Tariffs on imported paper products are not one number. They are several separate duties, each with its own legal basis, stacking on top of each other depending on where a napkin, tissue, or parent roll was actually made. This article is for purchasing managers and owners at jan-san and foodservice distributors, converters, and retailers who need to understand those layers before quoting a landed cost. You will get a plain map of each layer, what it currently applies to, and where to verify the number.
The legal landscape here moved several times between February and September 2026, and can move again before you read this. Treat every rate below as a dated snapshot, and confirm the fully stacked figure for your specific product and origin with a licensed customs broker before quoting a customer.
Key takeaways
- A landed paper import can carry up to five duty layers: base HTS duty, Section 301, antidumping or countervailing duty, a country framework rate, and (historically) IEEPA-based tariffs.
- The Supreme Court struck down IEEPA-based tariffs on February 20, 2026, erasing the "reciprocal" tariff regime built around country-by-country rates.
- A replacement Section 122 global surcharge ran late February to late July 2026, then expired by statute and was not renewed.
- As of late July 2026, a new Section 301 action tied to forced-labor enforcement added 10 to 12.5 percent on goods from 60 economies, including China and Vietnam.
- Standing antidumping orders on tissue paper and thermal paper predate all of this and run independently, with active circumvention and evasion inquiries in 2026.
- Country of origin follows where the paper was made, not where it was cut, folded, or packaged. A converting move alone rarely changes your duty exposure.
Why "the tariff" on paper is really several tariffs
Ask a supplier for "the tariff rate" on a container of napkins and you will get a partial answer, because there is rarely one rate to quote. A single HTS line can carry a base duty, an additional Section 301 duty tied to country of origin, and a separate antidumping deposit tied to the product and manufacturer, all calculated independently and added together at entry.
Which layers apply depends on three things: the exact 10-digit HTS classification, the confirmed country of origin, and whether that product or manufacturer sits under an active trade remedy order. Get any one wrong on a quote and the number you gave a customer will not match what CBP actually assesses.
Layer one: the base HTS duty
Chapter 48 of the Harmonized Tariff Schedule covers most paper and paperboard articles, including heading 4818 for toilet paper, facial tissue, towels, and table napkins. For common subheadings under 4818, including toilet paper and facial tissue, the published general (most-favored-nation) rate is free of duty (Unisco HTS lookup, 4818.20.00, accessed September 2026).
That does not mean every paper article enters duty-free. Some parent stock, coated paper, and paperboard classifications carry a small positive general rate, and the exact subheading shifts with basis weight, ply, and finish. Confirm the specific 10-digit classification with your broker rather than assuming the whole chapter is free, since this base rate is what every other layer below gets added to.
Layer two: Section 301, in two parts
Section 301 of the Trade Act of 1974 is the tool USTR uses to add duties tied to a trading partner's practices, and China has carried Section 301 duties on most of its goods since 2018 through 2020, generally described as 25 percent on Lists 1 through 3 and 7.5 percent on List 4A, depending on which list an HTS line landed on. A four-year review, with modifications finalized in September and December 2024, focused mainly on strategic sectors like steel, semiconductors, and electric vehicles rather than paper goods (USTR, Four-Year Review, accessed September 2026).
A second, newer Section 301 action stacked on top of this in 2026. On July 23, 2026, USTR announced final action across 60 economies for failing to prohibit imports of forced-labor goods: 10 percent for a shorter list of 17 economies with qualifying prohibitions or trade agreements, roughly 10 to 12.5 percent net of MFN for select goods from the EU, Taiwan, Japan, Korea, and Switzerland, and 12.5 percent for the remaining 43 economies, including China and Vietnam (USTR, "USTR Takes Action in Forced Labor Section 301 Investigations," July 23, 2026). This is on top of the original China-specific lists, not a replacement for them.
Layer three: what happened to "reciprocal" tariffs
Through 2025, country-by-country "reciprocal" tariffs, along with fentanyl-linked tariffs on China, were imposed under the International Emergency Economic Powers Act (IEEPA). That changed on February 20, 2026, when the Supreme Court ruled 6-3 in Learning Resources v. Trump that IEEPA's language authorizing the President to "regulate" imports does not include the power to impose a tariff, striking the whole IEEPA tariff structure down (Skadden, "The Supreme Court Ends IEEPA Tariffs," February 2026).
The administration moved fast, invoking Section 122 of the Trade Act of 1974 within days. That authority allows a temporary balance-of-payments surcharge, capped by statute at 150 days, and a 10 percent global surcharge took effect February 24, 2026. The Court of International Trade ruled on May 7, 2026 that this exceeded the statute's scope; the government appealed, and the Federal Circuit stayed that ruling so collection continued.
Section 122 then hit its own 150-day limit and expired July 24, 2026 without renewal, since extending it requires an act of Congress (Gibson Dunn, "Section 122 Global Tariffs Invalidated by the Court of International Trade," 2026). The forced-labor Section 301 action took effect the same day and is the closest thing to a replacement now in force.
Where Vietnam, South Korea, Taiwan, and the EU stand
Treat every country figure here as provisional and reconfirm before quoting. Vietnam's earlier IEEPA-based rate, which had reached as high as 46 percent before a 2025 framework lowered it, no longer applies now that IEEPA tariffs are void; Vietnam currently sits in the 12.5 percent tier of the July 2026 forced-labor Section 301 action. South Korea and Taiwan fall into that action's narrower 10 to 12.5 percent, net-of-MFN tier, alongside separate bilateral talks that predate the Supreme Court ruling and may not map cleanly onto it.
The European Union operates under a distinct July 2025 framework setting a 15 percent all-inclusive ceiling on most goods, meaning you pay the higher of MFN or 15 percent rather than stacking the two, with steel, aluminum, and copper carved out at 50 percent (The White House, "Fact Sheet: The United States and European Union Reach Massive Trade Deal," July 2025). None of these arrangements are guaranteed to hold through the rest of 2026.
Layer four: antidumping and countervailing duty orders
Separate from all of the above, specific paper products from specific countries carry standing antidumping (AD) or countervailing duty (CVD) orders, tied to a Commerce Department finding of below-fair-value sales or a countervailable subsidy. These apply by product scope and country regardless of what Section 301 or any framework rate is doing.
| Order | Product scope | Country | Case number | Status as of 2026 |
|---|---|---|---|---|
| Antidumping | Cut-to-length tissue paper, 29 gsm or less; excludes jumbo/parent rolls | China | A-570-894 | Active since 2005; deposit rates have run as high as 112.64 percent (CustomsMobile, AD/CVD Message 5095205) |
| Antidumping, circumvention inquiry | Tissue paper finished in Vietnam from Chinese-origin jumbo rolls | Vietnam | Under A-570-894 | No separate Vietnam order exists. Commerce opened a country-wide circumvention inquiry on August 6, 2026 into tissue completed in Vietnam from Chinese jumbo rolls, and a 2011 circumvention finding under the China order already reached some Vietnamese producers (Federal Register, August 6, 2026) |
| Antidumping and countervailing | Lightweight thermal paper | China | A-570-920 / C-570-921 | Active since 2008, continued in a January 2026 sunset review; CBP opened an evasion case (EAPA 8267) in June 2026 alleging misclassification (CBP, EAPA Case 8267, June 2026) |
| Antidumping | Thermal paper | Germany, Japan, South Korea, Spain | Country-specific | Orders issued November 2021 after an ITC injury finding; original investigation margins ranged roughly from the single digits to over 100 percent depending on country and producer |
Rates in AD and CVD orders are set per named manufacturer, change through periodic administrative reviews, and can rise sharply for a company found circumventing the order. Ask your broker for the current company-specific deposit rate rather than assuming a percentage from an older filing still applies.
Country of origin: why finishing somewhere new does not reset anything
CBP determines country of origin using a substantial transformation test: whether processing in the last country of production changed the article's name, character, or use enough to create something new (International Trade Administration, "Rules of Origin: Substantial Transformation," accessed September 2026). Minor finishing generally does not clear that bar.
CBP has ruled on this directly for converted paper. In ruling NY N333041, jumbo rolls of toilet tissue and towel stock milled from pulp in one country were shipped to a second country for unspooling, cutting, folding, and packaging. CBP held that the milling country remained the country of origin, because the converting operations were minor finishing that left the paper's essential character unchanged, consistent with earlier rulings on printed and folded tissue and on parent rolls cut into sticky notes (CustomsMobile, CBP Ruling NY N333041, June 13, 2023). The same logic sits behind the 2026 circumvention inquiry into Vietnamese-finished tissue made from Chinese jumbo rolls in the table above: regulators are asking the identical question, as enforcement rather than an advance ruling.
Moving a converting line to a new country, by itself, usually does not change your country of origin or duty exposure. The change has to happen upstream, where the base paper is manufactured. Offshore Products works through this kind of origin question with U.S. buyers evaluating a move, across its supplier relationships in Asia and Europe, since getting it wrong shows up as a customs bill after the container has landed.
The layers, side by side
| Layer | Legal basis | Applies to | Status as of September 2026 |
|---|---|---|---|
| Base HTS duty | Harmonized Tariff Schedule, Chapter 48 | All origins | Often free for finished tissue, towel, and napkin lines; confirm the exact subheading |
| Section 301 (original lists) | Trade Act of 1974, sec. 301 | China-origin goods on Lists 1 to 4A | Generally 25 percent (Lists 1 to 3) or 7.5 percent (List 4A), largely unchanged for paper since 2020 |
| Section 301 (forced-labor action) | Trade Act of 1974, sec. 301 | Goods from 60 named economies, including China and Vietnam | 10 to 12.5 percent depending on country tier, effective July 24, 2026 |
| IEEPA reciprocal and fentanyl tariffs | IEEPA | Country-specific rates set in 2025 | Invalidated by the Supreme Court, February 20, 2026; not collectible |
| Section 122 global surcharge | Trade Act of 1974, sec. 122 | Nearly all imports | 10 percent, February 24 to July 24, 2026; expired by statute, not renewed |
| Country framework deals | Executive agreements | EU (15 percent ceiling); Vietnam, Korea, Taiwan arrangements | Confirm current status; several predate the IEEPA ruling |
| Antidumping and countervailing duty orders | Tariff Act of 1930, Title VII | Specific products and countries, per the table above | Active, company-specific, subject to review and circumvention findings |
| Country of origin determination | 19 CFR 134, CBP rulings | Decides which of the layers above actually attach | Converting or finishing alone generally does not shift origin |
Legal ways to manage the cost, not evade it
Nothing below gets around a tariff that legitimately applies. It is how importers legally reduce the base they are taxed on, or recover duty they are owed, while staying inside the rules above.
Diversify origin upstream, not just downstream
Since origin follows where the paper is made, relocating only the converting or packaging step does not change your exposure, as the ruling above shows. Real diversification means qualifying a supplier whose base paper is actually milled elsewhere, verified with a broker or a CBP ruling request before you commit volume.
Tariff engineering within the rules
Tariff engineering means designing a product, before it is made, so it legitimately falls into a lower-duty HTS classification or different origin treatment. It has to be a real design or process choice, documented and defensible, not a paperwork description that does not match what ships. A binding ruling request to CBP before you commit confirms it will hold up at entry.
First-sale valuation where it applies
When goods pass through a middleman, CBP allows duty to be calculated on the earlier manufacturer-to-middleman price, provided that sale was bona fide, arm's-length, and clearly destined for the U.S. market from the start. This only lowers the value duty is calculated on; it does not remove any layer above, and CBP requires you to declare when you use it.
Duty drawback
Drawback refunds duties already paid, generally up to 99 percent, on imported merchandise later exported unused or used to manufacture something exported (U.S. Customs and Border Protection, "Drawback," accessed September 2026). A distributor re-exporting to Canada, or a converter shipping finished goods abroad after using imported parent rolls, can potentially qualify. Claims run through the ACE portal with pre-export notice deadlines, so this needs setting up before the shipment, not after.
Tariff clauses in supply agreements
Build a clause specifying who absorbs a tariff change between order and delivery, referencing the HTS classification and declared origin the quote is based on, with a re-opener if either changes materially. Given how often the layers above moved in 2026, a contract silent on this leaves one side holding a cost swing nobody priced in.
Frequently asked questions
Does converting paper in a new country change where it is from for customs purposes?
Usually not. CBP looks at whether the last processing step created a new article with a different name, character, or use. Cutting, folding, rewinding, and packaging jumbo rolls into finished tissue or towel generally does not clear that bar, so origin stays with the country where the base paper was actually made.
What is the current combined tariff on tissue paper made in China?
It depends on the exact HTS line and whether an antidumping order covers that specific product. As of September 2026, a China-origin tissue product can carry its base HTS duty, a Section 301 rate from the original lists (commonly 25 percent), the newer 12.5 percent forced-labor Section 301 layer, and, if it falls inside the scope of the standing tissue paper order, an additional antidumping deposit that has historically run over 100 percent for some manufacturers. Confirm the stacked total for your specific product with a licensed customs broker.
Are Vietnam-made paper products tariff-free?
No. Vietnam sits in the 12.5 percent tier of the July 2026 forced-labor Section 301 action, and Commerce is running a country-wide circumvention inquiry, opened August 6, 2026, into tissue finished in Vietnam from Chinese-origin jumbo rolls under the China antidumping order. Vietnam-origin paper still needs the same layer-by-layer check as any other origin.
Can a jan-san distributor use duty drawback?
Potentially, if imported paper or a product made from it is later exported unused or as part of a manufactured good that is exported. It requires advance notice filings and ACE enrollment, so it needs to be arranged before the export happens, and a broker can confirm whether a specific export qualifies.
Do these tariffs apply to paper made in the European Union?
EU-origin goods currently fall under a separate July 2025 framework setting a 15 percent all-inclusive ceiling on most products, rather than the layers described above for China and Vietnam. Confirm whether that framework is still in force for your specific product before quoting, since it predates several of the changes described in this article.
How often do these rates actually change?
Frequently enough that a rate confirmed in one quarter of 2026 was not always still accurate the next. Between February and September 2026 alone, the legal basis for country-specific tariffs changed twice. Date every figure you quote and reconfirm anything older than a few weeks before you rely on it.
Next step
None of this replaces a licensed customs broker's classification and rate confirmation for your specific product and origin, but knowing which layers to ask about is what makes that conversation productive. Offshore Products works with U.S. buyers on exactly this kind of sourcing and import question across its supplier relationships in Asia and Europe. If you are evaluating a new origin for napkins, tissue, or parent rolls, request a quote or read more about how import management covers classification and origin questions alongside paper parent roll sourcing.
Sources
- Office of the United States Trade Representative, "USTR Takes Action in Forced Labor Section 301 Investigations", July 23, 2026
- Office of the United States Trade Representative, "Four-Year Review", accessed September 2026
- Skadden, Arps, Slate, Meagher & Flom LLP, "The Supreme Court Ends IEEPA Tariffs, Bringing Fresh Uncertainty for Companies", February 2026
- Gibson Dunn, "Section 122 Global Tariffs Invalidated by the Court of International Trade: Ruling and Next Steps", 2026
- The White House, "Fact Sheet: The United States and European Union Reach Massive Trade Deal", July 2025
- Federal Register, "Certain Tissue Paper Products from the Socialist Republic of Vietnam: Initiation of Circumvention Inquiry", August 6, 2026
- U.S. Customs and Border Protection, "EAPA Case 8267: Lightweight Thermal Paper from China", June 2026
- CustomsMobile, AD/CVD Message 5095205, Antidumping Duty Order A-570-894, Certain Tissue Paper Products from China, accessed September 2026
- CustomsMobile, CBP Ruling NY N333041, June 13, 2023
- International Trade Administration, U.S. Department of Commerce, "Rules of Origin: Substantial Transformation", accessed September 2026
- U.S. Customs and Border Protection, "Drawback", accessed September 2026