Sep 5, 2026

Section 301 Tariffs on China in 2026: Lists, Rates, Exclusions, and How to Check Your HTS in 60 Seconds

The 25% that’s hiding in your quote

The FOB price your supplier sent you may already have a 25% Section 301 tariff buried inside it — and neither of you noticed.

Here’s the 2026 situation in one sentence: Section 301 was not cancelled. List 1, List 2 and List 3 still carry 25%; List 4A still carries 7.5%; on top of that, USTR’s 2024 four-year review added strategic-industry surcharges (EVs at 100%, semiconductors at 50%, batteries at 25%); and IEEPA — the 20%+10% add-on the Supreme Court struck down — is gone, but 301 is a completely different thing.

This article shows you how to work out, before you buy, whether your HTS code is on a 301 list — and what that does to your landed cost. Four free tools, no account, about 60 seconds per code.

What Section 301 actually is (the three things a buyer cares about)

Section 301 of the Trade Act of 1974 lets the U.S. Trade Representative investigate and respond to foreign trade practices. When a finding is upheld, CBP collects the extra duty at the port. You never see a separate invoice; it shows up as an additional rate on the entry.

Three mechanics matter for a buyer:

301 is a layer, not a replacement. Total additional duty = MFN (Column 1) rate + 301 (+7.5% to +100%) + 232 if it hits + AD/CVD if it hits. A product can be hit by more than one of these at once. Don’t let anyone tell you “we already pay 301, so no 232” — they stack.
It only bites China-origin goods. Origin is decided by CBP rules of origin, including the substantial-transformation test for goods assembled or processed in Hong Kong or elsewhere. Routing freight through a third country does not wash it.
It is product-specific, not company-specific. Whether you are hit depends on your HTS code, not on who you buy from. Two suppliers shipping from the same province can be treated completely differently if their product classifications differ.

The four lists, current rates, and Chapter 99 codes

These are the working numbers as of September 2026:

List	Effective	Rate	Chapter 99 code	Typical categories
List 1	Jul 2018	25%	9903.88.01	Machinery, aircraft parts
List 2	Aug 2018	25%	9903.88.02	Semiconductors, chemicals
List 3	Sep 2018 (10%), raised to 25% May 2019	25%	9903.88.03	Furniture, building materials, apparel
List 4A	Sep 2019	7.5%	9903.88.15	Consumer electronics, footwear, apparel
List 4B	—	Not implemented	9903.88.16	Suspended since 2019-12-18, never imposed

Note on List 4A: it was originally split across 9903.88.04–.14; the active code since the Phase One agreement is 9903.88.15.

One addition the old blog posts miss — and it is two separate things, not one. First, in September 2024 USTR introduced a new set of strategic-industry surcharges under the Section 301 investigation: EVs at 100% via 9903.91.05, semiconductors at 50% via 9903.91.06, lithium batteries at 25% via 9903.91.07–.08 (USTR 2024-09-13, 89 FR 79678). These were staged in rather than imposed all at once: the first batch (9903.91.01–.03) took effect 2024-09-27, EV 100% (9903.91.05) from 2025-01-01, and semiconductors/batteries (9903.91.06–.08) from 2026-01-01. They did not modify the legacy Lists — they are a parallel, additional duty mechanism. Second, the four-year review itself is a renewal assessment that is still pending in 2026; it has not terminated or modified any list. If your product is an EV or a battery, looking only at the List tables will understate what you actually owe.

Three timing bombs in 2026 (the ones buyers miss)

1. The second four-year review is running right now. USTR opened it on 2026-05-06. List 1’s industry-continuation window ran 2026-05-07 through 2026-07-05, and List 2’s ran 2026-06-24 through 2026-08-22 (FR 91 FR 24636). The public-comment phase opens only if continuation requests are filed. No termination decision has been issued, so the tariffs keep being collected — but a change in the second half of 2026 is entirely possible. Price quotes should carry a buffer clause, not a fixed “we locked the rate” promise.

2. The 178-item product exclusion expires 2026-11-09, 23:59 ET. During the window, qualifying products use the applicable exclusion code — 9903.88.69 for the 164 industrial products, plus 9903.88.70 for solar manufacturing equipment (per USTR FR 2025-21671, extended through 2026-11-09) — to offset the underlying list rate. After that date, the exclusion lapses and the underlying List rate snaps back automatically. If your product is on that exclusion list and you’re not watching the calendar, your 2027 landed cost jumps by the full list rate overnight.

3. IEEPA is dead. Stop double-counting it. The 20%+10% IEEPA tariffs were struck down by the Supreme Court. A lot of older blog posts and spreadsheets still add IEEPA on top of 301. Don’t. Mixed totals are worse than wrong ones — they make your quote untrustworthy.

How to check whether your HTS is hit, in 60 seconds

The manual method: take your 10-digit HTS, drop to the first 8 digits, and compare against the USTR’s Note 20 enumerations (subheadings (b), (d), (f), (s)) that describe each list. It works, but it is slow and easy to get wrong when a code sits on the boundary of two lists.

The fast method is the free Section 301 Lookup. Type in your 10-digit HTS, and it:

falls back to the 8-digit (and 6-digit) level to match the list,
returns the list number, the 9903.88.xx code, and the rate,
flags whether the code is on the 178-item exclusion (9903.88.69 for industrial products, 9903.88.70 for solar, active until 2026-11-09),
shows whether the same HTS also stacks Section 232 or AD/CVD.

Four worked examples:

HTS	Result
6204.43.00.10 (women’s synthetic-fibre dresses)	Hit — +25% (9903.88.03, List 3)
9503.00.00.90 (toys)	Hit — +7.5% (List 4A)
7208.10.00.00 (hot-rolled steel)	301 = No; Section 232 (steel, 9903.80.xx) = Yes, +50% since 2025-06-04
7207.11.00.00 (steel billets)	301 = Hit — +25% (9903.91.01, 4YR strategic); Section 232 = also +50%

One caution: 8-digit matching plus a product-description cross-check is the honest way to do this. USTR attaches some exclusions by description rather than by whole HTS chapter, so a bare code match can still miss an exclusion that applies to your specific product.

What a 301 hit does to landed cost

A 25% add-on is not “a bit more money.” Take a List 3 furniture import at CIF $10,000. MFN at 16% plus 301 at 25% is a 41% duty stack — $4,100 in duty alone, before freight, insurance, and VAT/DDP adjustments.

Do the arithmetic in the free Landed Cost Calculator, which lets you stack the 301 layer together with your Incoterm — EXW, FOB, CIF, or DDP — instead of treating them as separate problems. (It also fixes the classic mistake where an EXW quote is shown as if it were a DDP all-in price.)

And if you’re still deciding who pays the freight, the Incoterms 2020 Selector walks you through the responsibility matrix in a few questions. The wrong term doesn’t change the tariff — it just determines which of you argues about the 25% at the port of loading.

“Our supplier ships via Vietnam certificates of origin” — does 301 get bypassed?

No, and assuming it does is expensive.

The substantial-transformation rule decides origin: assembly and relabeling don’t count; the country where the last substantial processing happened does. Many “we wash it through Vietnam” arrangements have ended with CBP collecting the 301 duty from the importer plus penalties, and CBP is still actively enforcing this in 2026.

Before you get anywhere near origin planning, sanity-check the supplier’s identity. Run their USCC (the 18-digit Unified Social Credit Code) through the free USCC Validator, which verifies the checksum and decodes the registration authority and company type. A valid format does not mean the company exists — a checksum proves internal consistency, nothing more.

Exclusions: how to use them, when they expire

If your product is covered by the 178-item exclusion, you report it on a separate line using the applicable exclusion code — 9903.88.69 for industrial products, 9903.88.70 for solar manufacturing equipment — at entry, which offsets the underlying List rate. The exclusion is active until 2026-11-09, 23:59 ET, and if it is not renewed it snaps back to the full list rate.

The Section 301 Lookup result card marks the exclusion status for the code you check, and the underlying data is refreshed daily from the Federal Register API. That way you are not betting a shipment on a “pretty sure it’s still excluded” memory.

Before you sign the PO

Run this checklist and you catch most of the expensive surprises before the invoice lands:

☐ 10-digit HTS confirmed in the 301 tool — list number, Chapter 99 code, and rate
☐ Section 232 and AD/CVD sidebar checked (a code can be 301-clean and still stack 232 or AD/CVD)
☐ Exclusion confirmed as applying — and the expiry date noted (2026-11-09 for the 178-item list)
☐ Landed cost computed with the full stack, not just the 301 layer
☐ Supplier USCC validated, and SAMR status confirmed live (not revoked / not abnormal)

Bottom line: Section 301 in 2026 is alive, layered, and changing. Check the list, check the review calendar, check the exclusion expiry — and run your HTS through the tool before you sign the quote, not after the invoice lands.

FAQ

Why does the tool show “Rate pending”?

Because we never invent a number. The 9903.91.xx / 9903.92.xx strategic-industry codes sometimes lack published duty metadata in the source data we ingest. When that happens, the ChineseVerify Section 301 Lookup returns “Rate pending” rather than silently displaying 0%. A product hitting one of those codes is not tariff-free — it means the rate needs confirmation from the Federal Register before you rely on it. We would rather show you an honest blank than a wrong zero.