2026 HTS Revision 20: Pharma Tariff List and R&D Exemption
2026 HTS Revision 20 grew the Section 232 pharmaceutical tariff list to 149 lines and exempted clinical trial and R&D use (9903.04.70) from September 29, 2026.
Brendan McLaughlinFounder of HTS Hero- Published
- Reading time
- 3 min read
Key takeaways
- 2026 HTS Revision 20 took effect on September 28, 2026. Its tariff changes apply from September 29.
- The list of products covered by the Section 232 pharmaceutical tariff grew from 131 to 149 statistical lines.
- New heading 9903.04.70 exempts pharmaceuticals used solely for clinical trials, research and development, or other non-commercial purposes.
- The exemption for companies identified by the Secretary of Commerce (9903.04.61) lapsed on September 29, 2026, the end date written into it since Revision 14.
- As of October 6, 2026, Revision 20 is the current revision of the 2026 Harmonized Tariff Schedule.
2026 HTS Revision 20 is a pharmaceuticals revision, in force from September 28, 2026, with changes that apply from September 29. It leaves every rate alone. It changes which products the Section 232 pharmaceutical tariff covers and which ones are exempt, which for a drug importer can mean the difference between 0% and 100%. As of October 6, 2026, it's the current revision of the HTS.
At a glance
| Revision | 2026 HTS Revision 20 |
| In force from | September 28, 2026 |
| Tariff changes effective | September 29, 2026 |
| Programs affected | Section 232 pharmaceuticals |
| Previous revision | Revision 19 |
What changed
149 lines on the pharmaceutical tariff list
The Section 232 pharmaceutical tariff applies to products listed in U.S. note 40(c) to Chapter 99. Revision 20 expanded that list from 131 to 149 statistical lines:
- Several existing lines were split into finer statistical numbers, including
2922.19.09,2934.99.47,2937.22.00,2941.90.30,2941.90.50and3004.31.00. - In Chapter 30, four lines were removed (including
3004.20.0083and3004.90.9225) and 14 were added under3004.20,3004.32,3004.39and3004.90.92.
A medicine classified under one of the newly added lines that paid no Section 232 duty on September 28 can owe up to 100% from September 29, unless an exemption or a country deal applies.
New exemption 9903.04.70: clinical trials, R&D and non-commercial use
New heading 9903.04.70 covers pharmaceutical articles and ingredients that are solely for use in clinical trials, research and development, or other non-commercial applications, at 0%.
It joins the other "not a patented pharmaceutical" exemptions, for generics (9903.04.67), U.S. active ingredients (9903.04.68) and articles that aren't pharmaceuticals (9903.04.69). The headings from 9903.04.60 to 9903.04.70 are mutually exclusive, so a product enters under exactly one.
The country rate can still apply
Goods under 9903.04.70 don't count as Section 232 articles for the country programs, so the Section 301 forced-labor duty for the country of origin applies unless another exemption covers the product. Nearly all finished medicines under heading 3004 (every subheading except 3004.43.00) are on note 52(b)'s list and pay no country rate. A listed active ingredient such as 2918.99.30.00 from India, used solely for research, pays India's 10% unless it's claimed under 9903.05.89 for pharmaceutical applications.
Lapsed: the "identified companies" exemption
9903.04.61, which exempted products of companies identified by the Secretary of Commerce, only covered goods entered before September 29, 2026. That end date was written into the heading from the start in Revision 14, and it fell on the same day Revision 20's changes began. Those products now fall under whichever other pharmaceutical heading fits.
Clarified definitions
The notes also clarified three definitions without changing any heading:
- Excipients and inactive ingredients aren't pharmaceutical articles.
- Unpatented animal health products count as generics.
9903.04.69also covers pharmaceutical articles that are neither patented nor generic.
Also from September 29: Canadian import bans
Proclamations 11061, 11062 and 11063 ban imports of certain Canadian products listed in their annexes from 12:01 a.m. eastern time on September 29, 2026: many beers, wines and spirits (some only when packaged for consumers), whey, molasses and non-alcoholic beer, and motorcycles over 800 cc. CBP rejects any entry that includes them (CSMS #70050970). Goods imported before September 29 but not yet entered for consumption can still be entered, and they pay the 50% Section 338 duty. These bans came by proclamation and CBP guidance, outside this revision's change record.
What it means for importers
On $10,000 of a patented medicine under 3004.90.92.60 (base rate free), entered from September 29, 2026:
| Origin and use | Heading | Duty |
|---|---|---|
| Germany, commercial | 9903.04.62: 15% including base | $1,500 |
| India, commercial | 9903.04.60: up to 100% including base | $10,000 |
| India, solely for clinical trials | 9903.04.70 (0%), and 3004.90.92 is exempt from the country rate under note 52(b) | $0 |
If you import pharmaceuticals or their ingredients, check two things against Revision 20: whether any of your HTS lines were added to (or dropped from) the note 40(c) list, and whether any shipments qualify for the new R&D exemption. The duty calculator applies the Revision 20 list by entry date and asks whether the R&D exemption fits. For every 2026 revision in one place, see the 2026 HTS revisions hub.
Frequently asked questions
When did 2026 HTS Revision 20 take effect?
Revision 20 was published for September 28, 2026, and its Section 232 pharmaceutical changes apply to goods entered on or after September 29, 2026.
Are pharmaceuticals for clinical trials exempt from the Section 232 tariff?
Yes, from September 29, 2026. Heading 9903.04.70 exempts pharmaceutical articles and ingredients used solely in clinical trials, research and development, or other non-commercial applications. The importer has to be able to support that use.
Which products were added to the pharmaceutical tariff list in Revision 20?
From September 29, 2026, the note 40(c) list grew from 131 to 149 statistical lines. Six existing lines, including 2922.19.09 and 3004.31.00, were split into finer statistical numbers, four Chapter 30 lines such as 3004.20.0083 were removed, and 14 lines were added under 3004.20, 3004.32, 3004.39 and 3004.90.92.
Do exempt pharmaceuticals still pay other tariffs?
They can. Like generics, goods under 9903.04.70 aren't treated as Section 232 articles for the country programs, so a country rate such as the Section 301 forced-labor rate applies unless another exemption covers the product. Nearly all finished medicines under heading 3004 (every subheading except 3004.43.00) are on note 52(b)'s exemption list and pay no country rate, while a listed ingredient such as 2918.99.30.00 from India pays India's 10% unless it qualifies under 9903.05.89.
Sources
The official documents this article is based on
- USITC: 2026 HTS Revision 20 change record
- Federal Register: Proclamation 11020, Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients Into the United States
- USITC: Harmonized Tariff Schedule, Chapter 99
- Proclamation 11061: Excluding certain Canadian alcoholic beverages from importation (Federal Register)
- Proclamation 11062: Excluding certain Canadian products from importation (Federal Register)
- Proclamation 11063: Excluding certain Canadian products from importation (Federal Register)
- CBP CSMS #70050970: Certain Canadian products excluded from importation
Brendan McLaughlin · Founder of HTS Hero
Brendan is the founder of HTS Hero and a self-proclaimed tariff nerd. He has spent more than a year building and maintaining HTS Hero's tariff calculator, which meant reading every government tariff update and all 4,000+ pages of the Harmonized Tariff Schedule, across many revisions. He writes about US tariffs regularly on LinkedIn.
Related articles
2026 HTS Revision 19: Section 338 Canada Lists Expanded
2026 HTS Revision 19 widened the 50% Section 338 tariff on Canada from September 15, 2026, adding furniture, cheese and boats and stacking it on Section 232.
· 3 min read
HTS Revisions2026 HTS Revision 18: Section 232 Drone Tariffs, Beef Quota
2026 HTS Revision 18 added Section 232 drone tariffs of 25% or 100% from September 3, 2026, plus a 300,000-ton lean beef quota and Section 301 code fixes.
· 4 min read
HTS Revisions2026 HTS Revision 17: 50% Section 338 Tariff on Canada
2026 HTS Revision 17 added a 50% Section 338 tariff on about 550 listed Canadian products from August 22, 2026, owed even when USMCA is claimed.
· 3 min read
Know the day a tariff change hits your products
Add your HTS codes and countries once. HTS Hero checks every new tariff action against your imports and tells you exactly how each one is affected.
What you get
- Alerts when a tariff change hits your imports
- Before and after rates for each import, and the change in %
- Impact checks on any tariff action, plus rate history and CSV or Excel exports
- Free for 14 days on up to 200 imports, no credit card