US vs China Tariffs: Complete Section 301 Duty Rate Comparison (2026)
Section 301 tariffs on Chinese imports are the most consequential US trade policy measure since the Smoot-Hawley Tariff Act of 1930. Since the first tranche took effect in July 2018, these additional duties have reshaped supply chains, increased landed costs by 7.5-25% across hundreds of billions of dollars in annual imports, and created a compliance environment where misclassifying a single HTS subheading can trigger six-figure CBP penalties. This guide provides a complete breakdown of Section 301 duty rates by HTS chapter and tariff list.
Section 301 Tariff Structure: The Four Lists
The USTR implemented Section 301 tariffs in four tranches, each targeting different product categories at different duty rates:
| List | Effective Date | Annual Import Value (approx.) | Additional Duty Rate | Key Product Categories |
|---|---|---|---|---|
| List 1 | July 2018 | $34B | 25% | Industrial machinery (Ch. 84), electrical equipment (Ch. 85), medical devices (Ch. 90), chemicals (Ch. 28-29) |
| List 2 | August 2018 | $16B | 25% | Plastics (Ch. 39), chemicals (Ch. 28-38), base metals (Ch. 72-76), textiles raw materials (Ch. 50-55) |
| List 3 | September 2018 (raised to 25% May 2019) | $200B | 25% | Consumer electronics, furniture (Ch. 94), apparel accessories (Ch. 62), auto parts (Ch. 87), seafood (Ch. 3) |
| List 4A | September 2019 (reduced to 7.5% Feb 2020) | $120B | 7.5% | Mobile phones (Ch. 85), laptops/tablets (Ch. 84), knit apparel (Ch. 61), footwear (Ch. 64), toys (Ch. 95) |
Duty Rates by HTS Chapter
Chapter 28-29: Inorganic and Organic Chemicals
Chemical imports from China are heavily impacted by Lists 1 and 2. Rare earth compounds (2805, 2846), pharmaceutical intermediates (2933-2942), and specialty chemicals all carry 25% Section 301 duty. This has driven significant supply chain shifts to India and Europe for API sourcing.
Chapter 39: Plastics and Articles Thereof
List 2 (25%) covers most raw polymer resins (3901-3921). List 4A (7.5%) covers finished plastic consumer products including kitchenware and packaging materials.
Chapter 61-62: Apparel and Clothing
This is one of the most impacted sectors. Woven apparel (Chapter 62) primarily falls under List 3 at 25%, while knit apparel (Chapter 61) falls under List 4A at 7.5%. The practical impact: a Chinese-origin woven dress with a 12% MFN rate pays 37% total duty (12% + 25%), while a knit sweater with the same MFN rate pays 19.5% total (12% + 7.5%). This rate differential has shifted some sourcing from woven to knit constructions where design permits.
Chapter 64: Footwear
Footwear faces some of the highest combined duty rates in the HTS. With MFN rates up to 37.5% for certain athletic footwear, adding List 4A's 7.5% Section 301 duty creates effective rates of 45% or more. Footwear is one of the categories where Section 301 exclusions have been most actively sought.
Chapter 72-73: Iron and Steel Products
Steel products from China face a triple layer of trade remedies: MFN duty (typically 0-5%) + Section 232 (25%) + Section 301 List 2 (25%) + ADD/CVD (up to 500%+ for certain products). The combined effective rate on Chinese steel can exceed 100%. This is why Chinese steel imports have dropped over 90% since 2018.
Chapter 84: Machinery and Mechanical Appliances
Chapter 84 is the most impacted by value. List 1 (25%) covers industrial robots (8479.50), machine tools (8456-8466), and pumps (8414). List 3 (25%) covers HVAC equipment (8415), engines (8407-8409), and most industrial equipment. List 4A (7.5%) covers computers (8471) and some consumer electronics.
Chapter 85: Electrical Machinery and Electronics
Electronics are split across lists: smartphones (8517.12) and routers (8517.62) are List 3 at 25%. Semiconductors (8541-8542) are ITA-eligible for duty-free MFN treatment but may still face Section 301 depending on classification. Consumer electronics like televisions (8528) and audio equipment (8518) are on List 3 at 25%.
Product Exclusions
The USTR has granted multiple rounds of Section 301 exclusions, each with specific HTS subheadings and time-limited validity. Key points:
- Exclusions are product-specific and may be company-specific or available to all importers.
- Exclusions must be claimed using Chapter 99 HTS numbers (9903.88.xx series) at the time of entry.
- Expired exclusions retroactively restore the Section 301 duty — importers must monitor the USTR exclusion calendar continuously.
- The 2024 reinstatement covered 352 previously expired exclusions, primarily in machinery, chemicals, and consumer goods.
De Minimis Rule Changes
The Section 321 de minimis threshold allows goods valued under $800 to enter duty-free. However, significant changes are underway:
- Section 301 duties on textiles and apparel are NOT exempted under de minimis — this has been CBP policy since 2018 but enforcement has intensified.
- The Biden-Harris administration proposed closing the de minimis loophole for Chinese-origin goods in September 2024, and implementation continues in 2026.
- CBP has increased targeting of Section 321 entries from Chinese e-commerce platforms, particularly for textiles, electronics, and products subject to consumer safety regulations.
- Importers relying on de minimis for Section 301 avoidance should treat this as a high-risk compliance area — CBP enforcement is escalating rapidly.
Compliance Checklist for Section 301
- Verify the correct tariff list for each imported HTS subheading — do not assume based on product category alone.
- Check Chapter 99 exclusion numbers before every entry filing.
- Maintain country-of-origin documentation that meets CBP's substantial transformation test.
- Monitor the USTR Federal Register notices for exclusion expirations and reinstatements.
- Conduct quarterly audits of the top 50-100 SKUs by import value.
- Do not rely on de minimis (Section 321) for textiles, apparel, or other Section 301-covered goods.
Disclaimer: Section 301 tariff rates and exclusions change frequently. Always verify current rates with the USTR and CBP before filing entry documents. PoliteDraft provides reference data only — not legal or trade compliance advice.
Browse Related HTS Sections
Explore tariff rates and classification guides for the sections covered in this article.
References & Official Sources
- US International Trade Commission (USITC). Harmonized Tariff Schedule — 2026 Revision 9. hts.usitc.gov
- US Customs and Border Protection (CBP). Informed Compliance Publications & ACE Entry Guidance. cbp.gov
- Office of the US Trade Representative (USTR). Section 301 Investigation & Federal Register Notices. ustr.gov
- World Trade Organization (WTO). Tariff Data & Trade Statistics. wto.org
- International Chamber of Commerce (ICC). Incoterms & Trade Finance Rules. iccwbo.org
- IRS. Form W-8BEN Instructions & Publication 515. irs.gov