Are You Hit by Section 301?
If your supply chain runs through China, the answer is almost certainly yes. Since 2018, the USTR has imposed additional tariffs on over $370 billion worth of Chinese goods across four rounds. These aren't your normal customs duties — they stack on top of the MFN rate.
The math is simple: MFN base rate + Section 301 = what you actually pay. Take a wooden chair (HTS 9401.71.00) — the MFN rate is Free, but Section 301 slaps on 25%. On a $10,000 FOB shipment, that's an extra $2,500 out of your pocket.
Four Lists, Different Rates
The USTR started in July 2018, and each round went broader:
List 1 — 25%, $34 billion. Industrial machinery, electronic components, auto parts. The first targeted strike at high-end manufacturing.
List 2 — 25%, $16 billion. Chemicals, plastics, semiconductors. A follow-up punch one month later.
List 3 — 10% → raised to 25%, $200 billion. This is where it got personal for most importers — furniture, apparel, kitchenware. Consumer goods were suddenly in the crosshairs. If you're a small or mid-size importer, this is probably the list that hits you.
List 4A — 15% → reduced to 7.5%, $120 billion. Smartphones, laptops, apparel, footwear. Lowered after the Phase One trade deal in 2020, but never removed.
Exclusions: Yes, but Hard to Get
The USTR occasionally grants product-specific exclusions. To qualify, you need to show:
- The product is only available from China (no alternative sources)
- The tariff would cause severe economic harm to your business
- Excluding it wouldn't hurt US strategic interests
Exclusions typically last one year and must be renewed. They're granted at the HTS code and product level, not per company. CVDar flags active exclusions on HTS detail pages — worth checking, because it could save you a lot.
Real-World Example
A client importing stainless steel sinks (HTS 7324.10) from China:
| Component | Rate | Amount | |-----------|------|--------| | MFN duty | 0% | $0 | | Section 301 (List 3) | 25% | $2,500 | | MPF (0.3464%) | 0.35% | $34.64 | | Total extra cost | ~26% | $2,534.64 |
On a $10,000 shipment, landed cost jumps by over 26%. If you don't calculate this before placing the order, your margin evaporates. Use CVDar's landed cost calculator — enter an HTS code, goods value, and destination to get an instant breakdown.
Key Takeaways
- Section 301 only applies to goods of Chinese origin. Routing through Vietnam doesn't help — CBP checks the certificate of origin.
- This tariff is additive — it doesn't replace your MFN rate, it stacks on top.
- Exclusions are product-level, not company-level, and they expire.
- Always check duties before you order, not when the goods arrive at the port.