Section 301 Tariff Exclusions End in November 2026: What US Importers Should Do Now

If some of your China-origin goods enter under a Section 301 tariff exclusion, that exclusion has about a month left. When it ends, the China 301 duty for the product's list comes back on top of everything you pay today. This note sets out what the primary text says, what changes in your landed cost, and what to do before the date.

Last checked: 8 October 2026. This is commercial guidance, not legal or customs advice. Merillgrove does not classify goods; your licensed customs broker confirms the line and the rate.

In Short

• USTR extended 178 exclusions: 164 under HTSUS heading 9903.88.69 and 14 for solar manufacturing equipment under 9903.88.70.
• The operative text ends them for goods entered before 11:59 p.m. on 9 November 2026. The press release says "until November 10". Plan on 9 November.
• The date that counts is entry for consumption, or withdrawal from a bonded warehouse, not shipment.
• After that, the China 301 rate for the product's list applies again: 25% for Lists 1 to 3 headings, 7.5% for List 4A.
• As of today we found no notice of a further extension, and the underlying China 301 actions have been formally continued.

9 November, Not 10: The Primary Text

Broker alerts disagree, and both camps can point to USTR. The Federal Register notice of 1 December 2025 says in its body that USTR "has determined to extend the 178 current exclusions until November 10, 2026", and the USTR press release repeats that. But the DATES line says the exclusions run "through 11:59 p.m. eastern daylight time on November 9, 2026", and both annexes, which carry legal effect, cover goods entered "before 11:59 p.m. eastern daylight time on November 9, 2026". The HTSUS heading descriptions for 9903.88.69 and 9903.88.70 now read "through November 9, 2026".

One more wrinkle: the notice says eastern daylight time, but US clocks go back on 1 November. Do not plan to clear anything in the final hour. Treat entries on 9 November as the last safe ones and ask your broker how CBP will apply the cutoff.

What We Found About an Extension

On 7 October 2026 USTR published a notice that the two 2018 China 301 actions did not terminate at their four-year anniversaries and remain in effect. USTR also issued conforming amendments to five exclusions because some ten-digit statistical numbers changed on 1 July 2026. We found no notice extending the 178 exclusions beyond 9 November in USTR's Federal Register documents to 7 October, or in its September and October press releases. Extensions have come late before (the previous one was announced three days before expiry), so keep checking, but do not plan on one.

What the Lapse Does to Landed Cost

Rates are examples; your broker confirms the rate for your line.

A US distributor imports a China-made component under an exclusion. Customs value is USD 40.00 a unit. Freight, insurance and fees add USD 4.00. It pays a 3.0% MFN rate and the 12.5% forced labour Section 301 rate, and assumes, as its broker confirms, that the two Section 301 rates stack. The product sits on a 25% list.

• Duty today: 40.00 x (3.0% + 12.5%) = USD 6.20.
• Duty after the exclusion ends: 40.00 x (3.0% + 12.5% + 25.0%) = USD 16.20.
• Landed cost moves from 50.20 to 60.20, up USD 10.00 or 19.9%.
• At 20,000 units a year that is USD 200,000.

*From extension to expiry: the dates that matter for an excluded line.*

Run the same sum on your own file with the landed cost formula. If you need a first duty estimate before your broker replies, see estimate import duty before you buy.

Action List, Dated

1. By 16 October: list every SKU entered under 9903.88.69 or 9903.88.70 in the last 12 months. Check the ten-digit number against the exclusion text, including the July 2026 conforming amendments.
2. By 23 October: ask your broker which China 301 heading each line falls back to, and re-run landed cost at the full rate.
3. By 30 October: decide what to pull forward. Count only goods that will be entered, or withdrawn from a bonded warehouse, by 9 November. Weigh the duty saved against the cash and storage cost of early stock.
4. By 6 November: send suppliers the re-run figures and ask for a price contribution, a cost breakdown, or a quote from another origin. If a US vendor imports for you, expect its notice to arrive soon after.
5. 9 November: last safe entry day.
6. 10 November: check the Federal Register and ustr.gov for any late extension, then update your price lists.

If the duty change makes a second origin worth testing, China plus one sets out how to compare it fairly. If a vendor answers with a surcharge, test it with tariff surcharges on supplier invoices.

Next Step

Start with the free 12 checks and justified-increase quick calculator, which you can use on the duty change and on any vendor notice that follows: get the checklist.

If the re-run shows the line no longer works from China, a Sourcing Feasibility Brief tells you which origins are realistic for that product family, with landed-cost ranges and a go or no-go, in 7 to 10 working days. USD 2,900. Merillgrove is paid only by the buyer and takes no supplier commissions. Ask for a brief.

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Sources (checked 8 October 2026): Federal Register, Notice of Product Exclusion Extensions (2025-21671), https://www.federalregister.gov/documents/2025/12/01/2025-21671/notice-of-product-exclusion-extensions-chinas-acts-policies-and-practices-related-to-technology; USTR press release, 26 November 2025, https://ustr.gov/about/policy-offices/press-office/press-releases/2025/november/ustr-extends-exclusions-china-section-301-tariffs-related-forced-technology-transfer-investigation; USITC HTS, https://hts.usitc.gov/; Federal Register, Continuation of Actions (2026-20510), https://www.federalregister.gov/documents/2026/10/07/2026-20510/continuation-of-actions-chinas-acts-policies-and-practices-related-to-technology-transfer; Federal Register, conforming amendments (2026-17925 and 2026-20511), https://www.federalregister.gov/documents/2026/09/02/2026-17925/notice-of-conforming-amendments-to-product-exclusions-chinas-acts-policies-and-practices-related-to and https://www.federalregister.gov/documents/2026/10/07/2026-20511/notice-of-conforming-amendment-to-product-exclusion-chinas-acts-policies-and-practices-related-to; USTR forced labour Section 301 press release and fact sheet, https://ustr.gov/about/policy-offices/press-office/press-releases/2026/july/ustr-takes-action-forced-labor-section-301-investigations and 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; Federal Register, forced labour Section 301 actions (2026-15181), https://www.federalregister.gov/documents/2026/07/28/2026-15181. Last checked: 8 October 2026. Commercial guidance, not legal, customs or tax advice.