90%
of all imports were classified as de minimins shipments in FY2024*
How Brands Can Preserve Margins and Customer Experience in a Post-321 World
Key Insights For Brands Based in Specific Regions:
90%
of all imports were classified as de minimins shipments in FY2024*
Closing the de minimis loophole overhauls the playing field. This means you likely have more speed, reliability, and potentially a price advantage over the competition. But that won’t last forever.
Make sure to utilize this period to refine your process and cement your position. Consider savvy marketing campaigns like - Delivered from America- to earn more loyal customers.
To put the above strategies in context, let’s examine how certain companies and sectors are navigating the post-de minimis world, and benchmark the cost impact across product categories:
Chinese-founded e-commerce platforms Shein and Temu became emblematic of the de minimis era. By leveraging the Section 321 loophole, they built a direct-from-China fulfillment model, shipping hundreds of thousands of parcels daily to U.S. consumers at shockingly ultra-cheap prices compared to domestic brands. Now, with the playing field leveling on import duties, U.S. brands are beginning to regain a competitive edge. A Consumer Edge research from April 2025 shows a sharp slowdown in growth for these overseas platforms, while American retailers like Old Navy and Nordstrom Rack saw meaningful gains in consumer spending.27 In response, Temu has pivoted to a domestic fulfillment model, warehousing bulk inventory in the U.S. or working with local dropshippers so that orders arrive quickly and duties are paid upfront. Shein is following suit, investing in North American distribution centers to localize more of its operations.28
Even U.S. discount chains like Five Below are reportedly adjusting their sourcing to capitalize on customers seeking low-cost products without the risk of import delays.29 While American brands that rely on overseas sourcing still face higher costs, the advantage now lies with those that either manufacture domestically or source from tariff-exempt countries. Larger players like Steve Madden are better positioned to absorb these changes, having already diversified their supply chains to countries like Mexico and Vietnam.30 This shift allows U.S. brands to compete on product and brand attributes without being consistently undersold by 25-30% due to a tax loophole, and they can now more prominently highlight "Shipped from USA" as a powerful marketing asset.31
Here’s a breakdown of how U.S. brands under different product categories are affected:
Apparel is arguably the hardest-hit category, facing traditionally high import tariffs ranging from 15-30% depending on the material and garment type.32 When sourcing from China, additional punitive duties can push total tariffs well beyond 50%. For instance, a cotton shirt with a 16% Most Favored Nation (MFN) duty could face combined tariffs of up to 41% or more, depending on classification. Some apparel items may be hit even harder under specific HTS codes. As a result, a landed cost of $10 could easily rise to $14-$18 post-import. Fashion brands operating on thin margins must adapt. Many apparel brands are already raising prices, shifting production to lower-cost countries like Vietnam or Bangladesh, or cutting costs elsewhere. This directly threatens ultra-cheap “dupe” brands, whose business models were built on the de minimis loophole. A decline in the sheer variety of cheap, fast-fashion apparel is expected. On the other hand, domestic apparel producers or those in tariff-exempt trade agreement countries may step in to meet the demand from value-conscious consumers. For these players, the market is shifting in their favor.
Many electronics like smartphones, laptops, and headphones enjoyed zero tariffs under MFN status. However, the new U.S. policy introduced a blanket 10% tariff on most imports, with some exemptions for critical tech components.33 Notably, smartphones and computers remain exempt from the harshest China-specific tariffs. Still, a wide range of general consumer electronics such as gadgets, accessories, and small appliances now face duties of 10-15%. Additionally, direct-to-consumer shipments in this category may now encounter stricter enforcement of FCC compliance or lithium battery shipping regulations due to the shift to formal customs entry. The net effect is an estimated 10-25% price hike on consumer electronics for U.S. buyers. Delivery timelines may also stretch slightly if products are held for safety checks. Brands in this category might consider moving final assembly to countries like Mexico to leverage USMCA benefits or even the U.S. to dodge tariffs.
This is a broad bucket, including toys, home goods, cosmetics, and supplements. Many of these everyday goods previously had low tariffs (0-5%) but now face a base 10% tariff in addition to any existing category-specific rates.34 For instance, plastic household items that once had minimal duties may now see effective rates around 10-15%. While that may not seem significant on a per-item basis, it adds up quickly at scale. Some categories, like toys, already faced 7.5% tariffs under Section 301 if sourced from China, and these rates could now rise further.35 For Health and Beauty products like vitamins and cosmetics, apart from the tariffs, the main challenge now lies in complying with new requirements for full FDA documentation at entry.36 Brands must work closely with customs brokers capable of handling Partner Government Agency (PGA) filings, as every shipment will now require formal declarations.37 Ultimately, while price increases in this category may remain moderate (typically 5-15%), supply chain disruptions are likely if compliance standards aren’t consistently met.
Footwear has notoriously high U.S. tariffs typically at 10-20%, and up to 48% on lower-cost styles.38 Many shoes previously shipped under de minimis, such as knock-off sneakers and budget fashion footwear, avoided these tariffs entirely. With that loophole closed, those products will now be fully taxed, leading to noticeable price increases for online shoe buyers sourcing from abroad. Established brands like Nike won’t see much impact, as their pricing already accounted for these duties. However, gray-market and direct-from-China sellers will likely be forced to either raise prices or exit the market altogether.39 Similarly, accessories such as handbags, which carry high tariffs and are frequent targets of counterfeiting, will now be subject to strict inspection by customs officials. This added scrutiny could further slow shipments or increase compliance requirements for sellers in these categories.
Any niche or industrial products, including B2B small orders, hobbyist electronics, or car parts, will also be subject to duties and formal customs entry. The impact isn’t limited to B2C retail; sellers in B2B e-commerce must adjust their operations and pricing as well. For instance, while auto parts have traditionally carried moderate tariffs, smaller vendors of aftermarket components may need to raise prices to maintain margins under the new rules.
Overall, each product category has its own nuances, but the consistent trend is rising costs which will inevitably be passed on to consumers. The National Retail Federation estimated that in extreme scenarios, total tariffs on some categories could exceed 50%, up from previously single-digit rates. While some brands will try to absorb what they can, many will be forced to raise prices.40 Strategically, brands should assess the relative impact across verticals. If you sell in multiple categories, lean into those with lower tariff exposure in your marketing. Being aware of these category benchmarks will lead to smarter decision-making.