Trade & Compliance Insight

US vs China Tariffs: Complete Section 301 Duty Rate Comparison (2026)

By PoliteDraft Trade Compliance Team Published: 2026-07-12

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:

ListEffective DateAnnual Import Value (approx.)Additional Duty RateKey Product Categories
List 1July 2018$34B25%Industrial machinery (Ch. 84), electrical equipment (Ch. 85), medical devices (Ch. 90), chemicals (Ch. 28-29)
List 2August 2018$16B25%Plastics (Ch. 39), chemicals (Ch. 28-38), base metals (Ch. 72-76), textiles raw materials (Ch. 50-55)
List 3September 2018 (raised to 25% May 2019)$200B25%Consumer electronics, furniture (Ch. 94), apparel accessories (Ch. 62), auto parts (Ch. 87), seafood (Ch. 3)
List 4ASeptember 2019 (reduced to 7.5% Feb 2020)$120B7.5%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

  1. Verify the correct tariff list for each imported HTS subheading — do not assume based on product category alone.
  2. Check Chapter 99 exclusion numbers before every entry filing.
  3. Maintain country-of-origin documentation that meets CBP's substantial transformation test.
  4. Monitor the USTR Federal Register notices for exclusion expirations and reinstatements.
  5. Conduct quarterly audits of the top 50-100 SKUs by import value.
  6. 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.

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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