USA Tariff Information

The import duty/tariff landscape in the USA is constantly changing. The current truce between the US and China may or may not last and the decision of the US Supreme Court on the legality of some of the tariffs is now pending. 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 is the single most significant factor. Currently, a computer keyboard manufactured in China will generally attract around a 20% tariff on its landed value (updated following adjustments agreed during the most recent negotiation between China and the US, effective from 10th November 2025). However, different estimating tools are currently indicating varied results from 20% through to 35% so it's not at all clear. These tariffs will be/are probably being absorbed by the manufacturer, importer and supplier currently with some (or all) passed on to the US consumer. If the tariff regime continues in this manner or escalates 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:

 

  1. 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%).
  2. 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 have worked up a few examples of Fragment configurations and the possible effect of the current estimated tariffs (see below).

Example 1

  • Configuration 1

    Example 1 shows a base unit with with a wooden accent material (in this case oak) and no additional parts. The cost of this configuration is US$340.

    Shipping to the USA is US$45 for this configuration and therefore the landed value for the tariff calculation is US$385.

  • Estimated Tariff

    A consequence of specifying the wooden components in this configuration enables the product to be classified as UK origin, therefore subject to a 10% tariff.

    The estimated total cost would be US$424.

    Any additional extra wooden or resin parts will improve the overall UK value proportion strengthening the UK country of origin designation. Therefore it is recommended to add at least one resin component in addition to the base unit. Generally, however, largely all wooden configuration units should qualify as a UK origin product.

Example 2

  • Configuration 2

    Example 2 shows a base unit with with a brass accent material and no additional parts. The cost of this configuration is US$390.

    Shipping to the USA is US$51 (shipping cost is higher due to the added weight) and therefore the landed value for the tariff calculation is US$441.

  • Estimated Tariffs

    Since this configuration has no UK origin components and has not been substantially transformed, it will be subject to the tariff applied for China origin goods, currently estimated at 20-35%.

    The estimated total cost would be US$529 or US$595 of which US$88 or US$154 resectively is the US import tariff.

Example 3

  • Configuration 3

    Example 3 shows the following configuration including some additional options:

    • Base Unit
    • Brass Accent Material
    • Cracked Resin Backplate
    • Split Navigation Badge
    • Gloss Wood Finish
    • Polypropylene Plate
    • Hotswap PCB


    The total cost of this configuration without extra parts is US$475.

    Shipping to the USA is US$51 (shipping cost is higher due to the added weight) and therefore the landed value for the tariff calculation is US$526.

  • Estimated Tariffs

    Since this configuration has sufficient UK origin components and undergoes a substantial transformation within the UK, it should qualify as a UK origin product, attracting the lower 10% tariff. The addition of the resin backplate, navigation badge and gloss finish evidence substantial transformation within the UK.

    The estimated total cost would be US$579 of which US$53 is the US import tariff.

    As this configuration likely qualifies as a UK origin product the total cost works out significantly less than a base brass unit and features a number of additional components.

TLDR

Fragment configurations including wooden components should qualify as a UK product but would benefit from additional resin components to add more UK origin value.

A Fragment base unit brass configuration will likely have to be declared as a China origin product, attracting the currently estimated 20-35% tariff applicable to most China origin goods imported into the USA.
Brass accent units with significant additional resin components (primarily the backplate option) should qualify as a UK origin product because of the substantial transformation of the brass backplate thereby changing its country of origin.

If the UK and the USA were to conclude a Free Trade Agreement in due course, country of origin rules would likely be more precise allowing further refinement of what is required for a product's country of origin to be determined. However, at this time the final decision rests with US Customs and Border Protection and we cannot guarantee how they will view the product. Our estimates are based upon information available online, DHL's tariff estimation tools, other similar online tools and general guidlines on country of origin rules.