Cross-border operations guide ยท November 3, 2026

Section 301 List 4A and 4B: why a split from 2019 still sets your price in 2026

List 4 originally swept in the consumer goods earlier lists had spared: footwear, apparel, electronics, toys, the contents of a general merchandise store. Faced with that breadth, USTR divided the list. List 4A took effect in September 2019 at 15 percent additional, later reduced to 7.5 percent in the January 2020 phase one agreement. List 4B was scheduled for December 2019 and suspended days before it applied. A suspended list is a strange animal: the classification work was done, the Federal Register notices were published, and the duty simply never started.

How the split happened and why it stuck

Because it never started, teams forget it exists, and because List 4A's rate was halved once, teams misremember which half they are in. Both errors land in pricing. A sourcing model that applies 7.5 percent to a List 4B product overstates cost and loses the bid. A model that treats a List 4A product as suspended understates cost and finds out at entry summary, stacked on top of the MFN rate and any other actions in force by then.

Additional Section 301 duties are claimed and paid through chapter 99: the entry line carries the ordinary HTS subheading for classification and the 9903 subheading for the action. When you want to know what a product actually paid, that is the document trail to read, on the entry summary, not the supplier's quote sheet and not a blog summary of the lists, including this one. Lists were modified by exclusions, extensions, and later actions, and the only reliable answer for a given product on a given date is its classification worked against the current notices.

The chapter 99 line is the proof, not the spreadsheet

Keep a list determination in the product file: the HTS subheading, the list it falls in, the 9903 line applied, and the date and source of the determination. Files built that way survive staff turnover and broker changes. Files that live in one person's memory of a 2019 announcement do neither.

Exclusion processes granted product specific relief for defined periods, many later expired, some extended, and the Section 301 picture has continued to be adjusted by subsequent actions and reviews, including increases on specified product groups announced through the statutory review. An exclusion that saved a product in 2021 says nothing reliable about its treatment now. Checking exclusions is a dated exercise: current list status, current exclusion lists, current expiry, in that order.

Exclusions and later actions move the edges

Rates also stack in ways a single list lookup hides. A product can carry its column 1 rate, a List 4A additional duty, and exposure under separate authorities entirely, from Section 232 actions on steel and aluminium content to antidumping and countervailing duty orders that attach to the product and its origin. The 301 list check is one layer of the stack, done every time, never instead of the others.

The standing advice in this trade exists because the ground moves: confirm current status with a licensed customs broker before a sourcing decision, with the product's full classification in hand. Bring the broker the file described above and the question becomes a verification. Bring them a product photo and a guess and it becomes a classification project, billed like one.

For pricing committees, the honest line is a range with a date on it: this product, this list, this additional rate as of this determination, stacked on this base rate. Prices built on dated determinations can be defended when they change. Prices built on a remembered headline cannot, and in this area the headline is always older than the file.

Confirm before you commit the price

Frequently asked questions

What is the difference between List 4A and List 4B today?

List 4A goods carry an additional Section 301 duty, generally 7.5 percent since February 2020 for most lines. List 4B's additional duty was suspended before taking effect and has not been imposed. Classification decides which side a product sits on.

Where do I find which list my product is on?

Through its HTS classification checked against the USTR list annexes and the chapter 99 notes, a job your broker does with the product's full details. A keyword search of the list is a starting point, never the determination.

Do Section 301 duties replace the normal tariff rate?

No. They are additional. The column 1 rate still applies and the 301 duty stacks on top, along with any other applicable actions for that product and origin.

Could List 4B be imposed later?

A suspended action can be revived through agency process, which is why sourcing files should record the 4B determination rather than treating those products as permanently outside Section 301. Price with a contingency note, not with amnesia.

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