Liquid and Cream Skin-Washing Products for Retail Sale

Yes. CBP generally requires that the goods be in retail-ready packaging — individual consumer units with labeling — at the time of importation to qualify under 340130. Bulk liquid soap shipped in drums or totes for subsequent repackaging in the US would typically be classified under a different subheading, such as 340120 or 340290.

A liquid soap making only cleansing claims is regulated as a cosmetic under FDA jurisdiction, requiring proper ingredient labeling and no pre-market approval. If the product claims to kill germs or reduce bacteria (e.g., 'antibacterial'), FDA may treat it as an over-the-counter drug, triggering additional requirements including drug establishment registration and compliance with FDA monograph rules. Importers should review product claims carefully before entry. Classification is complex; consult a licensed customs broker or FDA's import guidance for your specific formulation.