Since July 24, 2026, a new tariff layer applies to goods from 60 economies — and in my experience talking to small importers, most of them found out the hard way: the quote looked fine, then the entry summary came back with a charge nobody budgeted for. This is the "global" Section 301 program (the forced-labor one, Federal Register 2026-15181), and it is separate from the older China Section 301 lists.
Last week I wrote about the five duty layers in a landed-cost calculation. Today, a concrete pre-order check: how to tell in about 15 minutes whether this new layer hits your product, and how much it actually adds.
Step 1: Nail down the 10-digit HTS code
Everything starts with classification. Get the exact 10-digit HTS code from your supplier — in writing. A 6-digit guess is not enough, because the exemptions and the Chapter 99 surcharge lines live at the 8–10 digit level. If two suppliers quote you "the same" product under different codes, resolve that disagreement before you compute anything.
Step 2: Confirm true country of origin
Origin is where the goods were grown, manufactured, or substantially transformed — not where they were shipped from. A Vietnamese-assembled product using Chinese components may or may not be Vietnamese origin; a Malaysian-traded Chinese-made good is still Chinese origin. When in doubt, your customs broker can make a formal determination. Getting this wrong poisons every later step.
Step 3: Check whether Section 232 covers your product (if yes, you may be exempt)
This surprises people: goods covered by the Section 232 sectoral tariffs — steel, aluminum, copper and derivatives, passenger cars/light trucks and parts, wood products, medium/heavy trucks and parts, semiconductors — are exempt from the global 301 layer, regardless of origin country. The two programs don't stack. So before you panic about the 12.5% tier, check whether your HTS line already falls under a 232 action.
Step 4: Find your country's tier
The program has four tiers:
| Tier | Economies (examples) |
|---|---|
| 10% flat (17) | India, Indonesia, Malaysia, Mexico, Canada, UK, Pakistan, Sri Lanka… |
| 10% cap | European Union (all 27), Taiwan |
| 12.5% cap | Japan, South Korea, Switzerland |
| 12.5% flat (38) | China, Vietnam, Thailand, Brazil, Hong Kong, Singapore, Türkiye, Australia… |
The "cap" tiers are net of MFN: the MFN duty plus the 301 surcharge combined cannot exceed 10% (or 12.5%). So a German machine part with a 2.5% MFN rate gets 7.5% added; a line with a 10%+ MFN rate gets zero added. Flat tiers just stack on top, period.
Step 5: If you import from Canada or Mexico — check USMCA eligibility
Goods from Canada or Mexico that qualify for USMCA duty-free treatment are exempt from the global 301 layer. The importer claims this eligibility, so make sure your supplier documentation actually supports a USMCA claim (certification of origin, tariff shift rules). Don't assume — verify, or skip the exemption.
Step 6: Scan the exclusion lists
Two kinds of carve-outs exist in U.S. note 52 of the Federal Register notice:
- General product exclusions — 16 specific commodity lines (etrogs, frozen tropical fruit, sowing seeds, açaí, single-strength citrus juice, coconut water, eucalyptus plywood, and similar). Narrow, but worth a scan.
- Per-economy product lists — Annex II of the notice lists product exemptions for specific countries (UK, EU, Switzerland, Taiwan, and others).
The authoritative source is the HTS Chapter 99, Subchapter III text on hts.usitc.gov — search your 10-digit code and read the Chapter 99 references that come back.
Step 7: Stack the layers — and watch China
For China origin, the new 12.5% global 301 layer stacks on top of the existing China Section 301 lists (the 7.5%–25% List 1–4A rates) and on top of MFN. A product that was "25% tariffed" last year can now carry meaningfully more. Also note: the existing China 301 exclusion lists are scheduled to expire November 10, 2026 — if your product currently relies on an exclusion, diarize that date.
Step 8: Mind the special cases
- In-transit relief: goods loaded before July 24 and entered before July 28, 12:01 a.m. ET escaped the layer. Only relevant for shipments in the pipeline at announcement time, but worth knowing if you're auditing old entries.
- Textile TRQs pending: Bangladesh, Cambodia, Indonesia, and Malaysia are supposed to get tariff-rate quotas for apparel; until USTR establishes them, the flat 10% applies.
- Canada has an extra layer: separate proclamations under Section 338 add a 50% surcharge on Canadian autos, dairy, and alcohol (effective August 22, 2026) — with no USMCA exemption, unlike the global 301 layer. If you import Canadian wine, maple-adjacent dairy, or vehicle parts, read the Annex II scope carefully; 232-covered goods are again excluded.
- Caps on compound duties: for the capped tiers, compound MFN duties are reduced to their ad-valorem equivalent first. This is fiddly math — most calculators (and some brokers) get it wrong.
Step 9: Recompute your margin at the landed number
Add the layers to MFN, add MPF (0.3464%, min/max apply) and freight, and re-run your unit economics at that number — not at invoice value, and not at last quarter's rate sheet. Then screenshot or print your calculation with the date on it: when a rate changes, you'll want to know which quotes were priced on which rule snapshot.
The honest caveats
This program is already being litigated at the Court of International Trade, and rates have been adjusted by proclamation more than once since July. Whatever you compute today, treat it as a snapshot: verify the rates the week you place the order, not the week you read a blog post (including this one).
I maintain a versioned tariff rule database for a living — we built InvoiceTariff precisely because static spreadsheets kept rotting — and even we re-verify against the Federal Register text every time the radar flags a change. The method above is the same one we walk through; do it manually once and you'll never look at a supplier quote the same way again.
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