The new round of US Section 301 tariffs took effect on July 24, 2026. For goods originating from mainland China and Hong Kong, this can be directly understood as:Except for explicitly exempted goods, most goods imported into the United States are subject to an additional 12.5% tariff on top of the existing tariff.
It doesn't only target goods suspected of being produced using forced labor. Ordinary clothing, plastic products, electronic components, and other goods originating from mainland China or Hong Kong, and not eligible for exemption, may also be subject to the additional tariff. It's not a surcharge charged by FedEx; imports via DHL, UPS, FedEx, air freight, and sea freight are all subject to the same set of U.S. Customs rules.
The United States took this measure because the relevant economies have not established or effectively enforced import bans on goods involving forced labor. CBP stipulates that goods declared for importation for consumption, or retrieved from bonded warehouses for consumption, starting at 12:01 AM Eastern Time on July 24, will be subject to the applicable 10%, 12.5%, or differential tariff rates based on the country of origin.
Goods originating from China will be subject to an additional 12.5%.
Goods originating from Mainland China are subject to HTSUS 9903.05.31, and goods originating from Hong Kong are subject to 9903.05.43. Except for goods eligible for exemption, all goods are subject to an ad valorem tax of 12.5%.
Tariffs are determined based on the country of origin of the goods, not on the place of shipment or transshipment. Goods produced in China will not change their status as originating from China even if they are transshipped through Singapore, Mexico, or Europe.
This 12.5% is typically levied separately from the existing Most Favored Nation (MFN) tariff. Items falling under Section 232 of the U.S. Customs Tariff, as explicitly listed in Note 52(f) and HTSUS 9903.05.90, are exempt from the newly added Section 301 tariff. Eligibility must be determined according to the corresponding Chapter 99 tariff code, not solely based on the product category. Anti-dumping duties, countervailing duties, and other taxes may continue to apply.
The following three examples can be used to understand this:
- Assuming the MFN tariff rate for a Chinese-origin product is 3%, with no other surcharges and not eligible for exemption, the additional tariff would be calculated at least as 3% + 12.5% = 15.5%.
- If the same product was originally subject to the Chinese Section 301 tariff of 25%, the tariff rate may reach 3% + 25% + 12.5% = 40.5%, with other taxes and fees calculated separately;
- If the goods meet the requirements of Article 232 as listed in 9903.05.90, the additional 12.5% tariff will not be applied, but the original Article 232 tariff will still need to be paid.
The 60 economies are divided into four tax calculation methods.
| Tax calculation method | Applicable economies | illustrate |
|---|---|---|
| Additional 10% | Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago, United Kingdom | An additional 10% will be levied on top of the existing applicable tax rate, except for goods that qualify for exemption. |
| Additional 12.5% | Other economies including China, Hong Kong, Australia, Brazil, Singapore, Thailand, and Vietnam. | An additional 12.5% will be levied on top of the existing applicable tax rate, except for goods that qualify for exemption. |
| MFN and this 301 total 10% | EU member states, Taiwan | If the original Most Favored Nation (MFN) tariff rate is lower than 10%, it will be adjusted to 10%; if the original tariff rate is equal to or higher than 10%, the 301 surcharge will be 0. |
| MFN and this 301 total 12.5% | Japan, South Korea, Switzerland | If the original Most Favored Nation (MFN) tariff rate is lower than 12.51 TP3T, it will be adjusted to 12.51 TP3T; if the original tariff rate reaches or exceeds 12.51 TP3T, the current Section 301 surcharge will be 0. |
For example, the most-favored-nation (MFN) tariff rate for goods originating from the EU is 31 TP3T, while the current Section 301 tariff rate is 71 TP3T, totaling 101 TP3T. The MFN tariff rate for goods originating from Japan is 51 TP3T, while the current Section 301 tariff rate is 7.51 TP3T, totaling 12.51 TP3T.
Which goods are exempt?
CBP established general and economy-specific exemptions under HTSUS 9903.05.85 to 9903.06.21, which mainly include:
- Note 52(e) specifies goods with tariff codes and intended for pharmaceutical use;
- Civil aircraft, engines and related components that conform to HTSUS General Note 6 and fall under the tariff heading specified in Note 52(d);
- Aluminum, steel and copper products listed in Notes 52(f) and 9903.05.90, aluminum or steel derivatives, as well as designated vehicles and parts, wood products and semiconductor products;
- From July 31, 2026, the patented medicines under HTSUS 9903.04.60 to 9903.04.66;
- Humanitarian donations of supplies and information materials;
- Certain raw materials, agricultural products and other designated goods listed in U.S. Customs Tariff Notes 52(b) and 52(c);
- Goods originating from Canada and Mexico that meet the USMCA tax exemption criteria;
- Qualified textiles and garments originating from Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, or Nicaragua and imported duty-free under CAFTA-DR;
- A limited number of designated products from economies such as the EU, the UK, Switzerland, and Taiwan.
There's a point of confusion here: Section 9903.05.88 exempts civil aircraft and their parts, not "ordinary goods transported by air." Ordinary international express shipments transported by air are not automatically exempt from this Section 301 tariff.
The exemption window for goods in transit has ended.
According to Article 9903.05.85, goods that were loaded onto a vessel at the port of loading before 12:01 a.m. Eastern Time on July 24 and were en route to their final mode of transport, and that were declared for import for consumption or to be withdrawn from a bonded warehouse for consumption before 12:01 a.m. on July 28, are eligible for the in-transit exemption.
Both conditions must be met simultaneously. The deadline has expired, and goods declared or collected after this period cannot use the 9903.05.85 in-transit exemption.
Chapter 98 Not all goods are tax-free.
Goods correctly declared under HTSUS Chapter 98 are generally not subject to the newly added Section 301 tariffs, except for the following items:
- 9802.00.40, 9802.00.50, 9802.00.60: Goods that are repaired, altered, or processed abroad after being exported;
- 9802.00.80: Goods assembled overseas.
For 9802.00.40, 9802.00.50, and 9802.00.60, the 301 surcharge applies to the value of repairs, alterations, or processing; for 9802.00.80, it applies to the value of goods assembled overseas less the cost or value of the U.S.-origin products therein.
Shipments to the US require re-verification of declaration documents.
Please confirm at least four pieces of information before shipping:
- The country of origin must be accurate; the country of shipment cannot be taken as the country of origin.
- Does the product description include the product name, material, and purpose? Avoid simply writing "accessory," "sample," or "gift."
- Is the 10-digit HTSUS encoding correct?
- Whether it complies with product, trade agreement or Article 232 exemption, and whether it can provide corresponding proof.
Section 99 (301) tariff code is typically declared by the U.S. importer, customs broker, or carrier's clearance team along with the import declaration. The shipper should provide the clearance agent with accurate information regarding the country of origin, commodity code, and exemption details; do not assume that simply adding a Section 99 number to the commercial invoice entitles you to tax exemption.
The new tariffs will directly affect import taxes and landed costs. When quoting prices, freight, import duties, carrier-paid taxes and handling fees, and other customs clearance costs should be calculated separately. International express shipping costs can be obtained through...CZL shipping cost inquiryPreliminary calculations; additional fees can be viewed.International Express Surcharge Inquiry.
Official source
- USTR: Taking Section 301 Actions Against 60 Economies Related to Forced Labor
- USTR: Final Action Federal Register Pre-Release Version
- CBP CSMS #69326983: Implementation and Application Guidelines
This article updates the information on the proposal stage released by CZL Express in June. Tax rates, economy groupings, exemptions and effective dates are subject to the USTR final action and CBP implementation guidelines.