How to Import Paper Products Into the US: A Distributor's Guide

If you buy AFH paper for a distributor, converter or foodservice program, learning how to import paper products into the US means more than finding a mill that can make what you need. The moment your container leaves the origin port, you are legally responsible for classification, duties and paperwork, whether or not a broker handles the filing. This guide covers who can serve as importer of record, how towel, tissue, napkin and parent roll products get classified under HTS chapter 48, and what a customs bond and ISF filing require. It also covers the documents, Incoterms and cost lines on every shipment, plus the mistakes that trip up first-time importers.

Key takeaways

The importer of record, not the mill or the freight forwarder, is legally responsible for classification, duties and compliance on every entry.
Most AFH tissue, towel and napkin products fall under HTS headings 4803 and 4818; cups and containers can land in heading 4823 or a plastics heading depending on material.
CBP requires a customs bond on commercial entries over $2,500; a continuous bond needs at least $50,000 or 10 percent of your prior year's duties, taxes and fees, whichever is greater.
Import Security Filing (ISF, or "10+2") data must reach CBP no later than 24 hours before your cargo loads on the vessel; late or inaccurate filings can each draw a $5,000 liquidated damages claim.
The Merchandise Processing Fee, Harbor Maintenance Fee and any applicable duty are separate line items that stack on top of your product cost.
A licensed customs broker files your entry, but the importer of record stays legally on the hook even when a broker handles the paperwork.

Who can import paper products into the US

Anyone bringing paper products into the US for commercial resale needs an importer of record, the party CBP holds accountable for the shipment. This can be the owner or purchaser of the goods, the ultimate consignee, or in some structures a licensed customs broker acting under a power of attorney. A distributor placing its first purchase order with a mill in China or Vietnam is almost always the importer of record on that entry, whether or not a broker is doing the legwork.

Being importer of record is a legal designation, not a formality. CBP guidance is direct: importers must use "reasonable care" to enter, classify and value merchandise under 19 U.S.C. 1484, and even when a broker files the paperwork, "you, the importer of record, are ultimately responsible for the correctness of the entry documentation presented to CBP and all applicable duties, taxes and fees." You will need a valid importer number, typically your IRS-issued EIN, before your first entry can clear.

Classifying paper products under HTS chapter 48

Towel, tissue and napkin stock: heading 4803

Unconverted jumbo rolls used to make towel, facial tissue and napkin stock, the parent rolls converters buy for further processing, generally fall under heading 4803, covering "toilet or facial tissue stock, towel or napkin stock and similar paper... whether or not creped, crinkled, embossed, perforated." As of September 2026, the USITC's Harmonized Tariff Schedule lists the base rate for this heading as free for most trading partners, including China and Vietnam.

Finished towels, tissues and napkins: heading 4818

Once stock is converted into a finished, packaged item, cut to size, folded or printed, it typically moves to heading 4818, which covers toilet paper, facial tissue, towels and table napkins "cut to size or shape." The schedule breaks this out further: 4818.10 for toilet paper, 4818.20 for facial tissue and towels, and 4818.30 for table napkins and tablecloths. As with heading 4803, the base rate on these lines is generally listed as free, but confirm the exact statistical suffix with your broker.

Cups and containers: heading 4823 or a plastics heading

Foodservice cups and containers do not automatically sit in chapter 48. A cup or container made mostly of paper or paperboard, including molded pulp cups, is classified under heading 4823, for example subheading 4823.69 or 4823.70. A cup made mostly of plastic, including many PLA and PET cold cups, instead falls under chapter 39, typically heading 3924. The dominant material decides the heading, so a paper cup with a heavy plastic lining or lid can classify differently than you expect. Get a broker opinion or a binding ruling before committing to volume on a new SKU.

Bonds, ISF and paperwork before the vessel sails

The customs bond

CBP requires a bond on commercial entries valued over $2,500, and on many regulated goods regardless of value. Most repeat importers use a continuous bond, covering every US port for a 12-month period; CBP's published guidance sets the minimum at $50,000, or 10 percent of the prior 12 months' duties, taxes and fees, whichever is greater. Importers who ship rarely can use a single transaction bond instead, generally set at the entered value plus applicable duties, taxes and fees. A bond written solely to satisfy ISF requirements needs a minimum of $50,000 for a continuous bond or $10,000 for a single transaction bond.

ISF 10+2: what CBP needs and when

Ocean shipments require an Import Security Filing, commonly called "10+2" for the ten data elements the importer provides plus two from the carrier, including the importer of record number, consignee, manufacturer, seller, buyer, country of origin and the six-digit HTS code. CBP requires this data no later than 24 hours before your cargo is loaded on the vessel at the foreign port, not 24 hours before arrival in the US. A late or inaccurate ISF is not a minor slip: CBP's published mitigation guidelines allow a liquidated damages claim of $5,000 per late filing and a separate $5,000 per inaccurate filing.

Documents that travel with the shipment

Four documents appear on essentially every ocean shipment. The commercial invoice and packing list travel with the cargo and support your entry filing. The bill of lading is your title document and proof of shipment. The arrival notice, issued by the carrier once the vessel is inbound, tells you and your broker when the container is due and what charges are waiting at the port. For the formal entry itself, CBP requires the initial entry documentation (CBP Form 3461) within 15 calendar days of landing, followed by the entry summary (CBP Form 7501) with estimated duties within 10 working days of entry. Missing either deadline can send your shipment to general order storage or trigger a liquidated damages demand.

Incoterms buyers actually see: FOB, CIF and DDP

Most quotes from Asian mills come back in one of three Incoterms, and each one moves the line between what the factory handles and what lands on your desk. Under FOB, the seller's responsibility ends once goods are loaded at the origin port; you or your broker arrange ocean freight, insurance and the entire US customs process. Under CIF, the seller pays freight and minimum insurance to the US port, but you still handle destination clearance, duties and inland delivery. Under DDP, the seller is contracted to handle import clearance and pay duties, though few overseas mills are actually set up to act as a US importer of record, so a DDP quote deserves a closer look before you accept it.

Incoterm	Seller handles	You (buyer) handle
FOB (Free on Board)	Export clearance, loading at origin port	Ocean freight, insurance, US customs entry, duties, inland delivery
CIF (Cost, Insurance and Freight)	Export clearance, ocean freight, minimum insurance to US port	US customs entry, duties, inland delivery
DDP (Delivered Duty Paid)	Export and import clearance, all freight, duties, delivery to your dock	Assisting the seller with import documents it cannot obtain alone

Duties, MPF and HMF: what lands in your total cost

Landed cost on a paper products shipment is rarely just "duty." Three separate charges typically apply. The HTS duty rate depends on your exact classification; base rates on most chapter 48 tissue, towel and napkin headings are listed as free, but shipments from China can carry additional tariffs layered on through Section 301 and other trade actions that move independently of the base HTS rate and change faster than any published guide can track, so confirm the current landed duty with your broker at time of shipment. The Merchandise Processing Fee (MPF) is an ad valorem fee of 0.3464 percent of customs value, with a minimum and maximum CBP adjusts for inflation each fiscal year; for fiscal year 2026, effective October 1, 2025, that floor is $33.58 and the ceiling is $651.50. The Harbor Maintenance Fee (HMF) applies to ocean shipments at 0.125 percent of cargo value. Ask your broker to run a landed cost estimate that includes all three before you commit to a purchase order, not after the container is loaded.

The role of a licensed customs broker

A licensed customs broker is authorized by CBP, under 19 CFR Part 111, to classify goods, calculate duties and file entries on your behalf. The license is national, so a broker in any port can file at any US port. CBP describes brokers as "licensed by CBP, but not CBP employees," and it maintains port-by-port broker lists without endorsing any firm on them. New importers typically sign a power of attorney and let the broker manage entry filing, classification and ISF submission, while an import-management partner such as Offshore Products handles the upstream work of sourcing the mill, approving samples and coordinating logistics between factory and broker. Either way, the broker's work does not transfer your legal liability; you remain the importer of record.

What the timeline actually looks like

There is no fixed number of weeks that applies to every shipment, since mill lead times, vessel schedules and port congestion all vary by lane and season. The sequence of steps, though, is consistent. Sourcing and sample approval happen first, followed by a purchase order and production at the mill. Pre-shipment inspection, where used, happens before the container is sealed and booked. Once booked, your ISF filing is due 24 hours before loading, and the bill of lading and commercial invoice follow. During ocean transit, your broker prepares the entry package so that when the arrival notice comes in, CBP Form 3461 can be filed promptly, well inside the 15 calendar day window, followed by the entry summary and duty payment inside CBP's 10 working day deadline. After release, drayage and delivery to your warehouse close out the shipment.

Common first-time importer mistakes

A few mistakes show up again and again on new importer accounts. Guessing at the HTS code instead of confirming it can misstate duty owed and create audit exposure. Treating the customs bond as a one-time task, rather than checking it still covers a full year of growing volume, can leave you underbonded. Booking freight before the ISF data is finalized turns a routine filing into a rushed, penalty-prone one. Accepting a DDP quote without confirming in writing who is actually listed as importer of record is a recurring surprise. And skipping quality inspection before the container is sealed is a sourcing problem more than a customs one, but it lands on the same desk once a shipment clears customs and then fails inspection at the warehouse. Working with a sourcing partner that also handles quality control, such as Offshore Products, is one way distributors catch spec problems before the container leaves port rather than after it lands.

Frequently asked questions

Do I need to be a licensed customs broker to import paper products myself?

No. Any importer of record can file its own entries with CBP, but most first-time importers hire a licensed customs broker because entry filing, HTS classification and bond paperwork are complex and mistakes fall on the importer, not the broker.

What HTS heading do parent rolls fall under?

Unconverted tissue, towel and napkin stock generally falls under heading 4803. Once that stock is cut, folded or packaged into a finished retail or AFH item, it typically moves to heading 4818. Confirm the exact statistical suffix with your broker.

What happens if I miss the ISF filing deadline?

CBP can assess liquidated damages against your bond. Published mitigation guidelines allow a $5,000 claim per late filing and a separate $5,000 claim per inaccurate filing, so filing with the best available data before the deadline is safer than filing late.

Do cups and foodservice containers get the same duty treatment as tissue and towel products?

Not necessarily. Paper and paperboard cups and containers generally fall under heading 4823, while plastic cups and containers, including many cold-drink cups, fall under chapter 39. Material composition, not end use, decides the classification, so get a ruling or broker opinion before ordering at volume.

Should I accept a DDP quote from an overseas mill?

DDP quotes can look attractive because the seller is contracted to handle destination duties and clearance, but few paper mills are actually set up to act as a US importer of record. Confirm in writing who will be listed as importer of record on the CBP entry before you accept DDP terms, since that responsibility does not disappear just because the invoice says DDP.

Next step

If you are weighing an import versus domestic supply decision on towel, tissue, napkin or parent roll volume, request a quote to talk through sourcing and landed cost, or see current formats for parent rolls and foodservice packaging and disposables. For distributors who want sourcing, sampling and customs coordination handled by one partner, see import management.