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178 China Section 301 exclusions expire Nov 10 unless USTR extends

FreightFigures (16 Sep 2026) notes all 178 remaining China Section 301 product exclusions (164 product-specific plus 14 solar-manufacturing equipment lines) expire at 11:59 p.m. ET on 9 Nov 2026. Entries or bonded withdrawals for consumption on or after 10 Nov lose heading 9903.88.69 and face the underlying list rates again (25% on Lists 1-3, 7.5% on List 4A) unless USTR acts. As of mid-September, no Federal Register comment request matching prior extension cycles had appeared.

FreightFigures published an eight-week importer playbook on 16 September 2026 for the quietest large tariff clock of Q4: the 178 China Section 301 exclusions that currently suppress duties via secondary HTS heading 9903.88.69. USTR last extended them on 1 December 2025 (FR Doc 2025-21671) through 11:59 p.m. ET on 9 November 2026. Absent a further extension, any China-origin entry (including withdrawal from warehouse for consumption) on or after 10 November pays the underlying list rate again: 25% on Lists 1, 2 and 3, and 7.5% on List 4A.

The 178 lines are 164 product-specific exclusions plus 14 for solar-manufacturing equipment. Exposure is concentrated in industrial inputs and capital equipment (pumps, motors, specialty chemicals, wear parts, some medical consumables, and solar tooling). Consumer goods already paying List 4A 7.5% see a smaller absolute change. FreightFigures notes that as of 16 September it could not find a Federal Register comment request comparable to the one that preceded the last extension cycle, which is the usual leading indicator.

Bonded warehouse behavior reverses versus many 2026 tariff deadlines. Duty is assessed on the withdrawal-for-consumption date, so goods still in bond on 10 November lose the exclusion when withdrawn. The first-order move for covered inventory already in bond is to withdraw before the deadline. Bonding remains useful for arrivals after 10 November if you want to wait for a possible late or retroactive extension (as happened after the prior expiry) or to re-export without ever paying the 301 layer.

Source: FreightFigures

Topics

  • tariffs
  • section-301
  • exclusions
  • customs
  • procurement
  • usa

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