Consumer Goods · For mid-market and enterprise importers
Get every SKU through U.S. customs in time for the retailer's delivery window.
Greenwich Mercantile works with consumer goods brands and suppliers that sell through U.S. retailers and manage hundreds of SKUs. Consumer goods run on retailer dates and promotional calendars. A container held over a missing children's product certificate, a wrong origin marking or an unanswered forced-labor question can miss the window it was bought for. Greenwich gets that paperwork in place before the goods ship, and uses the same record so you pay the lowest duty the law allows.
Why consumer goods get held at the border.
Home and kitchen goods, housewares, furniture and home decor, toys and juvenile products, sporting goods and personal care accessories share one border problem: hundreds of SKUs from many suppliers, where one missing or mismatched fact can hold a shipment. The usual causes:
- Supplier documents that do not agree. The invoice, packing list and product specification describe the same SKU differently.
- Children's product certificates. Toys and other products designed or intended primarily for children 12 or younger need a Children's Product Certificate, based on CPSC-accepted third-party laboratory tests, when a CPSC children's product safety rule applies. Since July 8, 2026, importers of most regulated consumer products must also eFile certificate data at entry.
- Origin marking that is missing or wrong. Each article, or its container where the rules allow, must show the English name of its country of origin, legibly and permanently, where the final buyer will see it.
- Forced-labor evidence nobody has collected. Under the Uyghur Forced Labor Prevention Act, goods made wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are presumed prohibited from U.S. importation. If CBP detains a shipment, the importer must show where the goods and their materials came from.
- Inconsistent tariff codes across the catalog. Similar products from different suppliers end up under different codes, and the code decides which agency data, such as CPSC certificate data, CBP expects at entry.
Each cause shows up in the paperwork and can be caught before the goods leave the factory.
What we do for consumer goods brands and retailers.
| When | What we do | What it is worth |
|---|---|---|
| Before the purchase order | Landed cost by SKU and supplier: duty, fees and delivered cost, with country-specific tariffs confirmed by a licensed broker for the entry date. | You see which factory is cheapest before the order and the promotional price are set. |
| Before the goods ship | Invoice, packing list, certificates, test reports, origin marking and supply-chain records checked against each other. Gaps go back to the supplier while the goods are still at the factory. | Stock is less likely to miss the retailer's delivery window over paperwork. |
| Every SKU, every reorder | One record per SKU: materials, tariff code, origin, value and certificate status, reused on every reorder and every new supplier. | The broker supports the correct duty treatment, and CBP questions are answered from the file. |
The work runs from the files and exports you already have. A licensed U.S. customs broker reviews the duty position and files the entry under their own power of attorney: our broker partner, or your existing broker working from the same record. Your company remains the importer of record and pays the duty.
Where the duty savings are in consumer goods.
One correction can repeat across many SKUs and every reorder. The savings come from getting the record right:
- Classification across the catalog. Material and function decide the tariff code: a storage box in plastic, wood or metal takes a different heading for each material. Gift sets may be classified as one article or item by item, depending on the rules for sets. See HTS classification errors.
- Origin. For most consumer goods, moving final assembly changes origin only if the work is a substantial transformation under CBP's rules, so settle the answer before production moves. See how CBP decides origin.
- First sale valuation. Where you buy through a trading company or other middleman, duty can in some cases be declared on the factory's price to the middleman. The first sale must be genuine, at arm's length, clearly destined for the United States and well documented. See customs valuation and first sale.
- Duty drawback on exports and returns. Duty paid on goods later exported, or returned to the supplier as defective or not to specification, may be refundable as drawback when the records match each export to a qualifying import. See how duty drawback works.
Apart from the general rate in the illustrative example below, Greenwich does not quote duty rates on this page. Tariffs on consumer goods have changed several times since early 2025, and the rate for any entry must be confirmed by a licensed broker for the entry date.
An illustrative duty example: first sale valuation on a $100,000 order.
Illustrative example. First sale valuation is one legal way for consumer goods importers that buy through a trading company to lower U.S. import duty. A U.S. importer buys an order of cotton terry bath towels from a trading company for $100,000. The trading company bought the same towels from the factory for $80,000.
Cotton terry towels are classified under HTS 6302.60.00 (toilet linen and kitchen linen, of terry toweling or similar terry fabrics, of cotton), general rate 9.1%.
Declared at the price paid to the trading company, the order pays $100,000 × 9.1% = $9,100 in duty. Declared at the factory's price under first sale, the same order pays $80,000 × 9.1% = $7,280 in duty, which is $1,820 less.
First sale valuation applies only when the factory's sale to the middleman is a genuine sale at arm's length, the goods are clearly destined for the United States when the middleman buys them, and invoices, contracts and proof of payment for both sales show it. In CBP's published guidance, goods made to a U.S. retailer's design specifications, carrying the retailer's labels, stock numbers and bar codes, and shipped directly from the country of manufacture to the United States are an example of goods clearly destined for the United States.
The example uses only the general (MFN) rate returned by the USITC Harmonized Tariff Schedule on 2 October 2026. Additional duties in force on the entry date must be confirmed by a licensed broker, and a licensed broker reviews the first sale evidence before the lower value is declared.
How the first piece of work is scoped.
The first piece of work covers one product category or one supplier country, with a defined output, a fixed fee quoted in writing before work starts, and a delivery date. You keep the output whether or not anything follows it.
Before that, a 20-minute call shows whether there is a problem worth pricing: which SKUs raise questions at entry, where supplier paperwork slows shipments, and what a missed delivery window costs you.
Questions, answered directly.
What do consumer goods importers need to clear U.S. customs?
A commercial invoice and packing list that agree, a correct tariff code, value and country of origin for every SKU, and origin marking on each article or its container. Products covered by a CPSC rule also need a certificate of compliance, and goods with materials that could come from Xinjiang need supply-chain tracing evidence.
What changed for CPSC certificates on July 8, 2026?
Since July 8, 2026, importers of most regulated consumer products must file certificate data electronically with CBP at entry, in full or by reference to a certificate stored in the CPSC Product Registry. For goods entered from a foreign-trade zone, the requirement starts on January 8, 2027. The certificates are not new; their data now travels with the entry.
Can Greenwich lower the duty we pay on consumer goods?
Where the facts allow it, yes: consistent classification across the catalog, first sale valuation where the buying structure allows it, origin planning before production moves, and drawback on exported goods. Any saving depends on your products and documents, and every duty position is reviewed by a licensed U.S. customs broker.
Can you promise our shipments will not be held?
No. CBP can examine or detain any shipment, and CPSC staff can inspect consumer products at the port. Greenwich works to prevent holds caused by missing or inconsistent paperwork, such as a missing certificate, a wrong origin marking or supplier documents that disagree.
Who files the entry with U.S. Customs?
A licensed U.S. customs broker reviews and files every entry under your power of attorney: one of our partner brokers, or your existing broker working from the same record. Greenwich does the customs work behind each entry with AI: the landed-cost model, the pre-entry document pack and the product record. Your company remains the importer of record and pays the duty.
Sources and limits
- CPSC: eFiling of certificate data
- CPSC: eFiling frequently asked questions
- CPSC: Children's Product Certificate
- 19 CFR Part 134: country of origin marking
- CBP: Uyghur Forced Labor Prevention Act
- CBP: drawback overview
- CBP: Bona Fide Sales and Sales for Exportation to the United States (first sale guidance)
- USITC HTS 6302.60.00: cotton terry toilet and kitchen linen (general rate 9.1%)
Sources support the stated context, but are not an endorsement of Greenwich and not a determination on your shipments. Nothing on this page is a duty quotation.
Twenty minutes with whoever owns your U.S. imports.
Tell us which SKUs, suppliers and retailer deadlines matter most. We will tell you honestly whether there is anything worth doing.
Or write to cameron@greenwich-mercantile.com.