Your duty stack changed before most teams could reprice it
New Section 301 tariffs now reach most imports from 60 economies, with country rules, product exclusions, transit timing, and duty stacking to resolve.
Briefing Table
The issue in operating terms: change, impact, required action.
Exposure Matrix
Which flows move first, who owns the handoff, and what to check.
Dates / Watchlist
Dates that belong in broker, compliance, finance, and operations calendars.
Read This First
- Signal: New Section 301 tariffs of 10% or 12.5% now reach most imports from 60 economies.
- Exposure: USTR says the covered trading partners account for 99.4% of U.S. imports, although country rules and product exclusions materially narrow the final charge.
- Watch dates: The duties took effect July 24, 2026. A narrow vessel in-transit exception closes July 28. Canada-specific Section 338 tariffs are scheduled for August 19.
- First move: Recalculate open entries by country of origin, HTS classification, preference claim, exclusion status, and every other Chapter 99 duty already in the stack.
Bottom Line
This is not another tariff announcement to file for later. The new Section 301 layer is already in effect.
Goods from 60 economies now face a 10% or 12.5% tariff unless a country rule, product exclusion, trade-agreement provision, or other carveout applies. For the European Union, Taiwan, Japan, Korea, and Switzerland, the new duty is generally calculated net of the ordinary most-favored-nation rate. Qualifying USMCA goods from Canada and Mexico are exempt. Products already subject to specified Section 232 measures are also outside this action.
The operational risk is not simply missing the new rate. It is applying the headline rate without testing the exceptions—or failing to stack it with another duty that still survives.
The Clearance Brief
1. A broad Section 301 layer went live on July 24
What changed: USTR imposed additional tariffs on goods from 60 economies following investigations into whether those economies prohibit and effectively enforce bans on imports produced with forced labor.
Seventeen named economies—including Canada, India, Mexico, and the United Kingdom—generally receive a 10% rate. Most other investigated economies generally receive 12.5%. The European Union and Taiwan use a 10% total-duty threshold net of the normal MFN rate; Japan, Korea, and Switzerland use a 12.5% threshold.
Operator impact: Country of origin now changes more than the headline rate. It determines the applicable Chapter 99 heading, whether the tariff is additive or net of MFN, and whether a trade-agreement exception may remove the new duty.
What to do next: Build a country-treatment field into every landed-cost review. Do not let teams apply a single “global tariff” percentage across the supplier file.
2. The exemption analysis is an HTS exercise, not a product-description shortcut
What changed: USTR exempted extensive product lists covering selected raw materials, products with limited domestic availability, articles that could create economy-wide disruption, and other products that would not advance the stated policy objective.
The notice implements the action through new Chapter 99 headings and detailed U.S. Note 52. The applicable result depends on the ordinary HTS classification, country of origin, and the relevant exclusion heading.
Operator impact: Two commercially similar items can receive different treatment because their HTS classifications differ. A supplier statement such as “this category is exempt” is not enough support for entry.
What to do next: Match every material SKU to the annex at the tariff-line level. Preserve the classification rationale, country-of-origin support, exclusion heading, and broker instruction in the entry file.
3. USMCA eligibility now has a direct 10-point consequence
What changed: Products of Canada and Mexico entered free of duty under USMCA are exempt from their respective new Section 301 tariff headings. Non-qualifying goods remain exposed unless another exclusion applies.
Operator impact: A weak or incomplete USMCA claim can now cost more than the loss of the ordinary preferential rate. The new 10% Section 301 charge may also attach.
What to do next: Recheck certificates and origin calculations for open Canadian and Mexican orders. Prioritize high-value SKUs, products with mixed-origin inputs, and claims that depend on tariff shift, regional value content, or special Chapter 4 rules.
4. “Excluded from this action” does not mean “duty-free”
What changed: Articles subject to specified Section 232 tariff measures—including covered steel, aluminum, autos and parts, copper, wood products, heavy vehicles and parts, and semiconductors—are carved out of this new Section 301 action.
For many other goods, however, the notice states that the new tariffs apply in addition to ordinary Chapter 1–97 duties and other applicable Chapter 99 duties. Antidumping, countervailing, taxes, fees, and other charges also continue.
Operator impact: Teams face two opposite errors: stacking the new tariff onto an expressly excluded Section 232 article, or failing to stack it onto another tariff that remains applicable.
What to do next: Require a line-level duty stack showing the base rate, preference claim, new Section 301 heading, other Chapter 99 measures, AD/CVD exposure, and fees. A single blended percentage hides the legal basis and makes broker review harder.
5. The transit exception is almost closed
What changed: The new duty applies to covered goods entered for consumption—or withdrawn from warehouse for consumption—on or after 12:01 a.m. ET on July 24.
A shipment can avoid the additional duty only if it was loaded aboard a vessel at the port of loading and already in transit on its final mode before that time, then entered or withdrawn before 12:01 a.m. ET on July 28.
Operator impact: Merely being ordered, produced, exported, or moving inland before July 24 does not satisfy the published exception. The final-mode and entry deadlines both matter.
What to do next: Isolate every entry using the exception. Retain vessel loading and final-mode evidence, confirm the entry timestamp, and give the broker a written instruction identifying the applicable Chapter 99 transit provision.
6. The tariff architecture is still moving
What changed: USTR plans tariff-rate quotas for qualifying textile and apparel imports from Bangladesh, Cambodia, Indonesia, and Malaysia based on those economies’ use of U.S. cotton and textile inputs. The mechanism is intended to become feasible by September 1, but its effective date and operating details require a later Federal Register notice.
Separately, three Section 338 proclamations are scheduled to impose additional 50% tariffs on specified Canadian products beginning August 19.
Operator impact: Today’s correct landed cost may not survive the next notice. Textile, apparel, and Canada-heavy import programs face another round of country and product mapping.
What to do next: Put affected purchase orders on a dated change-control list. Assign one owner to monitor the next USTR, Federal Register, and CBP implementation notices and update broker instructions when—not before—the legal mechanics are published.
The Entry Review That Should Happen Now
Start with entries filed since July 24 and shipments expected within the next 30 days.
- Confirm origin: Identify the legally supportable country of origin, not the ship-from location.
- Confirm classification: Revalidate the Chapter 1–97 HTS code before testing an annex exclusion.
- Assign country treatment: Determine whether the economy receives 10%, 12.5%, or a net-of-MFN calculation.
- Test special carveouts: Check USMCA eligibility, specified Section 232 treatment, Chapter 98 treatment, and the product exclusion headings.
- Build the complete stack: Add every surviving Chapter 99 measure, AD/CVD duty, tax, fee, and charge.
- Document timing: If using the transit exception, retain evidence for both loading/final-mode status and the July 28 entry deadline.
- Reprice the commercial file: Update landed-cost models, customer quotes, margin approvals, purchase orders, and Incoterm responsibilities.
Dates / Watchlist
Now in effect
- July 24, 2026: The 60-economy Section 301 tariffs became applicable to covered goods entered for consumption or withdrawn from warehouse.
- July 24, 2026: Goods not already loaded and in transit on their final mode by 12:01 a.m. ET lost access to the published transit exception.
Coming up
- July 28, 2026: Covered in-transit goods must be entered for consumption or withdrawn from warehouse before 12:01 a.m. ET to use the exception.
- August 19, 2026: The three announced Section 338 actions targeting specified Canadian products are scheduled to take effect.
- September 1, 2026: USTR's target for making the Bangladesh, Cambodia, Indonesia, and Malaysia textile/apparel TRQ mechanism feasible; a later notice must establish the effective date.
Operator Checklist
- Segment open imports by country of origin and HTS classification.
- Apply the correct 10%, 12.5%, or net-of-MFN country treatment.
- Match product exclusions at the tariff-line level.
- Revalidate USMCA support for Canadian and Mexican goods.
- Separate specified Section 232 exclusions from duties that continue to stack.
- Audit every entry claiming the July 24–28 transit exception.
- Update landed-cost, quote, and margin models.
- Give brokers written Chapter 99 instructions and retain the decision record.
- Flag textile/apparel and Canada exposure for the next implementation notices.
Operator Tool - From Our Partner
When a duty stack changes this quickly, start with the tariff line. The US Tariff Rates tariff tracker helps teams inspect current tariff measures before confirming landed cost or sending entry instructions.
Read previous operator briefings in the CLEARANCE archive.
Source Stack
- White House, Actions in the Section 301 Investigations of 60 Economies Related to Forced-Labor Import Prohibitions, published July 23, 2026: https://www.whitehouse.gov/presidential-actions/2026/07/actions-by-the-united-states-in-the-investigations-under-section-301-of-the-trade-act-of-1974-of-the-acts-policies-and-practices-of-60-economies-related-to-the-failure-of-each-economy-to-impose-and/
- USTR, Final Action Federal Register Notice and HTSUS Annexes, issued July 23, 2026: https://ustr.gov/sites/default/files/files/Press/Releases/2026/FLIP%20301%20Investigation%20Final%20Action%20FRN%207-23-26%20FINAL.pdf
- USTR, Fact Sheet: Section 301 Action in Response to the Failure of 60 Economies to Ban Imports Produced with Forced Labor, checked July 27, 2026: https://ustr.gov/about/policy-offices/press-office/fact-sheets/2026/july/fact-sheet-ustr-section-301-action-response-failure-60-economies-ban-imports-produced-forced-labor
- USTR, USTR Takes Action in Forced Labor Section 301 Investigations, published July 24, 2026: https://ustr.gov/about/policy-offices/press-office/press-releases/2026/july/ustr-takes-action-forced-labor-section-301-investigations
- CBP, Forced Labor Importer Guidance, published June 9, 2026: https://www.cbp.gov/sites/default/files/2026-06/fld_importer_guidance_final_06092026_0.pdf
- White House, Fact Sheet: Additional Tariffs on Canada, published July 20, 2026: https://www.whitehouse.gov/fact-sheets/2026/07/fact-sheet-president-donald-j-trump-imposes-additional-tariffs-on-canada/
- White House, Additional Duties Addressing Canadian Dairy Discrimination, published July 20, 2026: https://www.whitehouse.gov/presidential-actions/2026/07/imposing-additional-duties-to-offset-canadian-discrimination-against-the-commerce-of-the-united-states-with-respect-to-dairy/
- Federal Register, Initiation of Section 301 Investigations Concerning Forced-Labor Import Prohibitions, published March 17, 2026: https://www.federalregister.gov/documents/2026/03/17/2026-05151/initiation-of-section-301-investigations-of-acts-policies-and-practices-of-various-economies-related
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