USTR's notice of action of July 23, 2026 imposed Section 301 forced-labor duties effective 12:01 a.m. ET on July 24, 2026, on products of 60 economies at 10 or 12.5 percent by country group. For Chinese-origin goods the rate is 12.5 percent on most lines, reported under heading 9903.05.31, and it is not netted against the MFN rate. It sits on top of it.
The context is the February 2026 Supreme Court decision in Learning Resources v. Trump, which held that IEEPA did not authorize tariffs. CBP stopped collecting IEEPA duties on February 24, and a temporary Section 122 surcharge ran from February 24 to July 24, 2026. The Section 301 forced-labor action took its place on July 24, and the 145 percent and 30 percent IEEPA numbers are dead. Stop pricing against them.
For most general merchandise outside Section 232, the working structure is the MFN rate plus a 2018 Section 301 list duty of 25 percent or 7.5 percent, plus the 12.5 percent forced-labor duty in force since July 24, 2026, plus any four-year-review increase for that line. A Chinese-origin machined part in November 2026 pays exactly that stack: MFN, then the list duty, then 12.5 percent, and Section 232 on top where the steel or aluminum content is in scope.
Two exemptions matter. Goods already subject to Section 232 tariffs, including steel, aluminum, copper, automobiles and parts, and timber and lumber derivatives, are expressly excluded from the forced-labor duty under HTS note 52. USMCA-qualifying goods are also exempt. The 2018 Section 301 list duties still apply to Section 232 goods unless a specific note says otherwise, so the exemption is from the new 12.5 percent, not from the whole stack. One rate is never one rate: the MFN base plus 301 plus 232 plus AD/CVD where they apply is the number that lands on the entry summary, and the forced-labor duty is the newest layer in it.
Check three things. First, the HTS line: the forced-labor duty applies by line, and the exclusions are written into the notes, so a line you think is covered may not be, and a line you think is exempt may not be either. Second, the entry date: the duty applies to goods entered from July 24, 2026, and entries before that date are under the old regime. Third, the USMCA status: a qualifying good is exempt, and a good that almost qualifies is not.
Confirm the current status with a licensed customs broker before a sourcing decision, and check the entry summary, CBP Form 7501, for the 9903 line. Section 232 steel content is the other live question on the same entries, because the metal content in the bill of materials decides both the 232 duty and the forced-labor exemption. The stack only works if every layer is checked. The importers who get surprised are the ones who checked one.
USTR's July 23, 2026 notice imposed Section 301 duties on products of 60 economies at 10 or 12.5 percent, effective July 24, 2026. For Chinese goods the rate is 12.5 percent on most lines, reported under heading 9903.05.31.
No. It stacks on top of them. Most Chinese lines now pay the MFN rate plus the 2018 list duty of 25 or 7.5 percent, plus the 12.5 percent forced-labor duty, plus Section 232 where it applies.
Goods subject to Section 232 tariffs, including steel, aluminum, copper, automobiles and parts, and timber and lumber derivatives, are expressly excluded. USMCA-qualifying goods are also exempt.
No. The February 2026 ruling in Learning Resources v. Trump struck down the IEEPA tariffs only. Section 301 and Section 232 tariffs were not affected, and the forced-labor action was imposed after the ruling.