Are your cosmetic products packaged with aluminum caps, metal lids, or aluminum tubes?
If so, this is something you need to review carefully.
The United States has recently expanded enforcement around Section 232 measures covering steel and aluminum derivative products. Originally, Section 232 was designed to impose additional duties on certain steel and aluminum imports for national security reasons. As its scope has widened, derivative products containing steel or aluminum, including some types of cosmetic packaging, may now face additional duties of up to 50%.
In other words, the risk is not limited to the cosmetic formula itself.
Packaging components such as metal caps and aluminum tubes can become part of the issue. Even if the product itself is classified under Chapter 33 for cosmetics, packaging materials that contain aluminum or steel may still fall within the scope of Section 232, depending on how they are classified and declared.
What can happen in practice?
- HS code review
CBP may verify the declared HS code at the time of entry. If the classification is found to be incorrect, the shipment may be subject to post-entry review, additional duty assessment, or penalties. - Country-of-origin verification
Through documents such as supplier declarations, CBP may review the origin of the packaging components themselves. If certain materials or packaging parts were produced outside Korea, the tariff risk may increase. - Higher scrutiny for certain categories
Products involving cosmetics, aluminum, or other sensitive import categories may face a greater chance of review, delay, or hold depending on the entry details and supporting documentation.
The impact of this issue goes far beyond tariff cost alone.
Delays in inspection can lead to shipping delays and increased logistics costs.
A post-entry audit can trigger retroactive review of prior imports, along with potential penalties and legal exposure.
And over time, these issues can also weaken price competitiveness and put pressure on brand reputation in the market.
This is happening at the same time that the de minimis environment has also changed, making low-value shipments much less straightforward than before. As a result, activities that many brands once treated as simple, such as influencer sample shipments or direct-to-consumer orders through channels like Shopify or TikTok Shop, now require a much more careful approach to customs, duties, and fulfillment planning.
From our perspective, after more than 20 years of watching the North American logistics market, periods of uncertainty like this are rare. For K-Beauty brands, this is not just a temporary customs issue. It is a clear turning point that requires a more deliberate response strategy.