at 12.5% for China (10% for 17 named economies including Canada, India, Mexico and the UK). The Section 122 surcharge expired the same day, and the postal delivered-duty-paid threshold rose from US 800 to US 2,500.

Sources: the zonos.com US import tariff tracker, updated through August 26, 2026, and Avalara's de minimis guidance.

What the duty stack looks like now

Classification matters before arithmetic. Per the USITC Harmonized Tariff Schedule, heading 8509.80.50 carries a general rate of 4.2%, with electric toothbrushes at statistical suffix .45 and "other" appliances at .95; column 2 stands at 40%. CBP ruling NY L81826 classified an electric toothbrush under 8509.80.0045.

An illustrative calculation

Taking only the two verified rates that apply to a China-origin electric toothbrush classified under 8509.80.50 — 4.2% MFN plus 12.5% Section 301 forced-labor — the ad valorem duty before any legacy List duty is 16.7% of entered value. If a legacy Section 301 List rate also attaches to the specific subheading, the total moves materially: List 4A would add 7.5 points, List 3 would add 25.

This is illustrative arithmetic on two published rates, not a ruling. Whether legacy List duties attach depends on the exact subheading, and CBP's Customs Bulletin Weekly Vol. 58 No. 30 (July 31, 2024) discusses tariff no. 8509.80.50 in a Section 301 context. Confirm with a licensed customs broker before quoting landed cost.

The FDA layer is separate from the tariff layer

Duty is not the only gate. Under FDA product classification, "toothbrush, powered" is product code JEQ, regulation number 21 CFR 872.6865, Class I and 510(k)-exempt. Class I devices still require establishment registration and device listing. Registrar Corp notes (April 6, 2025) that basic battery-powered brushes without therapeutic claims or smart features may sit in that low-risk position — meaning claims and connectivity, not the tariff code, are what can change a device's regulatory footing.

Why this matters for buyers

• Drop-ship economics changed.

With de minimis gone for China since May 2025 and globally since August 2025, low-value direct parcels no longer enter duty-free. Consolidated commercial entry is now the default route.

• Postal shipments are no longer a workaround.

From July 24, 2026, normal duties reach postal shipments too, with prepaid duties required below the new US$2,500 threshold.

• Classification accuracy is now worth money.

The difference between a 4.2% base and a base carrying a 25% List duty dwarfs most freight negotiations.

• Rate architecture is still moving.

Section 232 measures on steel and aluminium at 50%, semiconductors at 25% from January 15, 2026, and the Section 338 action on Canadian goods from August 22, 2026 all reshaped the 2026 schedule within a few months.

Zhejiang-based OEM/ODM suppliers such as Charmhome, which ships adult and kids' electric toothbrushes and cordless water flossers to European and US distributors, now quote against a duty stack their customers must model per subheading rather than a flat de minimis assumption.

Sources

• Zonos — US Import Tariff Tracker(updates through August 26, 2026)

• USITC — Harmonized Tariff Schedule, Chapter 85

• Avalara — How to handle US-China tariffs and the end of de minimis

• FDA — Product classification JEQ, toothbrush, powered

• Registrar Corp — FDA Compliance for Electric Toothbrushes (April 6, 2025)