$77 billion in tariffs. 178 exclusions extended. Scheduled increases hitting specific products. Here's your complete guide to navigating the chaos.
Section 301 tariffs on Chinese imports now account for $77 billion of the total $79 billion in U.S. tariffs collected. That's not a typo—these tariffs dwarf everything else combined.
If you import anything from China, Section 301 isn't just relevant to your business. It IS your business.
And 2026 brings a complicated mix of good news and bad news: exclusions extended, but also scheduled tariff increases kicking in. Let's break down exactly where things stand.
The Current State of Play
In early November 2025, President Trump and Xi Jinping announced a "historic trade and economic deal." As part of this agreement:
- 178 tariff exclusions were extended until November 10, 2026
- "Fentanyl tariffs" on Chinese imports were reduced by 10% (through November 10, 2026)
- Maritime sector tariffs (Section 301 actions on China's maritime, logistics, and shipbuilding dominance) were suspended until November 10, 2026
This was significant relief for many importers. But it's temporary—and there's still plenty of tariff pain embedded in the system.
The Four Lists: Know Which One Hits You
Section 301 tariffs were implemented in waves, each with different product coverage and rates:
List 1: $34 billion in imports at 25% tariff
- Effective July 6, 2018
- Focus: Industrial machinery, electronics, aerospace parts
List 2: $16 billion in imports at 25% tariff
- Effective August 23, 2018
- Focus: Additional industrial and chemical products
List 3: $200 billion in imports at up to 25% tariff
- Initial 10% effective September 24, 2018
- Increased to 25% effective May 10, 2019
- Focus: Consumer goods, furniture, building materials, apparel
List 4: Originally planned for remaining imports
- List 4A ($112 billion): 15% → reduced to 7.5%
- List 4B: Indefinitely suspended
Your first step: determine which list(s) your products fall under. This determines your baseline tariff rate before any exclusions.
Exclusions: The Golden Ticket
If your product has an exclusion, you don't pay the Section 301 tariff. Some exclusions have been in place since 2019, repeatedly extended, and remain in effect today.
How to Check If You Have an Exclusion
- Identify your product's HTS code
- Check the USTR's published exclusion lists
- Verify the exclusion is still active (they do expire and get renewed)
- Confirm your product matches the exclusion's exact description
Critical detail: Exclusions are product-specific, not HTS-code-specific. An exclusion might cover "certain stainless steel cookware with copper-bonded bottoms" but not all products under that HTS heading. Read the exclusion language carefully.
The November 2026 Cliff
The 178 extended exclusions all expire November 10, 2026. What happens then is anyone's guess—it depends on the state of U.S.-China trade relations at that point.
Smart importers are:
- Not assuming exclusions will be renewed
- Modeling their cost structure with and without exclusions
- Exploring alternative sourcing for critical products
- Building exclusion renewal lobbying into their trade advocacy
Scheduled Tariff Increases: What's Coming
The September 2024 tariff modifications included phased increases for specific products. Here's what's hitting in 2026:
Medical Gloves
- 2025: 50%
- 2026: 100%
That's right—medical gloves from China face a 100% tariff in 2026.
Other Products with 2026 Increases
| Product Category | 2026 Rate |
|---|---|
| Semiconductors | Increased rates |
| Lithium-ion batteries (non-EV) | Increased rates |
| Permanent magnets | Increased rates |
| Natural graphite | Increased rates |
| Respirators and facemasks | Increased rates |
| Syringes and needles | Increased rates |
Paused Increases (Delayed to 2027)
Some scheduled increases were paused at the last minute:
- Upholstered furniture: Was scheduled for 30% on January 1, 2026—now delayed to January 1, 2027
- Kitchen cabinets and bathroom vanities: Was scheduled for 50% on January 1, 2026—now delayed to January 1, 2027
If you import these products, you got a one-year reprieve. Use it wisely—diversify your sourcing now rather than waiting for the 2027 cliff.
How to Actually Manage Section 301 Exposure
Step 1: Audit Your China-Origin Imports
For every product you import from China:
- What's the HTS code?
- Which Section 301 list applies (1, 2, 3, or 4)?
- What's the current tariff rate?
- Do any exclusions apply?
- Are any scheduled increases coming?
Step 2: Calculate Your Total Duty Exposure
Section 301 tariffs stack on top of regular duties.
Example:
- Regular MFN duty rate: 5%
- Section 301 tariff: 25%
- Total duty: 30%
For a $1 million import, that's $300,000 in duties—versus $50,000 without Section 301.
Step 3: Evaluate Mitigation Strategies
Tariff Engineering: Can the product be modified to fall under a different HTS code with lower or no Section 301 tariffs?
Origin Shifting: Can production move to a non-China origin? Substantial transformation rules determine what counts as a different origin.
First Sale Valuation: If you're buying through a middleman, can you declare the first sale (factory to middleman) price instead of the higher middleman-to-you price?
Drawback: If you re-export goods or use them in products that are exported, you can potentially recover 99% of Section 301 duties paid.
Step 4: Request a Binding Ruling If Uncertain
If you're unsure whether a product falls under Section 301 or which list applies, request a binding ruling from CBP. Guessing wrong is expensive.
Step 5: Engage in the Process
USTR conducts exclusion processes and accepts public comments on tariff modifications. If Section 301 significantly impacts your business:
- File for exclusions when processes open
- Submit public comments during rulemaking
- Engage with trade associations lobbying on your industry's behalf
The squeaky wheel gets the exclusion.
Key Dates to Watch
| Date | Event |
|---|---|
| Ongoing | Phase One compliance investigation |
| November 10, 2026 | 178 exclusions expire |
| November 10, 2026 | Fentanyl tariff reduction expires |
| November 10, 2026 | Maritime sector tariff suspension expires |
| January 1, 2027 | Furniture/cabinet tariff increases (if not extended) |
The Bottom Line
Section 301 tariffs are the dominant cost factor for China imports in 2026. The $77 billion in tariffs isn't going away—but smart management can significantly reduce your exposure.
The importers who thrive:
- Know exactly where they're exposed
- Actively manage exclusion processes
- Diversify sourcing for critical products
- Use every legal mitigation tool available
- Stay engaged with regulatory developments
The importers who struggle:
- Treat Section 301 as a fixed cost
- Ignore exclusion opportunities
- Fail to scenario-plan for exclusion expiration
- Don't engage with USTR processes
With November 2026 deadlines looming, now is the time to get your Section 301 strategy in order.
Section 301 compliance starts with accurate HTS classification. TariffLens helps you identify the right codes so you know exactly which tariffs apply—and which exclusions you might qualify for.