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Tariff Updates

Section 301 China Exclusions: Extended to November 9, 2026

The 178 Section 301 China exclusions under 9903.88.69 and 9903.88.70 expire at 11:59 p.m. ET on November 9, 2026. What they cover and what to plan for.

Brendan McLaughlinFounder of HTS Hero
Updated
Reading time
3 min read

Key takeaways

  • 178 Section 301 China exclusions are still in force: 164 product exclusions under heading 9903.88.69 (U.S. note 20(vvv)) and 14 solar manufacturing equipment exclusions under heading 9903.88.70 (U.S. note 20(www)).
  • USTR extended them from November 29, 2025 to 11:59 p.m. ET on November 9, 2026, in a Federal Register notice published December 1, 2025, following the US-China deal announced November 1, 2025.
  • Unless USTR extends them again, entries made on or after November 10, 2026 lose the exclusion and pay the Section 301 duty for the product's list: 25% for Lists 1 to 3, 7.5% for List 4A.
  • Excluded Chinese products still pay the HTS base rate and, since July 24, 2026, the 12.5% Section 301 forced-labor duty, which the exclusions don't cover.

Updated October 6, 2026: expiry is close

These exclusions expire at 11:59 p.m. ET on November 9, 2026, and USTR hasn't announced another extension yet. If your products rely on them, plan for the Section 301 duty coming back on entries from November 10.

The 178 remaining Section 301 China tariff exclusions, claimed under HTS headings 9903.88.69 and 9903.88.70, are extended until 11:59 p.m. ET on November 9, 2026. USTR set that date in a Federal Register notice published December 1, 2025, after the US-China deal of November 1, 2025. If they lapse, excluded products go back to paying 25% (Lists 1 to 3) or 7.5% (List 4A).

What the 9903.88.69 and 9903.88.70 exclusions do

The Section 301 tariffs on Chinese goods are split across lists, each with its own Chapter 99 heading (9903.88.01, 9903.88.02, 9903.88.03 and so on). Over the years, USTR has excluded specific products from those tariffs. Two headings carry the exclusions that are still alive:

  • 9903.88.69: 164 product-specific exclusions listed in U.S. note 20(vvv) to Subchapter III of Chapter 99
  • 9903.88.70: 14 exclusions for solar manufacturing equipment, listed in U.S. note 20(www)

The HTS itself confirms these are the only ones left: a compiler's note to U.S. note 20 says only subdivisions (vvv) and (www) are now in effect.

When a product matches one of these exclusions, the importer reports the exclusion heading instead of the Section 301 heading, and the 301 duty doesn't apply. The exclusion descriptions are often narrower than the HTS subheading they sit under, so a product can share a subheading with an excluded item and still owe the full tariff.

Updated statistical numbers from July 1, 2026

Some exclusions are written around 10-digit statistical numbers. When the HTS renumbered certain pump parts and plastic articles on July 1, 2026, the 9903.88.69 list picked up the new numbers. 2026 HTS Revision 18 has the details.

The extension timeline

DateWhat happened
May 31, 2025USTR extends the 164 product exclusions and 14 solar equipment exclusions through August 31, 2025
September 2, 2025Federal Register notice extends all 178 by 90 days, through November 29, 2025
November 1, 2025The White House announces a US-China deal that includes extending the 178 exclusions to November 10, 2026
November 26, 2025USTR announces the extension
December 1, 2025Federal Register notice published, effective November 30, 2025
November 9, 2026Current expiry, 11:59 p.m. ET

What duty applies if the exclusions expire

Without the exclusion, a Chinese product pays its full Section 301 rate again. Here's how the duty builds for an excluded product from China:

DutyWith the exclusionAfter it expires
HTS base rateAppliesApplies
Section 301 list dutyNone25% (Lists 1 to 3) or 7.5% (List 4A)
Section 301 forced-labor duty (9903.05.31)12.5%12.5%
Section 232, if the product is coveredAppliesApplies

The forced-labor duty that started on July 24, 2026 applies to products of China whether or not they use a 301 exclusion, though it switches off for goods that pay a Section 232 duty. 2026 HTS Revision 13 covers it, and our guide to US tariff stacking rules explains how Section 301 China combines with everything else.

What to do before November 9, 2026

  1. List every product that uses 9903.88.69 or 9903.88.70 on its entries.
  2. Work out the duty without the exclusion. That's usually the base rate plus 25% for products on Lists 1 to 3, plus the forced-labor duty. The duty calculator shows the full stack for any HTS code from China.
  3. Watch for a USTR notice. Extensions have tended to arrive close to the deadline, so don't assume either outcome.

A tariff change alert on your product catalog takes care of step 3 for you. Add your products to the Duty Guard and when an HTS revision changes the duty on one of them, you hear about it the same day.

FAQ

Frequently asked questions

When do the Section 301 exclusions 9903.88.69 and 9903.88.70 expire?

At 11:59 p.m. eastern time on November 9, 2026, under a USTR notice published in the Federal Register on December 1, 2025. Entries made on or after November 10, 2026 can't claim them unless USTR extends them again.

How many Section 301 exclusions are still active?

178: 164 product-specific exclusions claimed under 9903.88.69 and 14 exclusions for solar manufacturing equipment claimed under 9903.88.70. They are the only Section 301 China exclusions from the original lists still in effect.

What happens to my duty if the exclusion expires?

The product goes back to paying the Section 301 tariff for its list, which is 25% for Lists 1 to 3 and 7.5% for List 4A, on top of the base rate, the 12.5% Section 301 forced-labor duty and any other tariffs that apply.

Will USTR extend the Section 301 exclusions past November 2026?

As of October 6, 2026, USTR hasn't announced a further extension. Past extensions have often come within weeks of the deadline, so importers should plan for both outcomes.

Sources

The official documents this article is based on

  1. Federal Register: Notice of Product Exclusion Extensions, China's Acts, Policies, and Practices Related to Technology Transfer (December 1, 2025)
  2. USTR: USTR Extends Exclusions from China Section 301 Tariffs (November 26, 2025)
  3. USTR Federal Register notice extending exclusions to November 2026 (PDF)
Brendan McLaughlin
Written by

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.

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