US Import Regulations for Blank Apparel: A Compliance Checklist for B2B Buyers

Introduction: Why US Import Compliance Matters for Blank Apparel Buyers

Importing blank T-shirts, hoodies, polo shirts, and tank tops from China, Vietnam, Bangladesh, or other manufacturing hubs is a core sourcing strategy for US clothing brands, print shops, and distributors. But unlike domestic purchasing, international apparel imports trigger a set of US government regulatory requirements that, if missed, can turn a routine shipment into a costly compliance failure.

Unlike a general guide to shipping terms — such as our EXW vs FOB vs DDP comparison — this article focuses specifically on the regulatory layer: what US Customs and Border Protection (CBP), the Federal Trade Commission (FTC), and other agencies require from you as the importer of record, and exactly what you must have in place before your cargo arrives at a US port.

The stakes are real. CBP can hold your cargo pending inspection. The FTC can refuse entry to garments with incorrect labels. And misclassified HTS codes can result in back-payment demands plus penalties that dwarf the original duty bill. This checklist walks you through every compliance step, in the order you need to handle it.

What Is the Importer of Record, and Why Does It Matter?

Before diving into the checklist, one foundational concept: the Importer of Record (IOR) is the person or entity legally responsible for ensuring imported goods comply with all US laws and for paying any applicable duties and taxes. As a US buyer importing blank apparel, you — or your licensed customs broker acting on your behalf — are the IOR.

Being the IOR means you are on the hook for:

• Correct classification and valuation of your goods
• Payment of all duties, taxes, and fees
• Compliance with import prohibitions and restrictions
• Maintenance of import records for five years

Many first-time US blank apparel importers assume their supplier or freight forwarder handles this. In reality, the IOR designation must be explicitly assigned — typically to you or your customs broker — and it cannot be delegated to a foreign party. Understanding this is the foundation of everything that follows.

The US Blank Apparel Import Compliance Checklist

Work through these steps in order, from pre-shipment preparation through final US Customs clearance.

Step 1: Classify Your Goods with the Correct HTS Code

The Harmonized Tariff Schedule (HTS) code is a 10-digit US classification code that determines your duty rate. For blank apparel, the relevant HTS chapters are:

Key points:

• HTS codes are specific to garment type (knitted vs woven), fiber content, and end-use
• The first 6 digits are the global HS code; the additional 4 digits (the 7th through 10th) are US-specific
• Always verify your 10-digit HTS code with a licensed customs broker before ordering — the exact code affects your duty rate
• Misclassification is one of the most common CBP penalty triggers for apparel importers

Step 2: Determine Your Customs Bond Requirement

A customs bond is a financial guarantee between you (the importer), a surety company, and CBP. It guarantees payment of all duties, taxes, and fees, plus compliance with US import laws.

For commercial blank apparel shipments, you have two options:

When is a bond required? CBP requires a customs bond for all commercial imports where the total duties, taxes, and fees exceed $2,500. For most full-container blank apparel orders — even a 20ft FCL of T-shirts will exceed this threshold — an annual bond is the practical choice. For LTL shipments, a single entry bond may be more cost-effective.

Action item: If you import more than twice per year, obtain an annual continuous bond. Your freight forwarder or customs broker can usually arrange this through a surety company.

Step 3: File Your Importer Security Filing (ISF) 24 Hours Before Departure

The Importer Security Filing (ISF), also called 10+2, is a CBP regulation requiring importers to submit detailed cargo information before ocean freight arrives at a US port. For blank apparel imported via ocean container, ISF filing is mandatory.

ISF must be submitted no later than 24 hours before vessel departure from the origin port. Late filings can result in CBP holds, fines ($5,000–$10,000 per violation), and cargo delays.

The ISF requires 10 data elements from the importer (plus 2 from the carrier):

1. Manufacturer (or supplier) name and address
2. Seller name and address
3. Buyer name and address
4. Ship-to name and address (US destination)
5. Container stuffing location
6. Consolidator name and address (if applicable)
7. Importers of record number (your EIN or SSN)
8. Consignee number(s)
9. Country of origin
10. Commodity HTS code (10-digit)

Who files ISF? Your freight forwarder or customs broker typically files ISF on your behalf, but as the importer of record, you are ultimately responsible for its accuracy and timeliness. Always confirm your forwarder has submitted ISF at least 24 hours before your vessel sails.

Note: ISF does not apply to air freight or to shipments arriving via land border (Canada/Mexico). It applies exclusively to ocean cargo containers.

Step 4: Understand Section 301 Tariffs on Chinese Apparel

Since 2018, the US has maintained Section 301 tariffs on a broad range of goods imported from China, including most categories of apparel. These tariffs are in addition to the regular MFN duty rates shown in the HTS table above.

For most blank apparel sourced from China, the additional Section 301 tariff is 7.5% to 25% depending on the product category and the specific tariff tranche that applies. These tariffs have been subject to periodic modifications and exclusions.

What this means for your landed cost:

Practical implication: Always calculate your all-in landed cost — including Section 301 tariffs — before committing to a Chinese supplier. The true cost of sourcing from China vs Vietnam or Bangladesh (which are not subject to Section 301 tariffs on apparel) can be substantially different from the FOB price alone.

For guidance on comparing sourcing countries, see our article on working with Chinese blank apparel suppliers.

Step 5: Comply with FTC Textile and Apparel Labeling Rules

The FTC Care Labeling Rule and related textile labeling regulations apply to all apparel sold or imported into the US for commercial use. As a B2B blank apparel buyer importing for resale or for decoration (screen printing, DTG, embroidery), you are responsible for ensuring the garments you import have compliant labels.

Every garment must have a permanent label (affixed to the inside of the garment) showing:

• Fiber content: Percentage of each fiber (e.g., "100% Cotton" or "80% Cotton, 20% Polyester")
• Country of origin: e.g., "Made in China," "Made in Vietnam"
• Care instructions: Using standard FTC-approved care symbols or words (e.g., "Machine wash cold," "Tumble dry low")

RN number: If your company is importing apparel for commercial sale, you may need an RN number (RN stands for Registered Identification Number) issued by the FTC. This number identifies your company as the manufacturer or marketer on the garment label. Application is free via the FTC website.

What to verify with your supplier before ordering:

• Care labels are pre-attached and comply with FTC format
• Country of origin marking is correct and permanently affixed
• Fiber content matches what was quoted/ordered (e.g., ring-spun cotton vs open-end cotton)
• RN number (if required) is on the label or hang tag

Step 6: Appoint a Licensed Customs Broker

A licensed customs broker is your primary interface with CBP. Brokers handle entry filing, duty payment, cargo release, and post-entry amendments. For blank apparel importers who are new to US import procedures, a competent customs broker is not optional — it is a compliance requirement in practice.

When selecting a customs broker for apparel imports, confirm they:

• Hold a valid CBP customs broker license
• Have specific experience with textile/apparel HTS classification
• Can handle both ocean freight (FCL/LCL) and the relevant port of entry
• Provide pre-entry classification advisory (to confirm HTS code before shipment sails)
• Have access to a bond surety if you need help obtaining an annual bond

Many freight forwarders (such as DHL Global Forwarding, Kuehne+Nagel, or BCO-based forwarders) offer integrated customs brokerage services. Alternatively, you can appoint an independent broker. The key is to have the broker relationship established before your first shipment, not after cargo arrives at port.

Step 7: Understand the CBP Entry Process and Entry Types

When your ocean shipment arrives at a US port, your customs broker files a customs entry to begin the clearance process. The entry type affects timing and cost:

After entry filing, CBP may inspect a percentage of shipments (targeted or random). If your cargo is selected for examination, expect an additional 3–7 days. Your freight forwarder handles the examination logistics. Exam fees from the carrier or port authority are typically passed to the importer.

Step 8: Plan for US Warehouse Receipt and Compliance Records

After CBP clears your cargo, it moves to your designated US warehouse or fulfillment location. At this stage, retain the following records — CBP requires importers to maintain import records for five years from the date of entry:

• Customs entry package (commercial invoice, packing list, bill of lading)
• ISF confirmation
• Customs bond records
• HTS classification documentation
• Proof of duty payment
• Any CBP correspondence or inspection results

Organizing these records from day one makes your business audit-ready and simplifies any post-entry amendments or customs audits. For guidance on the broader supply chain from purchase planning through delivery, see our article on fabric lead times and production timelines.

Common Compliance Mistakes and How to Avoid Them

Based on patterns observed among first-time and mid-size US blank apparel importers:

Frequently Asked Questions

What HTS code should I use for blank T-shirts imported from China?

Men's and boys' knitted cotton T-shirts typically use HTS code 6109.10.0005 (duty rate 16.5% MFN). Women's and girls' versions use 6109.10.0012. However, the exact 10-digit code depends on fabric weight, construction, and specific garment type. Always confirm with a licensed customs broker before ordering.

Do I need a customs bond to import blank apparel into the US?

Yes, for shipments where total duties and fees exceed $2,500 — which applies to virtually all full-container and most LCL apparel shipments. You can use a single-entry bond for occasional imports or an annual continuous bond if you import regularly. Annual bonds typically cost $200–$600 and cover all entries for 12 months.

What is the ISF filing deadline for ocean freight from Asia?

ISF must be submitted to CBP no later than 24 hours before vessel departure from the origin port. For shipments from China, Vietnam, or Bangladesh, this means your ISF must be filed before your ocean carrier sails — typically 2–5 days before the actual departure, depending on the carrier's booking cut-off times.

Are Section 301 tariffs still in effect for apparel from China in 2026?

Yes. Section 301 tariffs on most Chinese apparel categories remain in effect as of 2026, with additional rates of 7.5% to 25% depending on the product and tariff tranche. These are in addition to the standard MFN duty rates. Tariff rates and product exclusions are subject to periodic US Trade Representative (USTR) review — monitor the USTR website for current rates.

What labeling is required on blank apparel imported into the US?

Per FTC regulations, every garment must have a permanent label showing: (1) fiber content by percentage, (2) country of origin, and (3) care instructions. If importing for commercial sale, you also need an RN number from the FTC to identify your company on the label. Care labels must use FTC-approved symbols or wording.

How long does US Customs clearance take for blank apparel?

For properly documented shipments with a licensed customs broker, clearance typically takes 1–3 business days after the cargo arrives at the port of entry. Cargo selected for CBP examination can add 3–7 additional days. Factor in US customs clearance when planning your total lead time — see our fabric lead times guide for full timeline planning.

Key Takeaways

• HTS classification is the foundation. Get your 10-digit HTS code confirmed by a licensed customs broker before placing any order.
• ISF filing is non-negotiable. File 24 hours before vessel departure or face penalties of $5,000–$10,000 per violation.
• Budget for Section 301 tariffs on Chinese goods. Add 7.5%–25% above your FOB price for Chinese apparel imports.
• Get an annual customs bond if you import regularly. It costs $200–$600/year and covers all entries.
• Labeling compliance is an FTC requirement, not optional. Verify care labels, country of origin, and fiber content with your supplier before production.
• Work with a licensed customs broker from day one. Their expertise in HTS classification and entry filing is worth the brokerage fee.

For a broader view of shipping economics alongside compliance, see our comparison of LTL vs FCL shipping for US blank apparel buyers. And if you are evaluating sourcing countries, our guide to working with Chinese suppliers covers tariff navigation in detail.