Restricted Products: A Plain-English Guide

Many imported products require more than a simple customs entry. Federal agencies maintain extensive lists of products that need permits, licenses, registrations, or specific labeling before they can enter the US. Get this wrong and the shipment is held, refused entry, or seized. This guide explains the restriction landscape in plain English.

What "restricted" means

A product is restricted when it can be imported only under specific conditions. Restrictions can be:

• Licensing: an import license or permit is required.
• Registration: the manufacturer or product must be registered with an agency.
• Notification: prior notice or arrival notice to an agency.
• Labeling: specific labels in English with required information.
• Standards compliance: meets US or international standards.
• Quota: limited quantity allowed; over-quota is prohibited.

A product is prohibited when it cannot be imported under any circumstances (counterfeit currency, certain firearms, illegal drugs, products of forced labor in certain cases).

The PGA framework

A Partner Government Agency (PGA) is any federal agency other than CBP that exercises import jurisdiction. The main PGAs:

CBP coordinates PGA review through the ACE (Automated Commercial Environment) PGA Message Set. When an entry is filed, ACE flags PGA hooks based on the HTS code, and the relevant agency reviews before release.

How to know if your product is restricted

The simplest check: look up the HTS code in the CBP PGA HTS Table. If the HTS has a flag (FD = FDA required, AS = APHIS required, etc.), the product is restricted in the sense that the PGA must approve before release.

For US importers, the LandedFees HS lookup tool surfaces all applicable PGA flags for the HTS at the point of classification, so you know upfront what permits or registrations are needed.

Common restriction categories

FDA: food, drugs, cosmetics, medical devices

• Food: facility registration, prior notice, FSVP (see Food and Beverage HS Codes: FDA and FSVP).
• Drugs: FDA registration, DSCSA serialization (see Pharma HS Codes and FDA Requirements).
• Cosmetics: MoCRA registration and listing (see Cosmetics: HS Codes + MoCRA).
• Medical devices: FDA establishment registration, device listing, premarket clearance (510(k), De Novo, PMA).

USDA APHIS: plants and animals

• Plant products: phytosanitary certificate from origin country, USDA APHIS inspection at port. Some products require import permit (PPQ Form 587 or equivalent).
• Animal products: APHIS Veterinary Services permit. Disease-area restrictions (CWD, BSE, foot-and-mouth zones).
• Wood packaging materials: must comply with ISPM 15 (heat treated or fumigated, stamped).

USDA FSIS: meat, poultry, eggs

• Origin country must be certified equivalent.
• Foreign establishment must be certified by the equivalence authority.
• Each shipment requires a foreign government health certificate.
• USDA inspection at designated import inspection establishment in the US.

EPA: pesticides and certain chemicals

• Pesticides (FIFRA-registered): must be EPA-registered for sale and use. TSCA chemicals: import certification required.
• Vehicles: must meet EPA emissions standards; EPA Form 3520-1 required.
• Engines: similar emissions certification.

FCC: radio devices

• Devices emitting radio frequency (mobile phones, Wi-Fi, Bluetooth, IoT) must have FCC equipment authorization.
• Certification: for intentional radiators (transmitters). Requires testing in an FCC-accredited lab.
• Supplier's Declaration of Conformity (SDoC): for some unintentional radiators.

DOT: vehicles and hazmat

• Vehicles: must meet Federal Motor Vehicle Safety Standards (FMVSS). NHTSA registration of importer (registered importer).
• Hazmat: classification and packaging per DOT 49 CFR. Hazmat-trained shipper. Driver/carrier qualified.

DEA: controlled substances

• Schedules I, II, III, IV, V. Each shipment requires DEA import permit (Form 357).
• Importer must be DEA-registered.

ATF: firearms, alcohol, tobacco

• Firearms: ATF Form 6 import permit required. Many models prohibited (sporting purpose test).
• Alcohol: TTB Federal Excise Tax. COLA (Certificate of Label Approval). Importer's basic permit.
• Tobacco: TTB permit. Heavy excise tax. PMTA for vape products (FDA jurisdiction).

Fish and Wildlife Service: CITES, MMPA

• Endangered species (CITES): permits in both export and import countries.
• Marine mammals (MMPA): import prohibited for most.
• Migratory birds, ivory, certain woods: specific restrictions.

OFAC: sanctions

• Goods from sanctioned countries (Cuba, North Korea, Iran, Russia in significant scope, Belarus, Venezuela in some scope) require OFAC license.
• Goods involving sanctioned persons (SDN List, Entity List) require license.
• Specially Designated Nationals (SDN): the OFAC list of persons whose property is blocked. Doing business with them is prohibited.

Worked example: importing CBD products

CBD (cannabidiol) sourced from hemp is legal in the US under the 2018 Farm Bill (delta-9 THC under 0.3 percent on dry-weight basis). But CBD products face restrictions from multiple agencies:

• FDA: CBD added to food or supplements is not currently approved by FDA. CBD topical and cosmetic products are gray area.
• DEA: hemp-derived CBD with THC < 0.3 percent is descheduled, but cannabis-derived CBD remains Schedule I.
• State law: varies widely. Some states ban CBD in food.

A CBD import:

1. Must be from registered hemp.
2. Must have certificate of analysis showing THC < 0.3 percent.
3. Must comply with USDA hemp program rules.
4. May not be sold as food, supplement, or therapeutic product without FDA premarket clearance.
5. Cosmetic CBD: MoCRA registration required.

The duty calculation is trivial (low MFN plus Section 122); the regulatory landscape is complex.

Worked example: importing wooden furniture from Vietnam

Vietnamese wooden furniture (HTS 9403.60) faces:

• APHIS: ISPM 15 compliance for wood packaging materials (pallets, crates).
• Lacey Act: declaration of wood species and country of harvest.
• CITES: if the wood includes any CITES-listed species (rosewood, certain hardwoods), permits required.
• AD/CVD: wooden bedroom furniture has an active AD order, requiring cash deposit.
• CPSIA: if intended for children, lead and phthalate testing required.

The customs broker handles the entry; specialty broker support may be needed for Lacey Act and CITES.

Self-check: am I restricted?

Quick screening questions:

1. Is the product food, drug, cosmetic, supplement, or medical device? FDA.
2. Does it contain animal or plant material? USDA APHIS or FSIS.
3. Is it a chemical, pesticide, or fuel? EPA.
4. Does it emit radio waves? FCC.
5. Is it a vehicle, vehicle part, or hazmat? DOT.
6. Is it a controlled substance or precursor? DEA.
7. Is it a firearm, explosive, alcohol, or tobacco? ATF.
8. Does it contain endangered species or wildlife? Fish and Wildlife.
9. Is the supplier on the OFAC SDN list or in a sanctioned country? OFAC.

If yes to any: restricted. Check the specific agency requirements.

How the calculator handles restrictions

The LandedFees calculator and HS lookup tool:

• Flag PGA requirements based on the HTS code.
• Check the supplier against OFAC's SDN list and BIS Entity List.
• Surface country-of-origin sanctions issues.
• Note state-level restrictions (CBD in food, certain cosmetics in California, etc.).
• Provide checklists of permit and registration steps before import.

Related guides

• Pharma HS Codes and FDA Requirements
• Cosmetics: HS Codes + MoCRA
• Food and Beverage HS Codes: FDA and FSVP
• Chemistry HS Codes: Using CAS Numbers
• What Is a Customs Broker and When Do You Need One
• 10 Most Misclassified HS Codes (and how to fix them)

Check your product against US restrictions on the HS lookup tool.