China's last 178 Section 301 tariff exclusions end Nov 9, and no extension has been published

The 178 remaining exclusions from the China Section 301 tariffs expire at 11:59 pm ET on Nov 9, 2026, and as of Oct 11 the US Trade Representative has published no notice extending them.¹ Goods entered on or after Nov 10 that now claim HTS 9903.88.69 or 9903.88.70 go back to their original list rate: 25% for Lists 1 to 3 and 7.5% for List 4A. On $100,000 of List 1 to 3 goods, that is $25,000 more in duty.⁶

Treasury Secretary Scott Bessent said on Sept 23 that the US-China truce would run to Jan 10, 2027.³ Many importers read that as covering the exclusions. It doesn’t, at least on paper, and we would price first-quarter orders as if the duty returns.

What exactly expires on Nov 9?

Two groups of exclusions: 164 product-specific ones claimed under 9903.88.69 and 14 for solar manufacturing equipment under 9903.88.70.¹ USTR has renewed them in short cycles since May 2024. The current extension was published Dec 1, 2025, after the Nov 1 Trump-Xi deal.¹

USTR’s press release says the exclusions run “until November 10, 2026.”² The Federal Register text says goods must be entered before 11:59 pm on Nov 9. Both mean the same thing in practice. The entry date sets the rate, so a container that leaves Shanghai in October and is entered on Nov 10 pays the full duty.

China’s separate 12.5% forced-labor tariff under Section 301 has applied since Jul 24, 2026, and keeps applying either way.⁸

Didn’t the truce extension push the date back?

No notice says so. Bessent’s Sept 23 statement amended nothing in the Federal Register. The White House fact sheet from the Sept 24 summit covers a new Board of Trade and tariff recommendations on $30 billion of goods in each direction, with no mention of the truce, Section 301 or the exclusions.⁴

Ship fees sit on the same clock. USTR suspended its Section 301 fees on Chinese-owned, -operated and -built vessels through 11:59 pm on Nov 9.⁵ Without a new notice those return on Nov 10 too, and carriers may pass them on as surcharges.³

An extension is plausible, since the truce points that way. A purchase order built on it is a bet on a notice that hasn’t been written. If one publishes, preparing cost you little. If it doesn’t, the importers holding a backup quote keep their margin.

Is my product on the list?

Probably not if you sell home or kitchen goods. The surviving exclusions are mostly industrial and technical products.⁶

Source: USTR, 90 FR 55232; Great Lakes Customs Law summary of U.S. notes 20(vvv) and 20(www), Jun 30, 2026.^1,6

The descriptions read like engineering specs, and a compressor one rating outside the band isn’t covered.⁶ Five exclusions were re-pointed to new 10-digit statistical numbers effective Jul 1, 2026, through notices published Sept 2 and Oct 7.⁷ If you matched your product last year, match it again.

Your entries settle the question. A covered line shows 9903.88.69 or 9903.88.70 where the usual List 1 to 4A Chapter 99 code would be.⁶ Your customs broker can pull every entry that claimed either code, or you can run the ES-003 Entry Summary Line Tariff Details report in the ACE portal.¹⁰

The exclusion line, 9903.88.69, carries no Section 301 duty; from Nov 10 the same goods take their list code. Illustrative values.

How much more will I pay if I lose it?

$7,500 per $100,000 of entered value on a List 4A product, or $25,000 on a List 1 to 3 product.^1,6 The 12.5% forced-labor tariff is already in your cost and doesn’t change.⁸

Source: USTR 90 FR 55232; CBP CSMS #69326983. Section 232 steel, aluminum and wood products are exempt from the forced-labor tariff.^1,8

After Nov 10, a List 1 to 3 product from China carries 37.5 points of Section 301 duty. The same product from Vietnam or Thailand carries 12.5, and from India or Malaysia 10.⁸

• China, entered by Nov 9 with exclusion12.5%
• China, entered Nov 10 or later37.5%
• Vietnam12.5%
• Thailand12.5%
• India10%
• Malaysia10%

Forced-labor Section 301 tariff plus, for China, the original List 1 to 3 rate of 25%. Excludes MFN duty. Source: USTR Federal Register notices; rates in force since Jul 24, 2026.

What can I do before Nov 9?

The fastest move is to pull entries forward. Anything entered before the cutoff keeps the exclusion, so talk to your broker about port and entry timing this month. Inventory you bring in early costs cash and storage, which is usually cheaper than 25 points of duty.

The second move is a direct conversation with your China supplier. A 25-point swing is big enough to reopen price or payment terms, and some suppliers will split it to keep the order.

Pricing a backup factory outside China takes longer, usually one or more order cycles before quality is proven. Vietnam, Thailand, Malaysia and India all sit among the 16 economies in USTR’s open excess-capacity investigation, with no rate set for any of them, so a move lowers today’s bill without guaranteeing next year’s.⁹

Where can I get a backup factory checked before Nov 9?

Standard Trade finds and checks backup factories for importers. We look for plants that already make your product and already ship to US brands, and we confirm they are manufacturers before you pay a deposit, in China, Vietnam, Thailand, India and elsewhere. Classification and CBP filings stay with your broker.

Tell us what you need checked: info@standardtrade.ai.

Common questions

1. Will USTR extend the Section 301 exclusions past November 9, 2026?

   Nobody outside USTR knows. The truce was extended verbally to Jan 10, 2027, but as of Oct 11 no notice has moved the Nov 9 date.^1,3 Plan as if the exclusions expire and treat an extension as upside.

2. How do I know if my imports use a Section 301 exclusion?

   Your entry lines will show 9903.88.69 or 9903.88.70 instead of the usual List 1 to 4A code.⁶ Ask your broker to pull every entry from the last 12 months with either code, or run the ES-003 report in ACE.¹⁰

3. Does the 12.5% forced labor tariff stack on Section 301 for China?

   Yes. The two are separate Section 301 actions. Most Chinese goods pay the 12.5% with or without an exclusion, unless an exemption applies, such as Section 232 steel, aluminum or wood products.⁸

4. If I move production to Vietnam, do I avoid Section 301?

   You avoid the original China tariffs. Vietnamese goods still pay 12.5% under the forced-labor action, and Vietnam is in the excess-capacity investigation.^8,9

5. Can I apply for a new exclusion?

   No. USTR has not opened a new exclusion request process, and it has described the remaining exclusions as a bridge to sourcing outside China.⁶