Teeth whitening strips: customs rules by destination

Customs and regulatory rules for whitening strips differ by destination, and several changed this past year. Below is what we've found in official sources, market by market. This is not legal advice. As importer of record, compliance in your market is your responsibility.

HS classification: where whitening strips sit in the tariff book

Teeth whitening strips fall under Harmonized System heading 3306, "preparations for oral or dental hygiene," not general cosmetics headings. U.S. Customs and Border Protection has repeatedly placed whitening strips in subheading 3306.90.0000, most recently in a September 2024 binding ruling on a competing strip product from China.[1] The base U.S. duty on that line is free; origin-specific duties (e.g., Section 301/Chapter 99 on Chinese-origin goods) apply on top of, not instead of, 3306.90. The EU uses the same 3306 heading. Confirm classification and any additional duties with your own broker, since rulings can vary by formulation and packaging.

United States: origin, a Supreme Court ruling, and the end of de minimis

If the strips are of confirmed U.S. origin (check the country-of-origin marking on the carton and confirm it with your broker), goods that were exported and are now returning may qualify for duty-free treatment under HTSUS 9801.00.10, "U.S. goods returned," provided they were not advanced in value abroad.[2] This is a documentary claim, not automatic. CBP requires a foreign-shipper declaration that the goods were not advanced or improved, plus proof of U.S. origin, typically the original export invoice or bill of lading, or for older or higher-value shipments a manufacturer's statement.[2]

Separately, on February 20, 2026 the U.S. Supreme Court ruled 6 to 3 in Learning Resources, Inc. v. Trump that IEEPA does not authorize the president to impose tariffs.[3] That struck down IEEPA-based ad valorem tariffs but left a related action untouched: suspension of the "de minimis" duty-free exemption for low-value shipments, effective August 29, 2025 under Executive Order 14324[4] and made indefinite for non-postal commercial shipments effective June 24, 2026.[5] There is currently no duty-free de minimis entry for commercial whitening-strip shipments at any value, and the tariff litigation hasn't changed that.

Saudi Arabia and the GCC: SFDA notification comes before customs

The Saudi Food and Drug Authority (SFDA) regulates teeth whitening products as cosmetics and requires notification before import or sale in the Kingdom. SFDA publishes a searchable list of notified cosmetic products[6] and runs notification through its current system, GHAD.[7] Notification is filed by a Saudi-licensed importer or distributor, not by the foreign supplier. We have not found an SFDA-published rule specific to whitening products beyond the general notification framework, so confirm current requirements with your Saudi importer before booking freight.

EU and UK: the 0.1% line decides how strips reach consumers

Under EU Regulation (EC) No 1223/2009, Annex III, entry 12, hydrogen peroxide (present or released, including from carbamide peroxide) in tooth-whitening products is capped at 0.1% for unrestricted retail sale.[8] Above 0.1% and up to 6%, products may only be sold to dental practitioners, must carry concentration labeling and an under-18 warning, and first use in each cycle must be by, or under direct supervision of, a dental practitioner. Above 6%, sale as a cosmetic isn't permitted at all.

Hydrogen peroxide (present or released) EU/UK sale channel
≤ 0.1% Open retail sale to consumers
> 0.1% – 6% Dental practitioners only
> 6% Not permitted as a cosmetic

The UK carries the same limits through the retained Annex III and the Cosmetic Products Enforcement Regulations 2013.[9] OPSS enforces this: a September 2025 report found an online-marketplace whitening pen at 7.32% hydrogen peroxide, over 70 times the consumer limit. The product was seized and destroyed and the listing removed.[10] This restricts most consumer-strength strips to dental-practitioner channels in the EU and UK. We state the rule as published. How a buyer structures a compliant EU/UK supply chain is the buyer's call and responsibility as importer of record.

Southeast Asia: Vietnam tightens low-value import treatment

Vietnam removed its VAT exemption for low-value express and e-commerce shipments effective February 18, 2025, under Prime Minister's Decision No. 01/2025/QD-TTg, annulling the prior VND 1,000,000 duty/VAT-free threshold.[11] Low-value parcels no longer enter VAT-free, so plan on VAT applying regardless of shipment value.

Shipping practicalities

Strips shipped in normal commercial quantities are a low-concentration peroxide gel on a plastic backing and are generally not treated as dangerous goods for air freight, but this depends on the exact formulation. Confirm with your forwarder's dangerous-goods desk before booking. We hand the goods to your forwarder ex Hong Kong with a commercial invoice and packing list. Export declaration, air waybill, and destination customs clearance and duty are your forwarder's and your responsibility as importer of record.

Checklist before you order

  • Confirm HS classification (3306.90) and any origin-specific duties with your own broker
  • If claiming U.S. goods returned (HTSUS 9801.00.10), line up the foreign-shipper declaration and proof of U.S. origin before shipping
  • Check current U.S. tariff and de minimis status at time of shipment. Both have changed repeatedly since 2025
  • For Saudi Arabia/GCC, confirm your SFDA-licensed local importer has notified the product before booking freight
  • For the EU/UK, confirm the hydrogen peroxide concentration of the exact product and who you may legally sell it to
  • Ask your forwarder to confirm dangerous-goods classification for your specific formulation and packaging
  • Keep our commercial invoice and packing list on file. You are the importer of record everywhere these goods land

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References

  1. CBP Ruling NY N342147, "The tariff classification of Dr. Dent.co Professional Teeth Whitening Strips from China": https://rulings.cbp.gov/ruling/n342147
  2. U.S. Customs and Border Protection, "Requirements for Importers and Brokers Regarding HTS Subheading 9801.00.10 – U.S. and Foreign Goods Returned": https://www.cbp.gov/trade/programs-administration/entry-summary/hts-subheading-9801
  3. Supreme Court of the United States, Learning Resources, Inc. v. Trump, No. 24-1287, decided February 20, 2026: https://www.supremecourt.gov/opinions/25pdf/24-1287_4gcj.pdf
  4. Federal Register, "Notice of Implementation of the President's Executive Order 14324, Suspending Duty-Free De Minimis Treatment for All Countries" (90 FR 42418, Sept. 2, 2025), effective Aug. 29, 2025: https://www.federalregister.gov/documents/2025/09/02/2025-16802/notice-of-implementation-of-the-presidents-executive-order-14324-suspending-duty-free-de-minimis
  5. Federal Register, "Indefinite Suspension of the De Minimis Exemption for Merchandise Arriving Through All Modes Other Than the International Postal Network," effective June 24, 2026: https://www.federalregister.gov/documents/2026/06/24/2026-12670/indefinite-suspension-of-the-de-minimis-exemption-for-merchandise-arriving-through-all-modes-other
  6. Saudi Food and Drug Authority, List of Notification of Marketing for Cosmetic Products: https://www.sfda.gov.sa/en/cosmetics-list
  7. Saudi Food and Drug Authority, Unified Electronic System (GHAD): https://www.sfda.gov.sa/en/eservices/unified-electronic-system-ghad
  8. Regulation (EC) No 1223/2009 of the European Parliament and of the Council, Annex III, entry 12: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32009R1223 (consolidated Annex III text also at https://www.legislation.gov.uk/eur/2009/1223/annex/III)
  9. The Cosmetic Products Enforcement Regulations 2013 (UK SI 2013/1478), Schedule 3: https://www.legislation.gov.uk/uksi/2013/1478/schedule/3
  10. UK Office for Product Safety and Standards, "Product Safety Report: Bright White Teeth Whitening Pen sold via eBay (2503-0197)," published 15 September 2025: https://www.gov.uk/product-safety-alerts-reports-recalls/product-safety-report-bright-white-teeth-whitening-pen-sold-via-ebay-2503-0197
  11. Prime Minister's Decision No. 01/2025/QD-TTg (Vietnam), annulling Decision No. 78/2010/QD-TTg, effective Feb. 18, 2025: https://thuvienphapluat.vn/van-ban/EN/Bo-may-hanh-chinh/Decision-01-2025-QD-TTg-on-annulment-of-the-entirety-decision-78-2010-QD-TTg/638550/tieng-anh.aspx
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