2026 Tariff Stacking Checklist

Updated April 2026

Every active tariff layer a U.S. importer must check before filing — and how the stack is calculated.

Why this matters

U.S. importers in 2026 are working under the most layered tariff stack since the 1930s. A single shipment can carry the standard MFN base duty, Section 301 (China), Section 232 (steel/aluminum), IEEPA action duties, antidumping (AD), countervailing duties (CVD), the Merchandise Processing Fee (MPF), and Harbor Maintenance Fee (HMF). Missing one layer is the difference between a profitable line and a returned check.

This checklist runs through every layer in the order CBP applies it. Use it before every filing — or hand it to your broker and ask which layers they've verified.

The seven layers, in order of application

Pre-filing checklist

1. HTS classification

• Confirm the 10-digit HTS code at the time of filing (HTS is updated mid-year).
• Re-verify with the General Rules of Interpretation (GRIs) — not the prior shipment.
• Cross-check Chapter 98 / 99 special provisions (MTB, GSP, IPR, etc.).
• Pull the MFN base rate from the General column for the country of origin.

2. Country of origin

• Apply the substantial-transformation test — assembly alone is not enough.
• For USMCA: verify rules of origin (tariff shift OR RVC) on the certification of origin.
• Reject transshipment routings — Vietnam/Mexico/Cambodia origin must be substantiated.
• Document with mill certs, BoM, manufacturer affidavit, and production records.

3. Section 301 (China) check

• Run the HTS through Lists 1, 2, 3, and 4A to find the additional Chapter 99 line.
• Add the Chapter 99 line (e.g., 9903.88.03) to the entry alongside the base HTS.
• Check active exclusions — most expired Dec 31, 2025; verify any extension orders.
• Apply 25% (Lists 1–3) or 7.5% (List 4A) on entered value.

4. Section 232 (steel & aluminum) check

• Confirm if the HTS is on the active Section 232 product list.
• Check derivative steel/aluminum coverage — many finished goods now in scope.
• Apply 25% (steel) or 10% (aluminum) on the value of the steel/aluminum content.
• For melted-and-poured certifications, attach mill certs to the entry packet.

5. IEEPA action duties

• Check the most recent EO action list for the country of origin and HTS.
• Apply the country-specific rate (10–145% range as of April 2026).
• Review recent USTR/Treasury notices — IEEPA rates can change with 7 days notice.
• Use the Chapter 99 subheading specified in the EO for the entry line.

6. AD/CVD scope

• Search the Commerce Department's ACCESS portal by HTS and country.
• Match the producer to the order — rates are per-producer, not per-country.
• Pull the cash deposit rate effective on date of entry, not order date.
• Post deposit at entry; final liquidation may be 12–24 months later.
• Watch EAPA evasion findings — transshipment penalty is assessment + interest + 100% penalty.

7. Fees

• MPF: 0.3464% on formal entry value (min $32.71 / max $634.62 per entry, 2026 cap).
• HMF: 0.125% on ocean cargo at U.S. ports.
• Cotton fee, sugar fee, beef fee — check by commodity.
• PGA processing fees — FDA, EPA, USDA, FCC, etc., where applicable.

Worked example — apparel from China, $50,000 entered value

The same shipment classified one chapter off, or with origin mis-stated, can shift this number by $5,000–$30,000.

Where importers lose money

• Mis-classification. One HTS digit can move a line from 0% to 32% MFN — and on or off a Section 301 list.
• Stale HTS codes. The HTS is updated each January and July. Brokers reusing prior filings miss new lines.
• Origin shortcuts. "Made in Vietnam" without substantial-transformation evidence triggers EAPA.
• Missed exclusions. Most Section 301 exclusions expired Dec 31, 2025 — but a handful were extended. Check before filing.
• Wrong AD/CVD producer. Same HTS, different producer = different cash deposit rate, sometimes by 200%+.