If you import anything from China into the United States, you are almost certainly dealing with Section 301 tariffs. These additional duties — layered on top of your product's regular HTS duty rate — have fundamentally changed the cost structure of importing from China since they were first imposed in 2018. Here's what you need to know as an importer in 2026.

What Is Section 301?

Section 301 of the Trade Act of 1974 gives the U.S. Trade Representative (USTR) authority to impose tariffs on imports from countries that engage in unfair trade practices. In 2018, the USTR determined that China's practices regarding technology transfer, intellectual property, and innovation were actionable under this statute. What followed was the largest tariff action in modern U.S. trade history.

The tariffs were imposed in four rounds (Lists 1 through 4), each covering different sets of HTS codes. At their peak, Section 301 tariffs covered approximately $370 billion worth of Chinese imports, with rates of 7.5% to 25% layered on top of the normal duty rate.

How Section 301 Tariffs Actually Work

This is where it gets practical — and where I've seen a lot of importers get confused. Section 301 tariffs are additional duties. They don't replace your product's regular HTS duty rate; they stack on top of it. So if your product has a regular duty rate of 5% and falls under a Section 301 list at 25%, your total duty is 30%.

The mechanism works through Chapter 99 of the HTS. When your product is classified under its regular HTS code (Chapters 1–97), you also get a secondary Chapter 99 code that represents the Section 301 tariff. Both codes appear on your customs entry, and both duty amounts are assessed.

💡 Real example: A Bluetooth speaker classified under 8518.22 (regular duty: Free) that falls under Section 301 List 3 gets an additional 25% tariff via its Chapter 99 code 9903.88.15. So a product that was duty-free before 2018 now costs 25% more at the border.

Which Products Are Affected?

The short answer: most products from China. The four lists cover a staggering range of goods, from industrial machinery and electronics to consumer products and agricultural goods. In 2024, the Biden administration conducted a statutory review and increased tariffs on several strategic sectors including electric vehicles (100%), semiconductors (50%), solar cells (50%), steel and aluminum (25%), and batteries (25%). These elevated rates took effect in phases through 2025 and 2026.

Checking whether your specific HTS code is covered requires looking at the USTR's published lists or checking the Chapter 99 cross-references in the current HTS schedule. On LookupHTS, when you look up any HTS code, the detail panel will show you if a Chapter 99 provision applies.

The Exclusion Process: A Frustrating Reality

I'll be honest — the exclusion process has been one of the most frustrating aspects of Section 301 for importers. The USTR periodically opened windows for companies to request product-specific exclusions from the tariffs. If granted, you could import that specific product from China without paying the additional Section 301 duty. The problem was that the process was slow, unpredictable, and most exclusions were temporary. Many importers invested significant time and legal fees preparing exclusion requests only to have them denied or to see previously granted exclusions expire without renewal.

As of 2026, the vast majority of product exclusions have expired. A limited number of exclusions related to medical supplies and critical manufacturing inputs remain active, but they represent a tiny fraction of overall trade. For most importers, the practical reality is that Section 301 tariffs are a permanent cost of doing business with Chinese suppliers.

Strategies Importers Are Actually Using

Over the past several years, I've watched the import community adapt to Section 301 in a few key ways. The most common strategy is supply chain diversification — shifting production from China to countries like Vietnam, India, Thailand, or Mexico that are not subject to the additional tariffs. This is easier said than done, and the transition often takes 12 to 24 months, but it has become the dominant long-term approach for importers with significant China exposure.

Another approach is duty drawback, where importers who re-export goods can recover some or all of the duties paid, including Section 301 tariffs. Foreign Trade Zones (FTZs) offer another avenue — goods can be admitted into an FTZ and re-exported without ever paying the tariff, or in some cases, manufacturers within FTZs can use "inverted tariff" advantages to reduce their overall duty burden.

Finally, some importers have explored whether their products can be legitimately reclassified under an HTS code that isn't covered by Section 301. This is a legitimate strategy when a product genuinely sits on the boundary between two codes, but it requires careful analysis and ideally a binding ruling from CBP. Reclassifying a product solely to avoid tariffs — without a genuine classification basis — is evasion and carries serious penalties.

What's Next for Section 301

Section 301 tariffs on China show no signs of going away. Both political parties have supported maintaining or increasing them, and the broader U.S.-China trade relationship remains contentious. For importers, the practical takeaway is to treat these tariffs as a permanent fixture and build them into your cost models, sourcing decisions, and pricing strategies accordingly. Hoping for a rollback is not a supply chain strategy.