Importing NA Beverages into the US · June 3, 2026
HS Code for Non-Alcoholic Beverages: 2202 and Duty
Non-alcoholic beverages classify under HS 2202: NA beer at 2202.91, alternatives at 2202.99.
Nick Bodkins · Co-founder, Avenor · New York
Every commercial shipment of NA beverages entering the US must clear US Customs and Border Protection (CBP) through a formal entry process. For non-alcoholic beverages, the CBP entry covers tariff classification, duty payment, and country-of-origin declaration — and unlike alcohol imports, there is no federal excise tax on truly non-alcoholic (sub-0.5%, non-malt) beverages. Getting the HS code classification right and having complete documentation prevents costly delays at port.
The excise-tax edge: Sub-0.5% non-malt non-alcoholic beverages pay no federal excise tax — while imported wine carries $1.07–$3.40/gallon and spirits $13.50/proof gallon on top of duty. On a landed-cost basis, that single exemption is the NA category's most underappreciated structural advantage.
Key Takeaways
- CBP entry is a separate parallel process from FDA prior notice — both are required; they serve different agencies.
- Non-alcoholic beverages (sub-0.5% ABV, non-malt) carry no federal alcohol excise tax — a meaningful landed-cost advantage over alcohol.
- HS code classification determines duty rate; most beverages fall under Chapter 22 of the Harmonized Tariff Schedule.
- Since 24 July 2026, EU-origin NA beverages pay a combined US duty of 10% of customs value (MFN plus Section 301).
- A licensed US customs broker handles the CBP entry filing for most commercial shipments.
- Country of origin, commercial invoice accuracy, and HS code classification are the three highest-stakes elements of the entry.
What Is CBP Entry?
When a commercial shipment arrives at a US port, it must be "entered" into US commerce through a formal CBP process. Customs entry covers:
- Tariff classification — assigning the correct HS (Harmonized System) code
- Duty payment — calculating and paying applicable import duties
- Country-of-origin declaration — confirming where the goods were produced
- Other agency coordination — CBP coordinates with the FDA, USDA, TTB, and other agencies whose regulations apply to the goods
The primary CBP filing document is Form 7501 (Entry Summary), typically prepared by a licensed customs broker. The importer of record is legally responsible for the accuracy of the entry, even if a broker prepares it.
The Core Entry Documents for Non-Alcoholic Beverages
| Document | Purpose | Prepared By |
|---|---|---|
| Commercial Invoice | States seller, buyer, goods description, quantity, price, country of origin | Exporter / manufacturer |
| Packing List | Detailed breakdown of carton/case counts, weights, dimensions | Exporter |
| Bill of Lading (ocean) or Airway Bill (air) | Transport contract; identifies goods, shipper, consignee | Freight carrier |
| CBP Entry Summary (Form 7501) | Declares goods to CBP; includes HS code, duty, value | Customs broker |
| FDA Prior Notice Confirmation | Confirms FDA food safety pre-notification | Customs broker / importer |
| Certificate of Origin | Supports duty preference claims under trade agreements | Exporter |
The commercial invoice is the single most important document for customs purposes. Inaccuracies — wrong product description, understated value, incorrect quantity — are the leading causes of CBP holds and penalty exposure for food importers.
Which HS Code Does Your Non-Alcoholic Beverage Fall Under?
The Harmonized Tariff Schedule (HTS) of the United States organizes imported goods by classification code. Chapter 22 covers "Beverages, spirits, and vinegar." Most NA beverages enter under HTS 2202, which covers drinks of an alcoholic strength not exceeding 0.5% vol — the exceptions are juices (heading 2009) and dealcoholized wine that finishes above 0.5% ABV (wine headings). The table below breaks out the codes that matter for the category, with the MFN duty rate and the total an EU-origin shipment pays since 24 July 2026.
| HTS code | Covers | What falls here | MFN duty | Total for EU origin (from 24 Jul 2026) |
|---|---|---|---|---|
| 2202.10 | Waters with added sugar/sweetener or flavored | Flavored sparkling water, sweetened NA sodas & mixers | 0.2¢/liter | 10% of customs value |
| 2202.91 | Non-alcoholic beer (0.5% ABV or less) | Dealcoholized and brewed NA beer | 0.2¢/liter | 10% |
| 2202.99 | Other non-alcoholic beverages (catch-all) | NA wine & spirit alternatives, hop waters, RTD NA cocktails, botanical drinks | 0.2¢/liter | 10% |
| 2009 | Fruit & vegetable juices, unfermented | 100% juice, juice blends, juice-forward NA drinks | Free to about 7.9¢/liter (varies by juice) | 10% for most juices; orange juice and a few named juices are exempt from the Section 301 layer |
| 2204 | Wine of fresh grapes | Dealcoholized wine finishing above 0.5% ABV | 6.3¢/liter (still wine) | 10% |
Rates as of September 2026, from the US Harmonized Tariff Schedule and CBP's guidance on the July 2026 Section 301 action; verify them against the current schedule at time of importation. The takeaway for most brands: the MFN rate under 2202 is a fraction of a cent per liter, but since 24 July 2026 goods of the EU pay a combined MFN and Section 301 duty of 10% of customs value, and that includes NA beer under 2202.91.
What Is the HS Code for Non-Alcoholic Beer?
Non-alcoholic beer classifies under HTS 2202.91, the dedicated US subheading for non-alcoholic beer of 0.5% ABV or less. Its MFN rate is 0.2¢ per liter, and from the EU it pays the combined 10% since 24 July 2026. The subheading covers brewed-to-strength and dealcoholized beer alike; confirm the final tested ABV, since anything above 0.5% moves the product out of the heading.
What Is the HS Code for Non-Alcoholic and Dealcoholized Wine?
Dealcoholized wine that finishes at 0.5% ABV or less classifies under HTS 2202.99, the catch-all for other non-alcoholic beverages, with an MFN rate of 0.2¢ per liter and a combined 10% for EU-origin goods since 24 July 2026. Wine that finishes above 0.5% ABV falls back into heading 2204 — classification follows the final tested ABV, never the pre-dealcoholization strength.
What Is the HS Code for Alcohol-Free Spirits and Ready-to-Drink Alternatives?
Alcohol-free spirit alternatives, botanical drinks, hop waters, and ready-to-drink cocktail alternatives classify under HTS 2202.99, provided they finish at 0.5% ABV or less: an MFN rate of 0.2¢ per liter, and the combined 10% for EU-origin goods. Sweetened sodas and flavored waters sit in 2202.10 at the same rates. Chapter 22 of the US Harmonized Tariff Schedule is the controlling source.
Critical note on dealcoholized wine: If a dealcoholized wine ends up above 0.5% ABV in the final product, it may need to be classified under the wine headings (2204) rather than the non-alcoholic beverage heading (2202). This matters because wine headings carry different duty rates and trigger different agency review. Always use the final, tested ABV of the product for customs classification — not the original ABV before dealcoholization.
HS code classification is a legal determination. Use a licensed customs broker who has experience with beverage classification to confirm the correct code for your specific product.
Duty Rates: What Does It Actually Cost?
Duty rates for beverages under Chapter 22 depend on HS code, country of origin, and applicable trade agreement provisions. Under MFN (Most Favored Nation / Normal Trade Relations) rates, every NA beverage line under heading 2202 carries 0.2¢ per liter. Since 24 July 2026, goods of the EU with an MFN rate below 10% pay a combined MFN and Section 301 duty of 10% of customs value, so an EU-origin NA beverage now pays 10% (CBP CSMS #69326983).
Duty rates change and must be verified against the current HTS schedule at the time of importation. US trade policy has moved quickly: tariffs imposed under IEEPA applied through 2025 until the Supreme Court struck them down on 20 February 2026, a 10% Section 122 surcharge ran from 24 February to 23 July 2026, and the Section 301 action replaced it on 24 July 2026. Verify current rates with your customs broker at time of shipment.
The excise tax advantage: Unlike alcohol imports — where federal excise taxes apply on top of duty (wine: $1.07–$3.40/gallon; distilled spirits: $13.50/proof gallon; beer: $3.50, $16 or $18 per barrel, depending on the brewer's volume and eligibility for reduced rates) — sub-0.5% non-malt NA beverages carry no federal excise tax. This is a meaningful landed-cost advantage and one of the underappreciated economic features of the NA category. Malt-based NA beer is "nontaxable" under IRC §5051 — it also carries no excise tax, but the label must state "Nontaxable under section 5051 I.R.C."
Worked Example: Landed Duty & Fees on One Pallet EU→US
Import charges at entry are the duty plus two CBP user fees: the Merchandise Processing Fee (MPF) and, for ocean freight, the Harbor Maintenance Fee (HMF). Take one pallet of sparkling NA aperitif shipped by sea from France, classified under 2202.99, with a customs (transaction) value of $8,000 and a net volume of 1,000 liters, entered between 24 July and 30 September 2026:
| Charge | Rate | On this pallet |
|---|---|---|
| Import duty (2202.99, MFN) | 0.2¢/liter × 1,000 L | $2.00 |
| Section 301 duty (EU goods, heading 9903.05.39) | Brings the total duty to 10% of value | $798.00 |
| Merchandise Processing Fee (MPF) | 0.3464% of value, min $33.58 | $33.58 (minimum applies) |
| Harbor Maintenance Fee (HMF, ocean only) | 0.125% of value | $10.00 |
| Total duty + CBP fees | $843.58 |
On an $8,000 pallet, total CBP duty and fees come to $843.58, about 10.5% of cargo value, and the Section 301 layer is almost all of it. Under the MFN rate alone the same pallet would pay $45.58. For an EU brand, entry cost is now a margin line: build it into the landed cost and the shelf price. The importer of record owes the duty at entry; who bears it commercially depends on your terms of sale.
Two caveats. The MPF is bounded: 0.3464% of value with a formal-entry minimum of $33.58 and a maximum of $651.50 through 30 September 2026, rising to $34.58 and $670.86 from 1 October 2026 (Federal Register, 31 July 2026). From 1 October the pallet above totals $844.58. And the HMF applies only to ocean shipments; air freight skips it. Confirm the current figures with your broker at time of entry.
The duty and fees above are only one layer of your true cost to shelf. To model the full picture, pair this with the currency, freight, and landed-cost guide for EU→US imports, then work the result forward with the FOB-to-shelf pricing and margin guide.
FDA and CBP: How the Two Processes Connect
CBP and the FDA work together at ports of entry. CBP screens all entries; the FDA reviews the food-specific information. The interaction looks like this:
- Your customs broker files the CBP entry summary (Form 7501) and the FDA prior notice simultaneously (or very close together) through ABI.
- CBP's Automated Targeting System (ATS) flags shipments for examination. The FDA's system screens the prior notice for food safety concerns.
- Most shipments are released without physical examination — this is called "release on manifest" or "automated release."
- If the FDA places a hold on the shipment, CBP will not release the goods until the FDA's hold is resolved.
- Once both CBP and FDA have cleared the shipment, CBP issues the release, and the goods can move to their US destination.
The key practical point: FDA holds delay CBP release. You cannot get your goods out of the port if the FDA has a hold, even if the customs entry is otherwise clear. This is why FDA prior notice accuracy and active facility registration are critical path items, not administrative afterthoughts.
Working with a Customs Broker
For first-time importers, a licensed US customs broker is not optional — it is practically necessary. Customs brokers:
- Prepare and file CBP entry summaries
- Handle FDA prior notice filing (confirm this is included in their scope)
- Navigate the Automated Commercial Environment (ACE) system
- Manage CBP examinations and FDA holds
- Advise on tariff classification and duty minimization
- Handle bonds (continuous or single-entry)
For European NA brands, look for a customs broker with experience in food and beverage imports, familiarity with FDA prior notice requirements, and ideally experience in the specific product category (beverages). DryAtlas's guide to importing NA beverages is a useful reference for the broader import picture.
What to Get Right on Your Commercial Invoice
The commercial invoice is the document CBP uses to assess duties and verify the entry. These are the highest-risk fields for errors:
- Product description: Must be specific and consistent with your HS code classification. "Beverages" is not enough; "Non-Alcoholic Dealcoholized Sparkling Rosé Wine, 0.0% ABV" is correct.
- Value: Must reflect the actual transaction value (what you paid, or the arm's-length price if related-party transaction). Do not understate for duty savings — this is customs fraud and carries civil and criminal penalties.
- Country of origin: Where the product was manufactured (not the shipper's country if different).
- HS code: Match the code used on the CBP Form 7501. Inconsistencies between invoice and entry filing attract scrutiny.
Written by Nick Bodkins, co-founder of Avenor, the US market-entry partner for overseas non-alcoholic beverage brands. Nick previously founded Boisson, the largest US non-alcoholic retail and e-commerce platform. Connect on LinkedIn.
Frequently asked questions
Do I pay import duty on NA beverages from the EU?
Yes. The MFN rate for non-alcoholic beverages under HTS 2202 is 0.2 cents per liter, but since 24 July 2026 goods of the EU pay a combined MFN and Section 301 duty of 10% of customs value, so an EU-origin non-alcoholic beverage now pays 10%. Duty rates change with trade policy; always verify the current rate with your customs broker at time of shipment. This is general information, not tax advice.
Is there a federal excise tax on non-alcoholic beverages?
No federal excise tax applies to sub-0.5% non-malt beverages. This is one of the most significant landed-cost advantages of the NA category vs. alcohol. Malt-based NA beer (cereal beverage) is also nontaxable under IRC §5051, but the label must state this. This is general information, not tax advice — verify with qualified counsel.
What is a customs bond and do I need one?
A customs bond is a financial guarantee required by CBP for formal entries over $2,500. It covers any duties, taxes, and fees that might be owed. Most commercial importers carry a continuous entry bond, which covers all entries for a year, rather than a single-entry bond per shipment. Your customs broker can advise on the appropriate bond structure for your import volume. The customs broker may include bond cost in their service fee or bill it separately.
What happens if CBP selects my shipment for examination?
CBP can select shipments for documentary examination (review of paperwork only) or physical examination (opening and inspecting the goods). Physical exams add time and cost — typically 3–10 business days for exam completion, plus exam fees. You cannot control whether CBP examines a shipment. You can reduce exam risk over time by maintaining a consistent import history with accurate documentation and no compliance issues.
Can I use the same HS code my European exporter uses on their export documents?
No — not automatically. The Harmonized System is internationally standardized at the 6-digit level, but the US Harmonized Tariff Schedule (HTS) uses 8- and 10-digit codes with country-specific detail beyond the international standard. The 6-digit code is consistent between your EU export documents and the US HTS, but the full 8- or 10-digit US classification may differ from your European exporter's domestic code. Always have your US customs broker classify the product under the full US HTS before filing the first entry.
Written by
Nick Bodkins
Co-founder, Avenor · New York
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