US-China tariffs hit 35% for most electronics in 2026. Seven criteria for vetting whether your sourcing agent can navigate the new tariff landscape.
Until 2024, choosing a China sourcing agent came down to three things: supplier network depth, quality control capability, and English fluency. Those still matter. But in 2026, with US-China tariffs stacked at roughly 35% for most electronics categories, your sourcing agent's trade compliance literacy has become equally critical — and most agents have not updated their knowledge past 2022.
This guide covers the seven criteria that now determine whether a sourcing agent will cost you money or save it, and the specific questions to ask before committing to a relationship.
For the current tariff rate structure and landed cost formula, see our China Electronics Tariffs 2026 guide. This guide assumes you already understand the landscape and focuses on how to find an agent who can navigate it.
Why tariff competence became a tier-1 criterion
Three changes in 24 months made this unavoidable.
The rate stack changed multiple times, and will change again. Section 301 tariffs (25% on most electronics components and consumer goods) are permanent and unaffected by court rulings. The Section 122 global surcharge (10%) expires around July 24, 2026 — but whether it drops to zero, gets extended, or gets replaced by something higher is genuinely uncertain as of this writing. An agent who learned tariff rates in 2023 is operating with material gaps.
De minimis is gone. The $800 per-shipment exemption that allowed duty-free sample imports was eliminated for China-origin goods on May 2, 2025. Every prototype batch, sample run, and partial shipment now requires a formal customs entry, a 10-digit HTS code, and full duty payment. This affects the development stage of every hardware project.
Classification determines margin. The difference between an HTS code classified as a finished consumer device versus an electronic subcomponent can be 15–20 percentage points of tariff rate. A single digit error can cost 10–20% in unnecessary duty on every shipment, compounded across an entire production run.
An agent who cannot engage with these specifics is not equipped for what 2026 sourcing actually requires.
7 criteria for evaluating a sourcing agent on tariff competence
1. Can they produce a full landed cost model — not just a factory quote?
This is the baseline test. A tariff-literate agent presents you with: ex-works factory price, inland China freight, export charges, ocean or air freight, HTS-specific import duty rate (MFN + Section 301 + Section 122), Merchandise Processing Fee (MPF at 0.3464%, minimum $31.67 per entry), and destination delivery.
The vast majority of agents quote the factory price and leave everything else as "your customs broker's problem." That framing made sense when total tariff load was 3–5%. At 35%, it hands off the most important number in your P&L.
Ask: "Can you send me a sample landed cost breakdown for a $50,000 PCB order using current HTS rates?" An agent who cannot produce this within 24 hours is telling you their competence level.
2. Do they understand HTS classification at 10-digit precision for your product category?
The first six digits of an HTS code are internationally standardized (the HS code). The final four digits are US-specific and are where the actual duty rate is set. An agent who quotes you 6-digit HS codes is working at half the required precision for US import calculations.
The test is simple: name your product and ask what 10-digit HTS code they would classify it under, and how they arrived at that. A competent agent either knows the answer immediately or tells you they need to verify with a licensed customs broker (acceptable) and then comes back with the answer. An agent who deflects or provides a 6-digit code is not equipped for post-2024 electronics sourcing.
For high-volume product lines or any classification you are uncertain about, the correct path is a CBP Binding Ruling (Form 177). This locks in the classification for every future shipment of that product, eliminating audit risk. A tariff-literate agent knows this option exists and can recommend when to pursue it.
3. Are their fee incentives aligned with tariff optimization?
Standard sourcing agent commission runs 3–10% of FOB order value. This creates a structural tension: first sale valuation, FOB Incoterm selection, and HTS reclassification all reduce the dollar figure the commission is calculated on. An agent charging 6% on a $100,000 order loses $600 for every $10,000 reduction in declared value they help you achieve.
This does not mean commission-based agents cannot help with tariff optimization — many operate with full transparency and genuine alignment. But it is a conflict worth surfacing directly.
Ask: "Does your fee change if we reduce the dutiable value through Incoterm optimization or first sale valuation?" A well-structured arrangement either uses a flat service fee (no conflict), or the agent commits explicitly that tariff optimization is within scope regardless of fee impact.
4. Are they monitoring Section 301 exclusions for your product category?
USTR has 178 active Section 301 exclusions at the time of writing — specific HTS codes where the 25% Section 301 tariff does not apply. These expire November 10, 2026. Some electronics subcategories qualify. On a $300,000 annual import volume, an active exclusion for your HTS code means $75,000 in saved duties per year.
An agent managing any meaningful procurement volume should be checking the Federal Register quarterly for exclusions applicable to their clients' product categories. If they have no idea what you are asking about, that is a direct answer to your competence question.
This is also a forward-looking indicator: the USTR investigation into Chinese excess manufacturing capacity opened March 2026 could produce new Section 301 determinations in early 2027. An agent tracking these developments protects you from being caught unprepared by rate changes.
5. Do they have genuine China+1 supplier relationships — and do they understand anti-circumvention enforcement?
Vietnam now manufactures a significant share of global electronics. For ITA-eligible products (smartphones, laptops, certain integrated circuits), Vietnam-origin goods face 0–3.9% tariff versus China's 35% effective rate. The cost difference is substantial enough that for some product categories, shifting 30–40% of production to Vietnam makes financial sense.
Two things to verify:
Genuine manufacturing relationships. There is a meaningful difference between a Vietnam supplier with real production capacity and a Chinese factory with a Vietnamese receiving address for relabeling. The first is a legitimate supply chain option; the second is tariff fraud.
Knowledge of the substantial transformation requirement. CBP enforces anti-circumvention rules aggressively. For goods assembled in Vietnam to qualify as Vietnam-origin, roughly 30% or more of the finished product's value must be genuinely created in Vietnam — not just assembled from Chinese parts. Violations carry a non-negotiable additional 40% penalty tariff on top of normal duties, plus seizure risk.
Any agent who says "we can route it through Vietnam" without immediately discussing substantial transformation documentation is raising a compliance flag, not offering a solution.
6. Can they coordinate with a licensed customs broker on complex matters?
A sourcing agent is not a customs broker and should not be impersonating one. The legally competent path for HTS binding rulings, anti-dumping and countervailing duty (AD/CVD) checks, duty drawback claims, and Section 301 exclusion applications is a licensed customs broker (LCB) or a freight forwarder with customs brokerage credentials.
The best sourcing agents have an established working relationship with at least one LCB and proactively involve them when your product category requires it. An agent who treats customs as entirely the importer's responsibility — with no warm handoff to a qualified broker — is a liability in 2026's compliance environment.
Ask: "If my product classification is complex or disputed, who do you bring in, and what's their license number?" An agent who cannot answer this question should not be managing electronics sourcing with 35% tariff exposure.
7. Do they provide full factory invoice transparency?
This criterion predates the tariff environment but has become more important within it. Hidden kickbacks — where an agent receives a factory margin undisclosed to the buyer — typically run 10–30% of the factory price and are invisible unless you have access to the original factory invoice.
The test: compare your agent's quoted factory price against equivalent listings on 1688.com, the Chinese domestic B2B platform where factories sell directly. A markup above 30% beyond what a reasonable service fee explains is a red flag.
Beyond the fee integrity question, this matters for tariff optimization: first sale valuation (see below) requires documented access to the actual factory-to-intermediary transaction price. An agent who conceals the factory invoice makes this technique legally unusable.
Tariff mitigation tactics your agent should know
A tariff-literate agent should be able to discuss all of these with you — not implement all of them on every order, but know when each is applicable:
First sale valuation. When goods pass through a trading company before reaching the US importer, customs duties can be calculated on the first arm's-length transaction price (manufacturer to intermediary) rather than the higher final price. On a $10 million product line, documented first sale valuation has produced 25% duty savings in practice. Requires a customs broker and full documentation chain. Feasible in roughly 50% of cases depending on supplier transparency.
FOB over CIF Incoterms. Ocean freight and insurance are excluded from dutiable value under FOB terms but included under CIF. On a $50,000 shipment with $3,000 freight, switching from CIF to FOB saves approximately $1,050 in duties at 35%. Small on any single shipment; material at annual volume.
Foreign Trade Zones. Over 190 active FTZ sites in the US allow duty deferral until goods enter US commerce, and the "inverted tariff" option lets you pay the finished-product duty rate rather than the (sometimes higher) component rate. Documented FTZ activations have produced $615,000 in annual savings for electronics manufacturers. Relevant for importers with significant annual volumes — not a day-one optimization.
HTS classification review. A professional audit of your HTS classification costs $2,000–$10,000 and often recovers its cost on a single production run. Legitimate classification changes — importing partially disassembled goods, reclassifying a product as a subcomponent rather than finished unit, or identifying a more accurate heading — are legal and common. Misclassification without genuine product basis triggers 4× duty penalties.
Section 301 exclusion monitoring. Active exclusions for specific 10-digit HTS codes eliminate Section 301 tariffs entirely. 178 exclusions expire November 10, 2026. Renewal petitions can be filed. An agent managing your long-term sourcing should be tracking this for your product category.
Red flags in agent vetting conversations
They cannot explain the tariff stack. If an agent cannot distinguish between Section 301, MFN duty, and the Section 122 surcharge, they are not current. These are not obscure terms — they are the three primary components of your landed cost.
They suggest transshipment through Vietnam without immediately raising substantial transformation. Legitimate China+1 supply chain diversification is a real option for some products. But any agent who frames Vietnam routing as a straightforward tariff reduction without discussing actual manufacturing content is either uninformed or suggesting something that carries severe penalties.
They quote only the factory price as your cost. In 2026, an agent who presents factory price as equivalent to landed cost is not doing the job the current environment requires.
They have no customs broker relationship. Standalone sourcing agents without any LCB relationship are structurally unable to handle the compliance complexity of a 35% tariff environment. This is not a nice-to-have; it is a capability gap.
They charge on order value with no transparency into the factory invoice. This is the pre-condition for hidden kickbacks, and it also makes first sale valuation legally unusable for your imports.
Questions to ask on a first call
- "What is the current effective tariff rate on [your product category] entering the US, and how did you calculate it?"
- "What 10-digit HTS code would you use for [your product], and what is the Section 301 rate for that heading?"
- "Can you walk me through the full landed cost from a factory in Shenzhen to our warehouse in New Jersey?"
- "Do you have existing supplier relationships in Vietnam or India for electronics manufacturing? How long have those relationships been active?"
- "Who is your licensed customs broker, and when would you involve them in a sourcing project?"
- "How does your fee structure interact with tariff optimization — if we reduce the dutiable value, does your fee change?"
- "Are there any active Section 301 exclusions for our product category?"
An agent who can answer all seven clearly is rare and worth paying for. An agent who deflects, hedges, or clearly does not know several answers is telling you their actual capability level before you have committed anything.
The bigger picture
The sourcing agents who thrived in 2019–2022 built their value on supplier relationships, quality control, and logistics coordination. Those capabilities still matter enormously — a factory audit caught after sampling protects you from production-stage disasters that no tariff optimization can fix.
But the tariff environment of 2026 has added a mandatory fourth capability: trade compliance literacy. An agent who excels at the first three and lacks the fourth will save you from bad factories and deliver tariffs you could have legally reduced by 10–25%. Understanding CE marking and FCC requirements is part of that literacy.
Finding an agent who covers all four is the sourcing challenge for this year. The questions in this guide are designed to help you identify who actually has that combination — and who is still operating on 2022 assumptions. For a shortlist to run these questions against, see our comparison of the leading China sourcing agents for electronics.
For importers building out the full landed cost picture before supplier selection, see our guide to importing electronics from China to the USA. For supplier verification once you have found candidates, see the factory audit checklist.
