A year ago the tariff was a line at the bottom of a landed-cost quote. Now it is one of the first numbers a European brand checks before planning a US entry. For some categories, production in the United States deserves a serious look alongside the freight quote.
Washington now polices the workarounds
Look at what happened this month around one raw material. On August 6, Proclamation 11052 put minimum import prices and tariffs on polysilicon and its derivatives under Section 232, taking effect December 4. Then, to stop importers from front-running the change, the Commerce Department issued a temporary rule, in force September 22 through December 3, that polices stockpiling. Existing importers who bring in volumes substantially above their historic averages can be barred from further entries until the new prices take effect. Importers who registered on or after August 6 face weekly volume caps. The government assumed the market would try to beat the tariff and wrote a rule to catch it. That is the climate your pricing now lives in.
Polysilicon is one input, but the direction is general. In July, USTR closed Section 301 investigations into 60 economies over forced-labor import enforcement and added duties of 10 or 12.5 percent, net of the normal MFN rate, on most imports from the European Union that are not exempted. Different legal tools, same result: the landed cost of an imported product keeps picking up new lines, and each new line arrives with enforcement attached.
Run the comparison before the market runs it for you
None of this means every brand should sew in America. It means the make-or-ship comparison now deserves real numbers instead of habit. This is the version I run, a working method rather than a rule.
- Landed cost, honestly. Product cost, freight, insurance, MFN duty, the newer tariff lines that apply to your category, brokerage, and something for the cost of a delayed or held shipment.
- US production cost. Written quotes from two or three contract manufacturers, with minimums, tooling, quality control and realistic lead times.
- The commercial upside. Shorter restocks, smaller minimums, domestic lead times buyers trust, and a local story in the sales meeting.
Duties and tariffs are charged when the goods enter, shipment after shipment. A US production cost is higher per unit and largely fixed. If the gap between the two is thin, one more tariff line tips it. If making it in the US costs double, shipping still wins and the tariff becomes a pricing problem to manage.
A composite example, not a client. A European bedding brand imports finished goods and pays the MFN duty plus the new Section 301 line on every shipment, plus ocean freight. A US contract manufacturer quotes a higher unit cost but no duty, no ocean leg, and a two-week restock. On thin-margin basics the import route still wins. On mid-market collections with frequent restocks, the US quote starts to close. This scenario is illustrative, not a real engagement or a quote.
The label is a separate legal test
One warning before anyone prints packaging. "Made in USA" is a legal claim. The FTC standard is "all or virtually all": final assembly or processing in the US, all significant processing in the US, and all or virtually all ingredients and components made and sourced in the US. Import the fabric and sew it in New Jersey and you may have a strong product with a strong story, but probably not an unqualified Made in USA label. Qualified claims such as "Assembled in USA" exist for exactly that case. The labeling rule has carried civil penalties since 2021, so treat the words on the label with the same care as the duty line.
Aegis Club is based in New York and covers the entire USA. For European home and lifestyle brands, we run the make-or-ship comparison with real numbers: landed cost against US production quotes, the buyers for each route, and pricing that still works with the tariff lines as they stand this quarter.
Sources: Federal Register, Measures To Restrict Stockpiling of Polysilicon and Polysilicon Derivatives Under Proclamation 11052 (temporary final rule); Office of the US Trade Representative, "USTR Takes Action in Forced Labor Section 301 Investigations," July 23, 2026; Federal Trade Commission, "Complying with the Made in USA Standard".