How to Import Raw Materials: A Compliance Guide

Importing raw materials comes down to two determinations made for each material — its HTS classification and its country of origin — because together they set your duty rate, your exposure to antidumping and countervailing duties, and which agency (USDA, EPA, or FDA) has to clear the goods. “Raw materials” is a catch-all that covers metals, minerals, wood, agricultural commodities, and chemical inputs, and the rules diverge sharply depending on which one you are bringing in. This guide covers the common backbone and the material-specific traps.

Classification and Origin Drive Everything

Every raw material is entered under a code in the Harmonized Tariff Schedule (HTSUS), and that code — combined with the country of origin — determines the rate of duty, eligibility for any trade-preference program, and whether trade-remedy duties apply. The importer of record is responsible for both calls under the duty of “reasonable care” (19 U.S.C. § 1484).

Because raw commodities are often nearly fungible, classification disputes are common, and small differences (form, purity, processing stage) move goods between tariff lines. Build the entry on a defensible classification analysis and a documented country-of-origin determination, and confirm the customs value you declare reflects the real transaction.

Watch for Antidumping and Countervailing Duties

Raw materials are the single most common target of U.S. trade-remedy cases. Antidumping (AD) duties offset goods sold below fair value; countervailing (CVD) duties offset foreign subsidies. They are assessed in addition to ordinary duty and can be steep and retroactive, so the question is not just “what is the tariff rate” but “is this material, from this country, under an AD/CVD order?”

Steel, aluminum, and many industrial chemicals also sit under shifting tariff actions (for example, Section 232 measures), and those rates change frequently — verify the current order and rate for your specific commodity and country at entry rather than relying on a figure that may be out of date.

Material-Specific Agency Clearances

The biggest difference between raw-material imports is which agency regulates the commodity:

• Metals and minerals → primarily customs and trade-remedy exposure (AD/CVD, Section 232); some critical minerals also carry reporting interest.
• Agricultural commodities (grains, plants, seeds, animal products) → USDA’s Animal and Plant Health Inspection Service (APHIS), often requiring import permits and phytosanitary certificates.
• Wood and timber → the Lacey Act, which makes it unlawful to import illegally harvested plants and requires a plant-products declaration (PPQ Form 505) for covered goods. APHIS expanded the declaration to many more wood products under Phase VII beginning December 1, 2024, and as of January 1, 2026 these declarations must be filed electronically rather than on paper.
• Chemical inputs → EPA under TSCA, including the Section 13 import certification (see our guide to importing chemicals).

Screen for Forced Labor

Several common raw materials — cotton, polysilicon, aluminum, and some minerals — fall within forced-labor enforcement. Under the Uyghur Forced Labor Prevention Act, there is a rebuttable presumption that goods produced wholly or in part in the Xinjiang region of China are barred from entry under 19 U.S.C. § 1307 unless the importer rebuts it with clear and convincing evidence. Trace raw-material supply chains to their origin and keep the traceability documentation, because CBP can detain goods on this basis without a prior order.

Post a Bond, Keep Records, Plan for Audits

Commercial imports generally require a customs bond to guarantee payment of duties and compliance — important for raw materials because AD/CVD and tariff actions can raise the amount owed after entry. Keep all import records for five years under 19 U.S.C. § 1508, and treat import-compliance risk as an ongoing program, not a one-time filing. If your material is subject to AD/CVD, expect closer scrutiny and possible customs audits.

Frequently Asked Questions

What determines the duty on imported raw materials?

The 10-digit HTS classification and the country of origin set the ordinary duty rate and preference eligibility. On top of that, raw materials may owe antidumping or countervailing duties, and metals like steel and aluminum may carry additional tariff actions that change over time.

Do I need a special permit to import raw materials?

It depends on the material. Agricultural commodities and plants usually require USDA/APHIS permits and phytosanitary certificates, wood products require a Lacey Act declaration, and chemical inputs require a TSCA certification. Metals and minerals are usually governed by customs and trade-remedy rules rather than a permit.

What is the Lacey Act declaration for wood imports?

The Lacey Act bars importing illegally harvested plants and requires a PPQ Form 505 declaration of the genus, species, volume, and country of harvest for covered plant and wood products. Coverage expanded under Phase VII starting December 1, 2024, and filings moved to electronic submission as of January 1, 2026.

How do antidumping and countervailing duties affect raw materials?

They add duties — sometimes large ones — when a specific commodity from a specific country is sold below fair value (AD) or is subsidized (CVD). Always check whether your material and source country are under an existing AD/CVD order before you commit to a purchase.

Raw-material imports reward homework done before the purchase order: classification, origin, trade-remedy exposure, and the right agency clearance. Reidel Law Firm helps importers run those checks on flat-fee terms, with a plain-English compliance memo and direct attorney access. Get an import compliance memo.