USA Tariff Information
The import duty / tariff landscape in the USA is constantly changing. As an example on 1st Nov 2025 an additional 100% tariff on Chinese products could well come into effect...or it might not. Moreover, as the time between placing an order and actually making a payment for any applicable duty or tariff will be months, the tariff regime could easily have changed once again.
The following information is not definitive or authoritative but is our best interpretation of the current situation, from our perspective as a UK designer and manufacturer of computer keyboards.
First and foremost, any tariff is based on the Harmonized Tariff Schedule of the United States (HTSUS) along with its Genera Rules of Interpretation to assign a 10 digit HTSUS code. There are rules for products with multiple components, products that are a 'set' and also for products that are a 'kit'. There are also country of origin rules. On top of this there are country specific, across the board tariffs, as well as specific product tariffs with aluminium or steel components, tariffs on autos and auto parts etc. It is complex and open to interpretation and, ultimately, is assigned by US Customs and Border Protection.
However, there are underlying principles that can provide a good level of confidence. There is a specific HTS code for computer keyboards - 8471.60.2000. A complete keyboard (apart from customer added switches/keycaps etc), fully or partially assembled is still classified as a keyboard. Even if it could be considered a kit (completely unassembled) or a set (keyboard and a separate PCB), its essential character remains a computer keyboard. Under the HTS system, a keyboard is generally tariff free.
However, for the USA now, it is the country of origin rules that really are the single most significant factor. Currently, a computer keyboard manufactured in China will generally attract around a 30% tariff on its landed value. However, this average 30% reciprocal tariff is due to expire on the 10th Nov 2025 so this could well change again imminently. These tariffs are probably being absorbed by the manufacturer, importer and supplier currently with some or all passed on to the US consumer. If the import costs continue as they are or escalate further it is reasonable to assume that more will be passed on to the consumer in time, increasing the final product cost.
For a non-China based manufacturer, the country reciprocal tariffs are likely to apply. In the case of the UK, this is set generally at 10% if/until a free trade agreement (currently being negotiated) comes into effect. However, for a product to be classified with a UK country of origin, it has to have been sufficiently worked or processed in the UK to meet the specific rules. For goods that incorporate non-originating materials (some keyboard components manufactured in China for instance), origin is determined in two ways:
- A product will meet the rule if the value of non-originating materials does not exceed a certain percentage of the final product's ex-works price (generally no more than 60%).
- The product's commodity code changes after the manufacturing process take place in the UK. i.e. the final product code is different from the individual component codes.
This essentially is a test of 'substantial transformation'. For Fragment, the addition of bespoke resin and transformed wooden components should largely meet this test which, together with all of the other value adding UK components, provides some confidence that the UK origin threshold will be met.
The ordering of additional spare parts as part of the main order of the keyboard should not alter the fact that the product is still designated a computer keyboard and with sufficient UK based 'transformation', resin/wood additions etc, should retain the UK 10% tariff.
An order without wood/resin parts i.e. a base unit with brass is unlikely to meet the substantial transformation or UK added value test, therefore requiring a China origin designation with the additional tariff level that implies.
In summary, to have a higher level of confidence for a UK origin designation and therefore the lower tariff level, the keyboard needs to include wood/resin components, the more the better.
In addition, subsequent orders placed after the main keyboard order has been shipped, if for China origin parts (PCBs, plates particularly), will likely attract a significantly higher tariff together with the extra shipping costs. It would be more cost effective overall to include everything in the first, main order.
We will publish some examples of Fragment configurations and the effect on estimated tariffs in due course.