Triplicate

How to Check if Section 301 or 232 Tariffs Apply to Your Product

Section 301 and Section 232 duties are extra US tariffs added to the normal rate. Section 301 duties depend on the country of origin (China since 2018; since July 2026 also a forced-labor duty on 60 economies and a separate action on Brazil), while Section 232 duties cover listed products from every country, such as steel, aluminium, copper, cars, lumber, chips, patented medicines and drones. To check, find the 10-digit HTSUS code, look for chapter 99 headings in the HTS and the official lists, and confirm origin and metal data before you ship.

Checked against official sources: 2026-09

At a glance

Section 301 China lists25% (Lists 1–3) or 7.5% (List 4A); 25%–100% on items raised since 2024
Section 301 forced-labor dutySince 24 Jul 2026: 10% or 12.5% on 60 economies; China 12.5% on top
China 301 exclusions178 left, ending 10 Nov 2026 (headings 9903.88.69 and 9903.88.70)
Section 232 metalsSince 6 Apr 2026: 50% or 25% of full customs value; UK 25% or 15%
Low metal contentNo metals duty if the metals are under 15% of weight (not ch. 72–76)
Other Section 232 goodsCars, parts, trucks, lumber, furniture, chips, patented drugs, drones
IEEPA tariffsEnded after the 20 Feb 2026 ruling; Section 301 and 232 unaffected
Who paysThe importer of record, usually through a licensed customs broker

Section 301: China lists, 2024 increases and 2026 actions

Section 301 of the Trade Act of 1974 lets the US Trade Representative (USTR) act against another country's unfair trade practices. Its duties follow the country of origin, not the country of export, and are added to the general rate.

The China duties apply only to products of China (ISO code CN). Hong Kong goods are outside the China lists, but pay the 2026 forced-labor duty.

USTR began a second four-year review of the China lists in May 2026, and its 2025 action on Chinese ships and cargo-handling equipment is suspended for one year from 10 November 2025. Rates can change, so check before each shipment.

Section 232: products, rates and start dates

Section 232 of the Trade Expansion Act of 1962 lets the President adjust imports that the Commerce Department finds threaten national security. The duties cover the listed products from every country; lower rates apply only where a proclamation gives them, for example to the UK, the EU, Japan or South Korea.

Product lists can grow. Commerce stopped taking metals exclusion requests on 10 February 2025, and the April 2026 proclamation ended the public inclusion process for metal derivatives; Commerce and USTR now add products themselves. On 6 August 2026 the Bureau of Industry and Security (BIS) proposed 14 more product groups, such as aluminium powder, trailers and welding machine parts. Auto parts have their own inclusion windows, such as 1–14 April 2026.

How to check: HTS code, chapter 99 and the official lists

Start from the 10-digit HTSUS code that will be used on the US entry and the country of origin. The tariff line shows the general rate. The extra duties sit in chapter 99, subchapter III, and the covered codes are listed in its U.S. notes and in the annexes to each USTR notice or presidential proclamation.

Country of origin, melt and pour, smelt and cast

Section 301 duties depend on the country of origin, which CBP decides by substantial transformation: processing that turns the goods into a new article with a new name, character or use. Shipping through, repacking, relabelling or simple assembly in another country does not change origin, so Chinese goods handled that way elsewhere still pay the China duties.

Section 232 duties apply whatever the origin, but the history of the metal can change the rate, so CBP needs these details on the entry:

How the duties stack, and the IEEPA ruling

One import can owe the general rate, Section 301, Section 232, Section 201 safeguard duties and antidumping or countervailing duties together. A free trade agreement lowers only the general rate unless a notice says otherwise. CBP wants the chapter 99 lines in a set order: Section 301 first, then Section 232, then Section 201.

The 2025 IEEPA tariffs ended after the Supreme Court held on 20 February 2026 that IEEPA does not authorize tariffs, and the temporary 10% Section 122 surcharge ran from 24 February to 24 July 2026. Section 301 and 232 duties were not affected and are not refunded through CBP's CAPE tool.

Who pays, and what to put on the commercial invoice

The importer of record pays Section 301 and 232 duties to CBP, normally through a licensed customs broker, and answers for the classification, origin and metal data declared. A foreign seller pays only when it is importer of record, as on DDP terms, or when the contract says so. Rates apply on the date of entry: some notices spare goods already in transit, but the April 2026 metals change did not.

The importer can only declare what the exporter tells it, so put the facts on the documents (Triplicate's free generator makes the commercial invoice and packing list):

Step by step

  1. Agree the 10-digit HTSUS code with your US buyer or broker (Triplicate's HS code lookup gives the 6-digit start).
  2. Confirm the country of origin: where the goods were last substantially transformed, not where they ship from.
  3. Open the code at hts.usitc.gov, note the general rate and follow any footnote to a chapter 99 heading.
  4. For goods of China, check the Section 301 lists, the 2024–2026 increases and whether an exclusion still applies.
  5. Check the forced-labor and other Section 301 rates for your country of origin, and whether your product is exempt.
  6. Check the Section 232 annexes and CBP guidance for metals, vehicles, wood, chips, medicines and drones.
  7. For metal goods, get the metal weights and the melt and pour or smelt and cast countries from your mill or supplier.
  8. Read recent CSMS messages and Federal Register notices for changes, then confirm the total duty with the broker.
  9. Put the HTS code, origin and metal data on the invoice and packing list, recheck before each shipment and keep records for five years.

Documents you usually need

Common problems and how to avoid them

The supplier cannot say where the aluminium was smelted or cast.

What to do: Get the primary and secondary smelt and cast countries before shipping; under CBP guidance an unknown country ("UN") brings the 200% rate set for Russian aluminium.

Goods finished in a third country are declared as non-Chinese to avoid Section 301.

What to do: Origin changes only with substantial transformation. Keep production records and, if in doubt, ask CBP for a ruling; a wrong origin can bring back duties and penalties.

The metals duty is quoted only on the value of the steel or aluminium.

What to do: Since 6 April 2026 the duty applies to the full customs value; update quotes and landed-cost sheets.

The price relies on a Section 301 exclusion.

What to do: Check that the product matches the exclusion's exact description, and plan for its end on 10 November 2026 unless USTR extends it.

A copper wire or cable entry is rejected in ACE.

What to do: Since 14 September 2026 ACE rejects the four covered copper codes without smelt and cast countries; give them to the importer, or "OTH" if unknown.

A product falls under two Section 232 actions and is charged twice.

What to do: Check the overlap rules in CBP guidance: metals are charged once per product, and cars or parts paying the auto duty generally do not pay the metals duty.

Sources

  1. Strengthening Actions Taken To Adjust Imports of Aluminum, Steel, and Copper Into the United States (Proclamation 11021, 2 April 2026) The White House, Federal Register
  2. Notice of Modification: China's Acts, Policies and Practices Related to Technology Transfer, Intellectual Property and Innovation (four-year review, 18 September 2024) Office of the US Trade Representative, Federal Register
  3. Notice of Actions in Section 301 Investigations ... Related to the Failure of Each Economy To Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced With Forced Labor (28 July 2026) Office of the US Trade Representative, Federal Register
  4. USTR Extends Exclusions from China Section 301 Tariffs Related to Forced Technology Transfer Investigation (November 2025) Office of the US Trade Representative
  5. Request for Public Comments on the Proposed Implementation of Duties on Additional Aluminum, Steel, and Copper Derivative Articles Under Section 232 (6 August 2026) Bureau of Industry and Security, US Department of Commerce, Federal Register
  6. Harmonized Tariff Schedule (HTS) information and search US International Trade Commission
  7. Trade Remedies US Customs and Border Protection
  8. Section 301 Trade Remedies Frequently Asked Questions US Customs and Border Protection
  9. CSMS # 68855869 - GUIDANCE: Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States (5 June 2026) US Customs and Border Protection
  10. CSMS # 69711865 - Copper Additional Smelt and Cast Country Detail Error Code Update (31 August 2026) US Customs and Border Protection

Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.

Share with a colleagueWhatsAppLinkedInX

Trade notes

Had this problem? Share how you solved it

Tell us what happened and what worked. We read every message. With your permission we may add your case to this note, without your name or company.

Common questions

Do Section 301 China duties apply if Chinese goods ship from Vietnam or Mexico?

Yes, if the goods are still of Chinese origin. CBP looks at origin, not the country of export, and only processing that creates a new article with a new name, character or use changes origin. Repacking, relabelling or simple assembly does not.

My product contains some steel. Does the 50% or 25% metals duty apply?

Only if its HTS code is listed in the Section 232 annexes. For listed derivatives outside chapters 72 to 76, no metals duty is due if the steel, aluminium and copper together weigh less than 15% of the product; otherwise the rate applies to the full customs value.

Can Section 301 or 232 duties be refunded like the IEEPA duties?

No. CBP's CAPE refunds cover IEEPA duties only. Section 301 duties can be recovered through duty drawback if the goods are later exported and the drawback rules are met.

Who pays Section 301 and 232 duties, the exporter or the importer?

The importer of record pays them to CBP, usually through its customs broker. An exporter pays only if it acts as importer of record, for example on DDP terms, or agrees in the contract to share the cost.

More free tools

Triplicate is free and keeps getting better. Found it useful? Support Triplicate ♥