Section 301 Tariffs 2026: What You Need to Know

What Are Section 301 Tariffs?

Section 301 of the Trade Act of 1974 gives the US Trade Representative (USTR) authority to impose tariffs on imports from countries engaged in unfair trade practices. Since 2018, the US has used Section 301 to impose additional tariffs on hundreds of billions of dollars of Chinese imports, fundamentally altering the cost structure of US-China trade.

These tariffs are in addition to the standard Most Favored Nation (MFN) duty rates in the HTS. So a product with a 3% MFN rate that is also on Section 301 List 3 would face a total duty of 28% (3% MFN + 25% Section 301). The financial impact is enormous: US importers have paid over $230 billion in Section 301 duties since 2018.

The Four Lists Explained

1. List 1 ($34B): 25% tariff on 818 HTS codes including industrial machinery, auto parts, and chemicals. Effective July 2018.
2. List 2 ($16B): 25% tariff on 279 HTS codes including semiconductors, plastics, and motorcycles. Effective August 2018.
3. List 3 ($200B): 25% tariff on approximately 5,700 HTS codes covering a broad range of consumer and industrial goods. Effective September 2018, raised from 10% to 25% in May 2019.
4. List 4A ($120B): 7.5% tariff on approximately 3,800 HTS codes including consumer electronics, apparel, and food products. Effective February 2020.

2026 Updates and Increases

Following the USTR’s 2024 four-year review, several key changes took effect in 2025 and 2026. Electric vehicle tariffs increased from 25% to 100%. Solar cell tariffs increased from 25% to 50%. Semiconductor tariffs increased from 25% to 50%. Lithium-ion EV battery tariffs increased to 25% (effective 2026). Steel and aluminum tariffs increased to 25%. These increases reflect the administration’s strategic focus on protecting domestic manufacturing in critical technology sectors.

How to Determine If Your Product Is Affected

Section 301 tariffs are imposed on specific HTS codes, not on product categories in general. To determine if your product is subject to Section 301 duties, you need the accurate 8-digit or 10-digit HTS code, the country of origin of the product (Section 301 applies only to Chinese-origin goods), and a check against the current USTR lists including any active exclusions.

This is where accurate HTS classification becomes critical. A classification error that places your product on a different HTS code could mean the difference between 0% and 25% additional duty. Conversely, a more specific classification might move your product off a covered list.

Mitigation Strategies

• Supply chain diversification: Source from Vietnam, India, Thailand, or Mexico instead of China
• First Sale valuation: Use the first sale price (manufacturer to middleman) rather than the transaction price to reduce the dutiable value
• Foreign Trade Zones (FTZ): Import into an FTZ and re-export without paying Section 301 duties
• Duty drawback: Recover 99% of duties paid on imported goods that are subsequently exported
• Product re-engineering: Modify the product to classify under an HTS code not covered by Section 301
• Tariff engineering: Restructure how goods are imported (e.g., ship components separately for assembly in the US)

How Camtom Helps

Camtom automatically cross-references your HTS classification against all four Section 301 lists, active exclusions, and recent modifications. The system calculates the total duty burden including MFN rate plus Section 301 surcharge and identifies if any mitigation strategies apply. This real-time analysis ensures you never miss a Section 301 liability — or an opportunity to legally reduce it.