Importing SPC & LVT Flooring
to the USA — The Complete
2026 Guide
Importing SPC and LVT flooring from China to the USA involves five compliance layers that do not exist for domestic sourcing: HTS code 3918.10.10 classification, Section 301 List 3 tariff at 25%, potential AD/CVD (antidumping and countervailing duty) scope ruling exposure, FloorScore SCS-FS-05154 and CARB 2 certification requirements, and California Proposition 65 compliance. Furthermore, the choice of entry port — Long Beach, Savannah, or Houston — has a significant impact on total landed cost for different destination states. This guide covers all five layers with the specific data Ecoflors uses when preparing shipments for US distributor programme members.
HTS Code Classification — Getting It Right Before CBP Does
Vinyl flooring from China is classified under HTS heading 3918.10 — floor coverings of plastics, whether or not self-adhesive, in rolls or tiles. The specific 10-digit subheading depends on product construction, and misclassification is the most common and most costly compliance mistake for US flooring importers. US Customs and Border Protection (CBP) actively audits Chapter 39 imports from China due to the high volume of Section 301 tariff revenue involved.
| Product type | HTS 10-digit code | Section 301 rate | Classification note |
|---|---|---|---|
| SPC Click (rigid core) | 3918.10.10.00 | 25% List 3 | Rigid PVC core with limestone composite — classified as floor coverings of plastics. The rigid core classification does not change the HTS heading. |
| Dryback LVT (glue-down) | 3918.10.10.00 | 25% List 3 | Flexible PVC core — same heading as SPC. Product description on commercial invoice must state “glue-down installation” to distinguish from self-adhesive products. |
| Loose Lay LVT | 3918.10.10.00 | 25% List 3 | Friction backing does not change classification. Classified with Dryback under same subheading. |
| Pre-attached IXPE underlay | Classified with parent product | No separate duty | Factory-attached underlays are classified with the flooring product — not subject to separate classification or duty assessment. |
| Separately imported underlay | 3921.90.19.00 | Check separately | If imported separately from flooring, underlay is classified under Chapter 39 plastics — different subheading from the flooring itself. |
Some importers attempt to classify SPC flooring under HTS Chapter 44 (wood and articles of wood) to avoid Section 301 List 3 tariffs, arguing that the EIR wood-grain surface qualifies as a wood product. CBP has issued multiple ruling letters confirming that SPC flooring with a PVC core is classified under Chapter 39 regardless of surface appearance. Misclassification under Chapter 44 triggers CBP penalty proceedings, retroactive duty assessment with interest, and potential seizure. Ecoflors provides a CBP-compliant commercial invoice with the correct HTS code and product description as standard for all US shipments.
Section 301 Tariffs — The 25% Reality and How to Manage It
China-origin vinyl flooring (HTS 3918.10) has been subject to Section 301 List 3 tariffs at 25% since September 2018. This tariff is applied on top of the standard MFN (Most Favoured Nation) duty rate of 3.9% — making the total effective tariff rate on SPC flooring from China approximately 28.9% of the CBP-declared customs value.
Ocean freight estimated for 20ft container Long Beach, divided by approximately 2,400 m² at 5mm SPC. Local drayage, customs clearance fees, and inland freight to destination warehouse not included. Ecoflors provides a complete landed cost model per shipment including all component costs.
First Sale Valuation — the most underused duty reduction strategy
First Sale Valuation is a legal CBP-approved methodology that allows US importers to declare the customs value of goods based on the first sale in the transaction chain — typically the factory price — rather than the last sale (the price from the trading company or intermediary to the US importer). For importers sourcing through a trading company or agent, First Sale can reduce the dutiable customs value by 15–25%, delivering a proportional reduction in Section 301 tariff liability.
To qualify for First Sale, the importer must demonstrate: (1) that the goods were destined for US export at the time of the first sale, (2) that the first sale price was at arm’s length, and (3) that the documentation chain from factory to buyer is complete. Ecoflors, as a direct factory supplier, provides the complete factory invoice, packing list, and supporting documentation required for First Sale claims. For importers previously sourcing through trading companies, switching to direct factory sourcing with Ecoflors eliminates the intermediary markup — delivering First Sale benefits without a separate CBP application.
USTR (Office of the United States Trade Representative) periodically grants temporary product-specific exclusions from Section 301 List 3 tariffs. Some vinyl flooring HTS subheadings have received temporary exclusions in the past. Check the USTR exclusion list at ustr.gov before each shipment — exclusions are product-specific, time-limited, and not automatically renewed. Ecoflors monitors the exclusion list and notifies active customers when a relevant exclusion applies to their product specification.
AD/CVD Scope Rulings — What Antidumping Risk Actually Means for SPC
In addition to Section 301 tariffs, certain vinyl flooring products from China are subject to antidumping (AD) and countervailing duty (CVD) orders. AD/CVD orders are separate from Section 301 tariffs and are product-specific — meaning they apply to specific HTS subheadings based on formal USITC (US International Trade Commission) determinations, not to all vinyl flooring from China.
| Product | AD/CVD order status | Ecoflors position | Action required |
|---|---|---|---|
| Multilayered Wood Flooring (MLWF) | Active AD/CVD order — high rates | Not applicable — Ecoflors products are 100% PVC/SPC, not wood composite | Confirm product is classified under Chapter 39 (not Chapter 44) on commercial invoice |
| Hardwood Plywood | Active AD/CVD order | Not applicable — no wood content in SPC or LVT products | No action required |
| SPC / LVT vinyl flooring (Chapter 39) | No active AD/CVD order as of 2026 | Not subject to AD/CVD — Section 301 tariff only | Monitor USITC for new petitions — industry associations occasionally file new AD petitions |
| WPC (Wood Plastic Composite) | Monitor — scope ruling under review | Ecoflors does not manufacture WPC — not applicable | If sourcing WPC, request scope ruling confirmation before importing |
AD/CVD scope rulings are based on product description — and ambiguous product descriptions on commercial invoices can trigger CBP scope inquiries. Always describe SPC and LVT flooring explicitly as “vinyl floor covering, PVC core, Chapter 39” on the commercial invoice. Avoid describing the product as “wood-look flooring,” “laminate flooring,” or any description that could be interpreted as wood-composite. Ecoflors provides invoice descriptions pre-cleared for CBP Chapter 39 classification.
US Certification Requirements — FloorScore, CARB 2, Prop 65, and LEED v4
The US market has three certification frameworks that are effectively mandatory for commercial and multi-family project specification — not required by CBP for import clearance, but required by specifiers, architects, and institutional buyers at the project bidding stage.
FloorScore (SCS-FS-05154) — LEED v4 and California Section 01350
FloorScore certification confirms that a flooring product meets California Section 01350 VOC emission limits — the strictest indoor air quality standard in the US. For LEED v4 EQ Credit 2 (Low-Emitting Materials), FloorScore is the primary accepted certification for resilient flooring. Any project targeting LEED certification — which includes the majority of commercial office, multi-family, healthcare, and education construction in the US — requires FloorScore. Ecoflors FloorScore certificate number: SCS-FS-05154, applicable to all SPC and LVT product lines. Verifiable on the SCS Global Services database.
CARB Phase 2 — California composite wood standard
The California Air Resources Board (CARB) Phase 2 formaldehyde standard limits emissions from composite wood products. For vinyl flooring, CARB Phase 2 compliance confirms the product does not off-gas formaldehyde above 0.05 ppm — a requirement increasingly referenced by multi-family developers in California, New York, and other states with strict IAQ requirements. All Ecoflors products carry CARB Phase 2 compliance documentation as standard.
California Proposition 65 — what it means for flooring importers
Proposition 65 (Safe Drinking Water and Toxic Enforcement Act of 1986) requires businesses to warn Californians about significant exposures to chemicals that cause cancer, birth defects, or other reproductive harm. For vinyl flooring, the primary Prop 65 chemical of concern is DEHP (di(2-ethylhexyl) phthalate) — a plasticiser used in some PVC formulations. Ecoflors uses a phthalate-free PVC formulation — DEHP, DBP, BBP, and DINP are absent from the product composition. This eliminates Prop 65 warning label requirements for Ecoflors flooring sold in California.
GREENGUARD Gold — schools and healthcare
For US school district procurement, hospital systems, and government building contracts, GREENGUARD Gold (UL) is frequently specified alongside FloorScore. Ecoflors GREENGUARD Gold certificates: 135464-420 (SPC) and 135462-420 (Dryback LVT). Both are verifiable on the UL Product iQ database and are supplied with every shipment without additional request.
| Project type | FloorScore | CARB 2 | GREENGUARD Gold | Prop 65 | Ecoflors status |
|---|---|---|---|---|---|
| LEED v4 commercial office | ✓ Required | ✓ Required (CA) | Optional | ✓ Phthalate-free | All held |
| Multi-family / BTR (CA) | ✓ Required | ✓ Required | Optional | ✓ No warning needed | All held |
| K-12 school districts | ✓ Required | ✓ Required | ✓ Required | ✓ Phthalate-free | All held |
| Healthcare / hospital | ✓ Required | ✓ Required | ✓ Required | ✓ No warning needed | All held |
| General retail / hospitality | Recommended | Recommended | Optional | ✓ No warning needed | All held |
Port of Entry — Long Beach, Savannah, or Houston?
The US has three primary container ports for China-origin flooring imports — Long Beach (LA), Savannah (GA), and Houston (TX). The correct port depends entirely on the final destination state. Importing through the wrong port adds significant inland drayage and rail costs that can eliminate the FOB price advantage of direct factory sourcing.
Default entry port for West Coast states. For Midwest and Southeast destinations, compare total cost against Savannah before defaulting to Long Beach.
Significantly lower inland freight cost for Southeast US destinations. Florida and Georgia multi-family developers frequently achieve lower total landed cost via Savannah despite longer ocean transit.
Best port for Texas, Oklahoma, and Gulf Coast destinations. Houston avoids the Long Beach congestion premium while providing shorter inland drayage to major Texas distribution centres.
Recommended Products for the US Market — By Project Type
| US project type | Recommended product | Key US specification | FOB from |
|---|---|---|---|
| Multi-family BTR (garden-style) | 5mm SPC Click · 20mil · IXPE | FloorScore SCS-FS-05154 · CARB 2 · GREENGUARD Gold · Prop 65 compliant | US$6.18/m² |
| High-rise multi-family (IIC acoustic) | 6mm SPC Click · 20mil · IXPE | △IIC 20–22 dB · FloorScore · CARB 2 · GREENGUARD Gold | US$6.35/m² |
| LEED v4 commercial office | 2.5mm Dryback · 20mil wear | Class 33/42 · FloorScore SCS-FS-05154 · CARB 2 · Phthalate-free | US$4.20/m² |
| K-12 school (CHPS / LEED) | 6mm SPC Click · 20mil · IXPE | FloorScore · CARB 2 · GREENGUARD Gold 135464-420 · Prop 65 | US$6.35/m² |
| Healthcare / hospital | 3mm Dryback · 28mil wear | GREENGUARD Gold 135462-420 · CARB 2 · FloorScore · Phthalate-free | US$5.40/m² |
| Hospitality / hotel renovation | 6mm SPC Click · 20mil | Fast install · no adhesive · same-day re-entry · FloorScore | US$6.35/m² |
| Large-volume retail (national chains) | 2mm Dryback · 12mil wear | Lowest FOB · ~7,000 m²/20ft · FloorScore · CARB 2 | US$3.80/m² |
The Complete CBP Document Checklist — What Every US Shipment Needs
Frequently Asked Questions
the Complete Compliance Pack.
CBP-compliant commercial invoice with correct HTS code, ISF data pack, FloorScore SCS-FS-05154, CARB 2 declaration, GREENGUARD Gold certificate, packing list with per-carton weight, and port routing recommendation — all included as standard. FOB from US$3.80/m² · MOQ 800 sqm / SKU · Long Beach 18–22 days · Savannah 24–28 days · Houston 24–30 days.