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 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.
- Lists 1 and 2 (from July and August 2018) and List 3 (25% since 10 May 2019): 25%, under headings 9903.88.01, 9903.88.02 and 9903.88.03. List 4A: 7.5% since 14 February 2020, under 9903.88.15.
- Four-year review increases from 27 September 2024: 100% on electric vehicles and on syringes and needles; 50% on solar cells; 25% on EV lithium-ion batteries, battery parts, some critical minerals, steel and aluminium products, ship-to-shore cranes and face masks.
- From 1 January 2025: 50% on semiconductors, polysilicon and wafers and on medical rubber gloves; 25% on some tungsten products. From 1 January 2026: 25% on other lithium-ion batteries, natural graphite and permanent magnets; 100% on medical gloves; 50% on face masks. Most of these rates use headings 9903.91.xx.
- Exclusions: 178 product exclusions remain (164 products and 14 types of solar manufacturing equipment), claimed under 9903.88.69 or 9903.88.70. USTR extended them until 10 November 2026.
- Chinese semiconductors: a further Section 301 duty started at 0% on 23 December 2025 and rises on 23 June 2027, by an amount USTR will announce at least 30 days before.
- Since 24 July 2026, the forced-labor duty: 10% or 12.5% on goods of 60 economies, 12.5% for China on top of the list duties. Since 22 July 2026, 25% on most goods of Brazil. Both exempt goods subject to Section 232.
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.
- Steel, aluminium and copper, since 6 April 2026 (Proclamation 11021): 50% on articles made entirely or almost entirely of these metals (Annex I-A) and 25% on listed derivative products and some copper products (Annex I-B), on the full customs value. Before then, many derivatives paid duty only on the value of their metal. UK goods made with UK metal pay 25% or 15%; Russian aluminium pays 200%.
- Metals, special rates: 10% for derivatives with at least 85% US-melted or US-smelted metal (85% since 8 June 2026); 15% in total with the general rate for listed industrial, power, farm and HVAC equipment until 31 December 2027 (Annex III); and since 8 June 2026, 25% on 28 codes of mobile industrial equipment (Annex I-C), or 15% in total for the EU, Japan, South Korea, Switzerland, Taiwan, the UK and a few others.
- Cars and light trucks 25% since 3 April 2025, auto parts 25% since 3 May 2025, with deal rates such as 15% in total for the EU, Japan and South Korea. Medium and heavy trucks and their parts 25%, and buses 10%, since 1 November 2025.
- Softwood timber and lumber 10%, and upholstered wooden furniture, kitchen cabinets and vanities 25%, since 14 October 2025; the furniture and cabinet rates are due to rise on 1 January 2027.
- Certain advanced computing chips: 25% since 15 January 2026, with end-use exceptions.
- Patented medicines and their ingredients: 100%, from 31 July 2026 for companies listed in Annex III and from 29 September 2026 for all others; 15% in total for the EU, Japan, South Korea, Switzerland and Liechtenstein. Generics are not covered.
- Drones: 100% for drones over 25 kg or with thermal imaging, docking stations and critical components, and 25% for other drones of 25 kg or less, since 3 September 2026; listed components follow at 25% on 9 February 2027. Polysilicon and its derivatives get minimum import prices plus a 15% duty from 4 December 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.
- Search the code at hts.usitc.gov and read the footnotes: many point to a chapter 99 heading, such as "See 9903.88.03". Footnotes do not show every action, so check the lists as well.
- Section 301 headings: 9903.88.xx for the China lists and exclusions (U.S. note 20), mainly 9903.91.xx for the 2024–2026 increases, and 9903.05.xx and 9903.06.xx for the 2026 forced-labor and Brazil actions.
- Section 232 headings: 9903.82.xx for metals since 6 April 2026, except Russian aluminium (9903.85.67 and 9903.85.68; earlier entries used 9903.80, 9903.81, 9903.85 and 9903.78), 9903.94.xx for cars and parts, 9903.74.xx for trucks and buses, 9903.76.xx for wood products, 9903.79.xx for chips, 9903.04.xx for medicines and 9903.08.xx for drones.
- Read the product annexes: USTR's notices in the Federal Register for Section 301, and for Section 232 the proclamation annexes on whitehouse.gov and in the Federal Register, plus BIS notices on derivative products.
- Follow CBP's Cargo Systems Messaging Service (CSMS) messages and Trade Remedies pages: they give the headings, filing rules and stacking order for each change, often only days before it starts.
- When unsure, ask a licensed customs broker, search CBP rulings (CROSS) or request a binding ruling from CBP.
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:
- Steel: the country of melt and pour, where the steel was first made in liquid form and poured into its first solid shape.
- Aluminium: the primary and secondary country of smelt and the country of most recent cast. Under CBP guidance of June 2025, an unknown country, reported as "UN", brings the 200% rate set for Russian aluminium.
- Copper: the smelt and cast countries for four wire and cable codes (8544.42.10, 8544.42.20, 8544.42.90 and 8544.49.10). Since 14 September 2026, ACE rejects entries without them; "OTH" is accepted if unknown.
- Weight: a product claiming the under-15% metal rule (heading 9903.82.03) must report the total weight of the metals in kilograms.
- Reduced rates need proof of where the metal was made: UK-origin goods with UK metal (25% or 15%) and derivatives with at least 85% US metal (10%).
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.
- China: the list duty and the 12.5% forced-labor duty add up, so a List 3 product pays the general rate plus 25% plus 12.5%.
- Goods subject to Section 232 are exempt from the forced-labor and Brazil Section 301 duties, but not from the China list duties.
- Steel, aluminium and copper are charged once per product, and cars or auto parts paying the auto duty generally do not also pay the metals duty.
- Some Section 232 rates are totals, such as 15% in total with the general rate for EU or Japanese medicines and for Annex III equipment, with nothing extra if the general rate is already higher.
- Example with illustrative rates: a steel derivative product of China in Annex I-B and on List 3, general rate 3%, customs value USD 10,000. Duty 300 + Section 301 2,500 + Section 232 2,500 = USD 5,300 before fees; the forced-labor duty does not apply.
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):
- A full description, the material and the 10-digit HTSUS code agreed with the buyer.
- The country of origin, and the manufacturer's name and address.
- For goods containing steel, aluminium or copper: the weight of each metal and the product's net weight.
- The country of melt and pour for steel; the primary and secondary country of smelt and the country of most recent cast for aluminium; the smelt and cast countries for copper wire and cable.
- For a reduced rate: the share of US or UK metal, backed by mill certificates or supplier declarations.
Step by step
- Agree the 10-digit HTSUS code with your US buyer or broker (Triplicate's HS code lookup gives the 6-digit start).
- Confirm the country of origin: where the goods were last substantially transformed, not where they ship from.
- Open the code at hts.usitc.gov, note the general rate and follow any footnote to a chapter 99 heading.
- For goods of China, check the Section 301 lists, the 2024–2026 increases and whether an exclusion still applies.
- Check the forced-labor and other Section 301 rates for your country of origin, and whether your product is exempt.
- Check the Section 232 annexes and CBP guidance for metals, vehicles, wood, chips, medicines and drones.
- For metal goods, get the metal weights and the melt and pour or smelt and cast countries from your mill or supplier.
- Read recent CSMS messages and Federal Register notices for changes, then confirm the total duty with the broker.
- 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
- Commercial invoice with HTS code, country of origin, manufacturer and metal data
- Packing list with net and gross weights
- Mill test certificate or supplier declaration of melt and pour or smelt and cast countries
- Bill of materials showing the weight of steel, aluminium and copper
- Production records showing where the goods were substantially transformed
- Evidence for any reduced rate claimed: USTR exclusion, UK or US metal, partner-country origin
- CBP ruling or the broker's classification notes
- Entry summary (CBP Form 7501) showing each chapter 99 line
Common problems and how to avoid them
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.
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.
What to do: Since 6 April 2026 the duty applies to the full customs value; update quotes and landed-cost sheets.
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.
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.
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
- 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
- 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
- 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
- USTR Extends Exclusions from China Section 301 Tariffs Related to Forced Technology Transfer Investigation (November 2025) Office of the US Trade Representative
- 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
- Harmonized Tariff Schedule (HTS) information and search US International Trade Commission
- Trade Remedies US Customs and Border Protection
- Section 301 Trade Remedies Frequently Asked Questions US Customs and Border Protection
- 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
- 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.
Trade notes
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.
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