If you import any product from China, there is a high probability that it is subject to Section 301 tariffs. These additional duties, first imposed in 2018 under the Trade Act of 1974, now cover the vast majority of Chinese imports to the United States across four separate lists. The rates range from 7.5% to 25% and are assessed on top of the standard MFN duty rate for the product's HTS classification.
The practical impact is significant. A product with a 5% base duty rate and a 25% Section 301 tariff has an effective rate of 30% — before any other applicable tariffs (Section 232, AD/CVD) are added. For many importers, Section 301 tariffs have fundamentally changed the economics of sourcing from China.
This guide covers all four Section 301 lists in detail, explains how to determine whether your product is covered, shows how Section 301 tariffs stack with other duties, and outlines the strategies available to reduce your exposure.
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Download PDFWhat Are Section 301 Tariffs
Section 301 tariffs are additional ad valorem duties imposed on imports from China under Section 301 of the Trade Act of 1974. This section of the law authorizes the United States Trade Representative (USTR) to take action against foreign trade practices that are "unjustifiable" or "unreasonable" and that burden or restrict U.S. commerce.
The current Section 301 tariffs originated from a USTR investigation launched in August 2017 into China's trade practices related to technology transfer, intellectual property, and innovation. The investigation concluded that China's practices were actionable under Section 301, and the first tariffs were imposed on July 6, 2018.
Since then, the tariffs have been expanded four times through four separate lists, each covering additional Chinese imports. The tariffs are administered by USTR but collected by CBP at the time of importation. They are assessed as additional ad valorem duties on the entered value of the goods — meaning they are calculated as a percentage of the customs value (transaction value) of the imported merchandise, on top of any existing duty rate.
Section 301 tariffs apply exclusively to goods of Chinese origin. Country of origin is determined by where the goods were substantially transformed into their final form, not where they were shipped from. Simply routing Chinese goods through a third country (transshipment) does not change the country of origin and is an evasion violation subject to severe penalties under the Enforce and Protect Act (EAPA).
The Four Lists
Section 301 tariffs on Chinese imports are organized into four lists, each enacted at a different time with different product coverage and rates. Together, these lists cover approximately 10,600 HTS codes representing the majority of Chinese imports by value.
List 1: $34 Billion at 25%
List 1 was the first set of Section 301 tariffs, effective July 6, 2018. It covers 818 HTS codes with an approximate annual trade value of $34 billion at the time of implementation. The tariff rate is 25%, applied in addition to the MFN base rate.
List 1 targets primarily industrial and technology products that were at the core of the original investigation into China's intellectual property and technology transfer practices. The major product categories covered by List 1 include:
- Industrial machinery and equipment: CNC machines, industrial robots, manufacturing equipment, turbines, engines, and pumps.
- Electrical equipment: Motors, generators, transformers, power distribution equipment, and electrical switching apparatus.
- Auto parts and motor vehicle components: Engines, transmissions, braking systems, chassis parts, and body components.
- Medical devices and instruments: Surgical instruments, diagnostic equipment, orthopedic devices, and dental equipment.
- Aerospace parts: Aircraft components, satellite parts, and navigation instruments.
- Nuclear reactors and related equipment.
List 1 products are identified in the HTS by a reference to subheading 9903.88.01. If your product's HTS classification includes a footnote or additional duty reference to 9903.88.01, it is on List 1 and subject to the 25% additional tariff.
List 2: $16 Billion at 25%
List 2 was enacted on August 23, 2018, covering an additional 279 HTS codes with an approximate annual trade value of $16 billion. The tariff rate is 25%.
List 2 expanded the coverage to additional industrial and technology products, including:
- Semiconductors: Integrated circuits, diodes, transistors, and semiconductor manufacturing equipment.
- Plastics and plastic products: Polymer resins, plastic sheets, tubes, pipes, and molded products.
- Chemicals: Organic and inorganic chemicals, pharmaceutical intermediates, and specialty chemicals.
- Railway equipment: Locomotives, rolling stock, rail fixtures, and signaling equipment.
- Electronic components: Printed circuit boards, capacitors, resistors, and connectors.
- Optical and photographic equipment.
List 2 products are identified in the HTS by a reference to subheading 9903.88.02.
List 3: $200 Billion at 25%
List 3 represents the largest expansion of Section 301 tariffs. It was initially enacted on September 24, 2018, at a rate of 10%, then increased to 25% effective May 10, 2019. List 3 covers approximately 5,700 HTS codes with an annual trade value of approximately $200 billion at the time of implementation.
List 3 dramatically expanded the scope of Section 301 tariffs beyond industrial goods to include a wide range of consumer and commercial products. The major product categories include:
- Consumer electronics: Routers, modems, Bluetooth devices, speakers, headphones, and monitors.
- Furniture: Wooden furniture, metal furniture, mattresses, lighting fixtures, and home furnishing accessories.
- Auto parts (expanded): Additional automotive components not covered by Lists 1 and 2.
- Agricultural products: Processed food products, animal feed, seafood, and agricultural chemicals.
- Textiles: Fabrics, yarns, fibers, and certain textile products (though most finished apparel was excluded from List 3).
- Building materials: Steel structures, aluminum products, tile, stone, and wood products.
- Handbags, luggage, and travel goods.
- Sporting goods and fitness equipment.
- Musical instruments.
List 3 products are identified in the HTS by a reference to subheading 9903.88.03. Because of its broad coverage, List 3 is the list that affects the most importers by count. If you import from China and are not sure whether your product is covered, it is very likely on List 3.
List 4A: $120 Billion at 7.5%
List 4A was enacted on February 14, 2020, covering approximately 3,800 additional HTS codes at a rate of 7.5%. The original tariff rate was set at 15% (effective September 1, 2019) but was reduced to 7.5% as part of the Phase One trade agreement between the United States and China.
List 4A fills most of the remaining gaps, covering many consumer products that had been excluded from earlier lists. Major product categories include:
- Apparel and clothing: Knitted and woven garments, T-shirts, trousers, dresses, jackets, and outerwear.
- Footwear: Athletic shoes, casual shoes, boots, sandals, and footwear components.
- Consumer electronics (expanded): Laptops, tablets, gaming consoles, and certain smartphone components.
- Food products: Processed foods, spices, sauces, canned goods, and snack foods.
- Toys and games: Dolls, action figures, board games, puzzles, and children's toys.
- Household goods: Kitchenware, small appliances, cleaning products, and household textiles.
- Personal care products: Cosmetics, toiletries, hair care, and skin care products.
- Pet products: Pet food, leashes, toys, and accessories.
List 4A products are identified in the HTS by a reference to subheading 9903.88.15. The 7.5% rate is lower than the 25% rate on Lists 1 through 3, but it still represents a significant cost increase when stacked on top of the MFN rate — particularly for high-volume, low-margin consumer products.
List 4B: Suspended
List 4B was originally planned to cover the remaining Chinese imports not captured by Lists 1 through 4A. It was scheduled to take effect on December 15, 2019, but was indefinitely suspended as part of the Phase One trade agreement. As of 2026, List 4B has never been implemented. However, it remains a tool available to the administration and could be activated in the future.
Summary of All Section 301 Lists
| List | Effective Date | HTS Codes | Trade Value | Rate | HTS Subheading |
|---|---|---|---|---|---|
| List 1 | July 6, 2018 | 818 | $34 billion | 25% | 9903.88.01 |
| List 2 | August 23, 2018 | 279 | $16 billion | 25% | 9903.88.02 |
| List 3 | September 24, 2018 | ~5,700 | $200 billion | 25% | 9903.88.03 |
| List 4A | February 14, 2020 | ~3,800 | $120 billion | 7.5% | 9903.88.15 |
| List 4B | Suspended | — | — | — | — |
How to Check If Your Product Is on a Section 301 List
Determining whether your product is subject to Section 301 tariffs requires knowing the product's correct HTS classification. Once you have the HTS code, there are two ways to check for Section 301 applicability.
Method 1: Check the HTS Directly
Look up your product's HTS code in the Harmonized Tariff Schedule at usitc.gov. Navigate to the specific 8-digit or 10-digit subheading for your product. In the tariff schedule, look for footnotes or additional duty references that point to a subheading in the 9903.88 range:
- 9903.88.01 = List 1 (25% additional tariff)
- 9903.88.02 = List 2 (25% additional tariff)
- 9903.88.03 = List 3 (25% additional tariff)
- 9903.88.15 = List 4A (7.5% additional tariff)
The reference will typically appear as "See 9903.88.xx" in the notes column or as a secondary duty rate. If none of these references appear for your HTS code, the product is not currently subject to Section 301 tariffs when imported from China.
Method 2: Use an HTS Lookup Tool
Our HTS code lookup tool automatically identifies Section 301 applicability when you search for a product's classification. The tool will show the base MFN rate, the applicable Section 301 list (if any), and the combined effective rate for Chinese-origin goods.
Important Classification Considerations
Section 301 tariffs are assessed based on the 8-digit HTS code. Two products that fall under the same 6-digit heading but different 8-digit subheadings may have different Section 301 treatment — one may be on a list while the other is not. This is why precise HTS classification matters. An error in classification can mean either paying Section 301 tariffs that do not actually apply to your product, or failing to pay tariffs that do apply (with attendant penalties and interest).
If you are unsure of your product's correct HTS classification, or if you believe your product may be classified under a code that incorrectly triggers or avoids Section 301 tariffs, have a licensed customs broker review the classification. The cost of a classification review is minimal compared to the cost of paying incorrect duty rates over multiple shipments.
How Section 301 Stacks with Other Tariffs
Section 301 tariffs do not replace other duties — they stack on top of them. When importing from China, the total duty rate on your product is the sum of the MFN base rate plus the applicable Section 301 rate, plus any other applicable special tariffs. Understanding this stacking is critical to calculating your true landed cost.
The following table illustrates how tariffs stack for common product categories imported from China:
| Product Category | MFN Base Rate | Section 301 | Other Tariffs | Effective Rate |
|---|---|---|---|---|
| Knitted apparel (Ch. 61) | 16.6% | 7.5% (List 4A) | — | 24.1% |
| Furniture, wooden (Ch. 94) | 0% | 25% (List 3) | AD/CVD (varies) | 25%+ (before AD/CVD) |
| Auto parts (Ch. 87) | 2.5% | 25% (List 1) | — | 27.5% |
| Steel kitchenware (Ch. 73) | 3.4% | 25% (List 3) | 25% Sec. 232 | 53.4% |
| Consumer electronics (Ch. 85) | 0% | 25% (List 3) | — | 25% |
| Footwear, athletic (Ch. 64) | 20% | 7.5% (List 4A) | — | 27.5% |
Note: Rates shown are representative examples. Actual rates depend on the specific 10-digit HTS code. Merchandise Processing Fee (0.3464% of value, min $31.67, max $614.35) and Harbor Maintenance Fee (0.125% of value for ocean shipments) apply in addition to these rates.
The stacking effect is most severe for products that are subject to Section 301 plus Section 232 (steel and aluminum products), or Section 301 plus AD/CVD orders. In these cases, the combined effective rate can exceed 50%, 75%, or even 100% of the product's customs value. For a detailed breakdown of tariff stacking across product categories, see our tariff stacking guide.
Exclusions and Exemptions
Since the Section 301 tariffs were first imposed, USTR has periodically granted product-specific exclusions that temporarily remove certain HTS codes from the tariff lists. Understanding the exclusion process is important for importers looking to reduce their Section 301 exposure.
How Exclusions Work
USTR opens exclusion request windows through Federal Register notices. During these windows, any interested party can submit a request to exclude a specific product (defined by HTS code and product description) from a Section 301 list. Exclusion requests must demonstrate that the product is not available from sources outside China, that the tariff causes severe economic harm to the requester, and that excluding the product would not undermine the objectives of the Section 301 action.
USTR reviews each request individually and publishes decisions in the Federal Register. Approved exclusions are retroactive to the date the relevant tariff list took effect, meaning importers can file for refunds on duties previously paid on excluded products.
Exclusion Status as of 2026
The exclusion landscape has shifted significantly since the program began. USTR granted thousands of product-specific exclusions in 2019 and 2020, providing significant relief for many importers. However, the majority of those exclusions expired in 2020 and 2021, and most were not renewed. Subsequent exclusion windows have been narrower in scope, and approval rates have declined.
As of 2026, relatively few active exclusions remain in effect. USTR continues to review the exclusion program and may open additional windows in the future, but importers should not plan their supply chain strategy around the expectation of receiving an exclusion. The safest approach is to assume the tariff will apply and pursue other mitigation strategies.
Checking for Active Exclusions
Active exclusions are published in the Federal Register and tracked by USTR. To determine whether your specific product has a current exclusion, check the most recent Federal Register notices related to Section 301 exclusions, review the USTR website's Section 301 page for updated exclusion lists, or consult with a customs broker who monitors exclusion activity.
How to Reduce Section 301 Exposure
While Section 301 tariffs cannot be avoided on legitimate Chinese-origin imports, several strategies can reduce their impact on your total landed cost and competitive position.
Tariff Engineering
Tariff engineering involves modifying a product's design, composition, or configuration so that it legitimately classifies under a different HTS code — ideally one that is not on a Section 301 list, or one that is on a lower-rate list. This is a legal strategy, but it must be done carefully. The product modification must be genuine and must result in a legitimately different classification. Simply relabeling or repackaging a product without changing its essential character is not tariff engineering — it is fraud.
Examples of legitimate tariff engineering include changing the material composition of a product (e.g., replacing steel with aluminum or vice versa to change the HTS chapter), modifying the product's intended use or functionality to shift its classification, or altering the product's form (e.g., importing a product as a set of components rather than a finished good, if the components classify differently).
First Sale Valuation
If your supply chain involves a middleman (such as a trading company that buys from the manufacturer and sells to you), you may be eligible to use "first sale" valuation. Under this method, duties are assessed on the price the middleman paid the manufacturer (the first sale), rather than the price you paid the middleman (the second sale). This reduces the customs value on which all duties — including Section 301 tariffs — are calculated.
First sale valuation requires specific documentation proving that the first sale is a bona fide arm's-length transaction. The documentation requirements include purchase orders, invoices, payment records, and evidence that the first sale was for exportation to the United States. Your customs broker should evaluate whether your supply chain qualifies.
Foreign Trade Zones
Operating within a Foreign Trade Zone (FTZ) can provide duty deferral benefits — you do not pay duties until goods leave the FTZ and enter U.S. commerce. An FTZ can also provide "inverted tariff" benefits if the finished product classifies under a lower duty rate than its imported components. However, FTZs do not eliminate Section 301 tariffs. If goods of Chinese origin enter U.S. commerce from an FTZ, Section 301 tariffs still apply. The primary benefit of an FTZ for Section 301 purposes is duty deferral (improving cash flow) and duty elimination on goods that are re-exported without entering U.S. commerce.
Duty Drawback
If you import goods from China and subsequently export them (either in the same condition or after further processing), you may be eligible for duty drawback — a refund of up to 99% of the duties paid, including Section 301 tariffs. Duty drawback also applies to "substitution" drawback, where you import goods from China (paying Section 301 tariffs), use or sell those goods domestically, and export commercially interchangeable goods that you sourced from another origin.
Drawback claims must be filed within five years of the date of importation and require meticulous recordkeeping. The potential savings are substantial for importers who also export, but the administrative burden is significant. A customs broker experienced in drawback can evaluate your eligibility and manage the filing process.
Supplier Diversification
The most direct way to reduce Section 301 exposure is to source products from countries other than China. Since Section 301 tariffs apply only to Chinese-origin goods, products manufactured in Vietnam, India, Bangladesh, Mexico, or other countries are not subject to these additional duties. However, supplier diversification involves trade-offs: different countries have different manufacturing capabilities, quality standards, lead times, and base duty rates.
CBP also closely scrutinizes imports from countries that are common transshipment points for Chinese goods. If goods are manufactured in China and merely shipped through or minimally processed in a third country, CBP will classify them as Chinese origin and assess Section 301 tariffs, plus penalties for evasion. Any supplier diversification strategy must involve genuine manufacturing in the alternative country. For a detailed analysis of China sourcing alternatives, see our dedicated guide. DTC brands specifically should review our China tariffs for DTC brands guide.
Recent Developments
Section 301 trade actions continue to evolve. Several developments in 2025 and 2026 are relevant to importers of Chinese goods.
New Section 301 Investigations
In March 2026, USTR launched 76 new Section 301 investigations targeting trade practices across multiple countries and sectors. While these investigations are separate from the existing China Section 301 tariffs, they signal an expansion of Section 301 as a trade policy tool and could result in additional tariffs on imports from other countries in the future.
USTR Review of Existing Tariffs
USTR is required to review existing Section 301 actions periodically. The statutory four-year review of the China tariffs has resulted in modifications to certain tariff rates, particularly for products deemed strategic to U.S. industrial policy. In 2024, USTR increased Section 301 rates on several product categories including electric vehicles (to 100%), lithium-ion batteries (to 25%), solar cells (to 50%), semiconductors (to 50%), and certain steel and aluminum products (to 25%). Additional rate increases on other product categories are phased in through 2026.
Potential Expansion
The use of Section 301 investigations against additional countries signals that Section 301 tariffs may no longer be a China-specific phenomenon. Importers who diversified sourcing from China to other countries to avoid Section 301 tariffs should monitor these investigations, as the same tariff mechanism could be applied to their alternative sourcing countries. The trade policy environment remains volatile, and supply chain decisions should account for the risk of tariff changes affecting multiple origin countries.
Frequently Asked Questions
What is the Section 301 tariff rate?
There is no single Section 301 tariff rate. The rate depends on which list your product falls under. List 1 products face a 25% additional tariff. List 2 products face a 25% additional tariff. List 3 products face a 25% additional tariff. List 4A products face a 7.5% additional tariff. These rates are applied on top of the existing MFN (most favored nation) base duty rate for the product's HTS code. For example, a product with a 5% MFN rate on List 3 has an effective rate of 30% (5% base + 25% Section 301). Some product categories, such as electric vehicles, batteries, semiconductors, and solar cells, face even higher Section 301 rates of 50% to 100%.
How do I know if my product has Section 301 tariffs?
Look up your product's 8-digit or 10-digit HTS code in the Harmonized Tariff Schedule at usitc.gov. In the "General" duty rate column or the footnotes, look for a reference to a subheading in the 9903.88 range. Specifically: 9903.88.01 means your product is on List 1 (25%), 9903.88.02 means List 2 (25%), 9903.88.03 means List 3 (25%), and 9903.88.15 means List 4A (7.5%). If none of these subheadings appear in the notes for your HTS code, your product is not currently subject to Section 301 tariffs. You can also use our HTS lookup tool to check your product's classification and any applicable Section 301 tariffs.
Can I get a Section 301 exclusion?
USTR has historically granted product-specific exclusions for certain HTS codes, but exclusion availability has varied significantly over time. Many exclusions that were granted in 2019–2020 expired and were not renewed. As of 2026, USTR periodically opens exclusion request windows, but approvals have become increasingly rare. To apply for an exclusion, you must submit a detailed request through the USTR's Federal Register process during an open window, demonstrating that the product is not available from non-Chinese sources and that the tariff causes severe economic harm. Consult current Federal Register notices for the status of any active exclusion processes.
Do Section 301 tariffs apply to goods from Mexico?
No. Section 301 tariffs apply specifically to goods of Chinese origin. Products manufactured in Mexico, Canada, Vietnam, India, or any other country are not subject to Section 301 tariffs. However, CBP actively investigates transshipment — the practice of routing Chinese goods through a third country to avoid Section 301 tariffs. If goods originate in China but are shipped through Mexico with minimal or no further processing, CBP will classify them as Chinese origin and assess Section 301 tariffs, plus potential penalties for evasion under the Enforce and Protect Act (EAPA).
Are Section 301 tariffs permanent?
Section 301 tariffs are not permanent by statute, but they have no automatic expiration date. The Trade Act of 1974 requires USTR to review Section 301 actions periodically, and the tariffs remain in effect until USTR determines they should be modified or terminated. The original Section 301 tariffs on Chinese goods have been in place since 2018, have been expanded multiple times, and show no signs of being reduced. Any modification would require a formal USTR review process, which can be initiated by the administration or through public petition. Businesses should plan as if Section 301 tariffs are a long-term cost factor in their China sourcing decisions.
This guide reflects Section 301 tariff rates and trade policy as of April 2026. Tariff rates, list coverage, exclusions, and trade policy are subject to change through executive action and USTR review processes. Specific duty rates should be verified against the current Harmonized Tariff Schedule at usitc.gov. Consult with a licensed customs broker for product-specific rate determinations.