This is the single most frequent question we receive from US supplement brands, and the answer is more straightforward than many assume.

HTS classification: Our green tea extract (non‑fermented, powdered extract from Camellia sinensis leaves) is properly coded under HTS 0902.10 (green tea in immediate packings ≤3 kg) or HTS 0902.20 (other green tea). These codes fall under Chapter 9, which has historically been excluded from the punitive Section 301 duties that hit many Chinese imports. As of April 2026, there is no additional Section 301 duty on these HTS lines.

Section 122 surcharge (IEEPA): The only new duty exposure is the 10% Section 122 surcharge implemented under the International Emergency Economic Powers Act, in effect through July 24, 2026. This 10% applies to the CIF value, on top of any standard MFN duty (which is often zero for tea extracts). If the surcharge lapses or changes after July 24, we will adjust quotes accordingly.

Landed‑cost modelling: We don’t just give you an EX‑W price. Every quote includes a detailed landed‑cost breakdown: EX‑W Hangzhou, freight (sea or air), insurance, and the exact Section 122 duty line item. We also provide post‑July 2026 scenarios showing what your cost looks like if the surcharge is extended, reduced, or removed. This lets your finance team budget with confidence across 2026‑2028.

What you can expect in our quote:  

• EX‑W USD/kg
• CIF‑US (destination port) with all charges separated
• Section 122 duty calculation at 10%
• Sensitivity table: ±5% duty rate change

If you’re building a multi‑year cost model, we can also lock in a duty‑sharing clause: if the 122 surcharge rises beyond 12.5%, we split the excess 50/50, keeping your upside capped.

Raw green tea leaf prices surged approximately 22% in the first quarter of 2026, driven by frost damage in Zhejiang and increased global demand for functional beverages. That volatility is real, but our contract design insulates you from it.

Index‑linked pricing: We tie your contract price to the China Green Tea Auction Index (published by the China Tea Marketing Association) or, for EGCG‑specific grades, to a blended raw‑leaf cost index we maintain internally. Prices are reviewed quarterly, not monthly, so you have long planning windows.

Caps and bands:  

• Maximum year‑over‑year increase: 10%.
• If the index moves down, you get the full benefit (no floor).
• A 14‑day renegotiation window opens only if the index moves beyond ±10%.

Priority allocation: For every annual contract, we reserve 20% of your forecasted volume as priority allocation. If a supply shock hits (e.g., another extreme weather event), this reserved capacity is filled first, before any spot orders. This alone saved our partners in 2025 when spot market prices spiked 35% and availability dried up.

Force majeure & alternative sourcing: Our supply chain spans three tea‑producing regions (Zhejiang, Fujian, Yunnan). If one region is impacted, we shift leaf procurement and still meet your specifications, with no price penalty beyond the index movement.

What a typical contract clause looks like:  

“Contract price per kg shall be the Base EX‑W price plus the Index Adjustment (capped at +10% YoY). In the event of a declared Supply Shock, the Buyer shall have first priority on 20% of contracted monthly volume, with any shortfall beyond that subject to mutual agreement.”

Regulatory scrutiny on botanicals has intensified dramatically in 2026. The USP monograph for green tea extract now aligns closely with EU pharmacopoeial limits, and buyers rightfully demand proof, not promises.

Heavy metal specifications (per finished extract):

Pesticide screening: We follow the EU Maximum Residue Limits (MRLs) for tea, which are stricter than USP alone. Our standard panel tests for 368 pesticides, including chlorpyrifos, acetamiprid, and glyphosate. Any detection above 0.01 mg/kg triggers a root‑cause investigation. We can also run a custom panel if your brand has a “Clean Label” or “Certified Pesticide‑Free” marketing position.

Residual solvents: Our extraction uses food‑grade ethanol and water. We test every batch for:

• Ethanol ≤ 1000 ppm (ICH Q3C)
• Ethyl acetate ≤ 500 ppm

2026 validation report: We provide a comprehensive dossier showing 12 months of third‑party mass‑balance data, including every out‑of‑specification (OOS) event, root cause, and corrective action. This is more than a COA — it’s your regulatory due diligence checklist in one PDF. If you need to show this to an FDA investigator or an EU notified body, it’s ready.

The days of accepting a factory‑only COA are over. Every batch of Blue Eyes Bio green tea extract is tested at a CNAS‑accredited ISO‑17025 laboratory (we use Intertek China and, for some EU clients, Eurofins).

What the report includes:  

• EGCG by HPLC‑UV (certified reference standard)
• Total catechins and caffeine
• Moisture, ash, particle size distribution
• Heavy metals: Pb, Cd, As, Hg, Cu
• Microbiology: TPC, yeast & mould, E. coli, Salmonella, Enterobacteriaceae
• Residual solvents (ethanol, ethyl acetate)
• Pesticide residue screen (368 compounds)

Chain‑of‑custody: Every report carries a QR code that links directly to the original lab report file, timestamped, with auditor credentials. The code also confirms the lot number, production date, and sample retention location. This makes your own QA audit — or a customer audit — a 30‑second exercise instead of a paperwork nightmare.

Your lab, your control: You can mandate a spot‑reanalysis at any EU‑based ISO‑17025 lab of your choice, once per quarter, at our cost. If the results differ by more than the method’s measurement uncertainty, we suspend further shipments until the deviation is resolved. In 2025, this clause was used once — and it turned out the client’s lab had an instrument calibration issue, not our product.

No one likes “black‑box” pricing. Our quotes are presented in three distinct line items:

1. Base EX‑W Price — the core manufacturing cost, fixed for the contract duration subject only to the index‑linked cap described earlier.
2. Index‑Linked Raw Material Surcharge — recalculated quarterly, capped at ±10% YoY.
3. Compliance & Traceability Fee — a fixed per‑kg charge that covers ISO‑17025 testing, pesticide panels, COA generation, QR traceability, and regulatory dossier updates.

What happens when costs change mid‑contract?  

• If the sum of components moves more than 8% year‑over‑year (up or down), we provide a 60‑day notice with a detailed worksheet showing the index movement and any external cost changes (e.g., new regulatory testing requirements).
• You then have a 30‑day renegotiation window. During that window, both parties can terminate the contract without penalty if no agreement is reached.
• If the change is under 8%, the original pricing holds.

This mechanism ensures that neither side absorbs a hidden shock. We’ve used this structure for three years and never had a contract dispute.

Incoterms we offer:  

• FOB Shanghai/Ningbo — for buyers who have their own freight forwarder relationships.
• CIF‑US (e.g., Los Angeles, New York) — including insurance, with duty separately itemised.
• CIF‑EU (e.g., Rotterdam, Hamburg) — same structure.
• We do not offer DDP, because we believe you should retain visibility and control over duties and customs clearing, but we provide all documentation to make it seamless.

US tariff optimisation: As mentioned in Question 1, we actively monitor Section 301 and Section 122 announcements. For high‑volume clients, we recommend EX‑W + freight + duty bundled under a CIF model, which gives you a single all‑in landed cost with duty exposure capped. We also offer a quarterly review of trade policy developments and, if applicable, we will re‑classify under alternative HTS codes where legally appropriate (e.g., 2106.90 for food preparations, if the extract is formulated).

EU carbon border adjustment (CBAM): While green tea extract itself is not currently in Phase 1 of CBAM (which covers cement, iron/steel, aluminium, fertilisers, and electricity), the EU is considering expansion to agricultural products by 2027–2028. To future‑proof your supply chain, we already calculate embedded CO₂ per tonne using a life‑cycle model that covers energy use during extraction, steam generation, and inland transport to port. You receive an annual CO₂ declaration template, compatible with the EU’s proposed format. This positions your brand as an early adopter of carbon transparency — a strong retail selling point.

Supply‑chain ethics is now a board‑level topic. Our due diligence programme is designed to meet both US C‑TPAT requirements and EU Supply Chain Due Diligence Act expectations.

Audit frequency: We perform quarterly on‑site audits of all major leaf‑supply farms and extraction facilities. Each audit uses a standardised checklist covering:

• Pesticide purchase and application records (cross‑checked with harvest dates)
• Water source testing (heavy metals, coliforms)
• Worker contracts, wage records, and age verification
• Fire safety and building integrity
• Traceability from village cooperative to processing batch

Forced‑labour zero‑tolerance: Any indicator — such as limited worker freedom of movement, retention of identity documents, or recruitment fees — results in immediate suspension of that supply source. We have a confidential reporting hotline for workers and a third‑party verification body (SGS, Bureau Veritas) that conducts unannounced spot checks annually. In 2025, this process led us to replace one sub‑supplier; full documentation of that decision was shared with all contracted clients.

2026 risk‑assessment template: Upon request, we share a PDF checklist that maps our audit findings to the Sedex Members Ethical Trade Audit (SMETA) pillars, so you can integrate it directly into your own supplier scorecard. We also welcome your own auditors — the clause is in our standard supply agreement.

We understand that “organic” and “natural” are not marketing fluff — they come with strict legal definitions in the EU (Regulation 2018/848) and US (NOP). Our production system accounts for both.

Organic certification: We maintain a separate, dedicated production line for organic green tea extract. It uses only EU‑recognised organic‑certified fresh leaves, and the final extract is certified under the EU Organic Regulation (certificate available on request). The organic batches are traceable back to the farm cooperative, and we do not use synthetic solvents in the extraction.

‘Natural’ claim support: For brands that label “natural source of antioxidants” or “naturally derived EGCG,” we provide a process‑map and affidavit confirming:

• No synthetic caffeine removal agents (e.g., methylene chloride)
• No synthetic antioxidants added
• Only water and food‑grade ethanol as extraction solvents

Low‑residual‑solvent guarantee: Our high‑purity EGCG 95% is ethanol‑de‑residualised to levels well below the pharmacopoeial limits. The typical ethyl acetate residue is below 100 ppm, and ethanol is below 500 ppm — far lower than many competitors. For clients marketing to “clean label” audiences, we can also supply supercritical CO₂‑extracted versions (available with a 4‑week lead time), though the cost is higher.

In 2026, several US states (e.g., California) are increasing enforcement on misleading “natural” claims. Our documentation gives your legal team a solid defence.

Innovation partnerships require trust and legal clarity. Our co‑development addendum has been reviewed by IP lawyers in both the UK and the US, and it balances your right to exclusivity with our ability to serve other clients.

Standard terms:  

• D‑NDA first: No technical discussions begin without a signed development NDA that covers all shared data, analytical methods, and formulation concepts.
• IP ownership: You retain full ownership of any formulation‑specific IP (e.g., a novel solid dispersion of EGCG with your carrier molecules). We retain ownership of any process‑improvement IP that is broadly applicable (e.g., a new drying method that improves solubility).
• Cross‑licence: We grant you a perpetual, royalty‑free, non‑exclusive licence to use any process‑improvement IP that we develop for your project. This means if we figure out a better way to micronise the powder during our work with you, you can use it forever without paying us extra.
• Controlled documentation: All R&D data is stored in a segregated SharePoint with access logs. Only named individuals from both sides have access, and all documents are watermarked with “Confidential — Joint Development.”

Real example: In 2025, a sports nutrition client wanted EGCG with improved cold‑water dispersibility. We jointly developed a agglomeration process. The client owns the formulation for their pre‑workout powder; we now offer the agglomerated EGCG as a standard product to other clients under a non‑exclusive basis. Both sides continue to benefit.

We understand that a first order is a test — of our product quality, our logistics, and our reliability. We make it low‑risk.

Standard first‑order terms:  

• Minimum order quantity: 200 kg (for EGCG 95%). If you need a smaller trial, we can supply a 25 kg “sample order” at a slightly higher per‑kg price, with the same full documentation.
• Payment: 30% advance payment with purchase order, 70% against scanned bill of lading copy.

12‑month forecast benefits: If you commit to a rolling 12‑month forecast (with quarterly review), we significantly improve terms:

• MOQ drops to 100 kg per shipment.
• Payment extended to 60 days net from BL date (subject to credit check).
• Quarterly volume tier‑discounts: e.g., 5 MT per quarter gets a 3% discount; 10 MT gets 5%.
• Consignment stock option: For US/EU clients ordering >1 MT/month, we can hold 4–6 weeks of safety stock at your forwarder’s warehouse, invoiced only when you draw down. This cuts your working capital needs dramatically.

All first‑time buyers also receive a free 25 g reference sample and a complete technical dossier before any payment. You test the product in your own lab, confirm it matches your requirements, and then we ship. If it doesn’t match, you pay nothing.