Here’s something a lot of importers are watching right now: 178 product exclusions from Section 301 tariffs on Chinese goods are still in place — but they’re set to expire at 11:59 p.m. on November 9, 2026. And if history is any guide, the window to get your house in order is shorter than it looks.
A Quick Recap of Where We Are
Section 301 tariffs on Chinese goods have been in place since 2018. Over the years, USTR carved out exclusions for hundreds of specific products — but the vast majority of those have since lapsed. What’s left today is a narrow set of 178 active exclusions: 164 product-specific exclusions and 14 covering solar manufacturing equipment.
These were last extended in December 2025, following the Trump-Xi trade agreement announced November 1, 2025. USTR pushed the deadline to November 10, 2026 — and that’s where things stand today.
To claim the exclusion, importers use HTSUS subheadings 9903.88.69 or 9903.88.70. If your product qualifies and you’re not claiming it correctly on entry, you’re overpaying duties you don’t owe.
What Happens If They Expire
If USTR doesn’t act before November 10, the exclusion disappears automatically. No grace period, no phase-out. Entries filed on or after that date revert to the underlying Section 301 rate — typically 25% on List 1, 2, or 3 goods, or 7.5% on List 4A goods — stacked on top of the standard MFN duty rate.
That’s a significant cost shift for any importer currently relying on one of these exclusions.
Worth noting: the exclusions only offset Section 301 duties. MFN duties and any applicable Section 232 tariffs on steel, aluminum, or copper still apply regardless.
Should You Count on Another Extension?
That’s the key question — and the honest answer is: don’t plan on it.
USTR has been consistent in framing these exclusions as a temporary bridge toward sourcing diversification away from China, not a permanent feature of the tariff system. Each extension cycle has been short. No new exclusion request process is currently open. The agency’s posture hasn’t changed.
Treating November 10 as a soft deadline that will inevitably move again is a risk without much support behind it.
What Importers Should Be Doing Now
If your supply chain touches any of the 178 active exclusions, now is the time to act — not October.
A few places to start:
- Confirm whether your products actually qualify. The exclusion language is specific and technical. It matches against 10-digit HTSUS classifications and detailed product descriptions — not general categories. If you haven’t done a careful line-by-line review, that’s step one.
- Model the cost impact. If the exclusion expires and isn’t renewed, what does your landed cost look like? Running those numbers now gives you time to make sourcing or pricing decisions without pressure.
- Evaluate your alternatives. Sourcing diversification, nearshoring through USMCA-qualifying countries, and duty drawback programs are all worth exploring depending on your product category and volume.
- Make sure you’re claiming correctly today. If you do qualify and aren’t using the right HTSUS subheading on entry, you’re leaving money on the table right now — before the deadline even matters.
The Bottom Line
The exclusions are still in place, and that’s genuinely good news for the importers who qualify. But November 10, 2026 is a real date, and the track record of these extensions suggests it’s not safe to assume there will be another one.
At Coppersmith Global Logistics, we work with importers to navigate exactly these kinds of trade compliance questions — helping you understand what applies to your product, what’s changing, and how to stay ahead of it.
If you’re unsure whether your imports are affected, reach out to our team. We’re happy to talk through it.
