Updated September 8, 2026 · Focus: the July 2026 tariff change and pre-shipment checks for commercial imports into the United States.
The new 12.5% duty is not a single total tariff rate for imports from China. Effective July 24, 2026, covered China-origin goods became subject to an additional Section 301 duty under HTSUS heading 9903.05.31, with specified exceptions. Your total depends on the product’s classification, origin, other applicable duties, and any exception that applies. CBP’s filing guidance sets out the measure and its entry requirements.
If you do not have an internal customs team, the practical task is to get those assumptions checked before you rely on an old cost sheet or accept a DDP quote. This guide explains what to collect, what to ask, and how to record the answer.
Before committing to the next shipment, check three things:
- Is the product’s country of origin China? Shipping from China alone does not establish origin.
- Has someone reviewed whether the July measure or a listed exception applies to this SKU?
- Which HTSUS code, duty measures, and review date support the number in your current budget?
If an answer is “I don’t know,” treat the budget as unverified (not automatically wrong, but not ready to rely on).
What changed in July 2026: how China import duties stack
The new duty comes from the Section 301 action concerning trading partners’ failure to prohibit imports made with forced labor. It is separate from the older China Section 301 tariff lists. USTR’s July 23 announcement explains the action and links to the notice.
For covered goods, CBP specifies entry for consumption, or withdrawal from warehouse for consumption, on or after 12:01 a.m. Eastern Time on July 24, 2026. Do not use the order date, sailing date, or arrival date alone to decide applicability.
The word that matters is “additional.” Start with the product’s base duty, then check each potentially applicable measure and its exceptions.
| Layer | What to verify | Common misreading |
|---|---|---|
| Base rate (MFN) | The Column 1 General rate for the correctly classified product in the current HTSUS. | Assuming there is one standard “China rate.” The base depends on the product. |
| Existing China Section 301 duties | Whether the product is covered by an existing list, its additional rate, and any applicable exclusion. Many covered products carry 7.5% or 25%; some categories have higher rates. | Thinking the July measure replaced the older China tariffs. |
| July 2026 Section 301 duty | Heading 9903.05.31 adds 12.5% for covered China-origin goods, unless a specified exception applies. | Using 12.5% as the total duty rate. |
| Section 232 and other exceptions | Check the relevant Section 232 measure and the conditions in heading 9903.05.90 and U.S. note 52(f). Other July-measure exceptions have their own conditions. | Assuming that any mention of Section 232—or any exception heading—automatically exempts the entire SKU from the new duty. |
| Antidumping / countervailing duties | Whether the product falls within an AD/CVD order and which rates apply. A tariff-code lookup alone is not a scope determination. | Omitting a potentially substantial duty layer from the budget. |
| Customs fees | For formal entries, MPF is generally 0.3464% of entered value, subject to a minimum and maximum. HMF is generally 0.125% for applicable ocean imports. | Treating these as part of the tariff percentage—or as universally fixed charges. |
For FY2026 formal entries, the MPF minimum is $33.58 and the maximum is $651.50. These limits, set in the FY2026 fee notice, apply through September 30, 2026; use the applicable FY2027 limits for entries on or after October 1. CBP’s user fee table lists the current HMF rate and other entry-related charges.
Does replacing 10% with 12.5% mean my total rises by 2.5 points?
Only if the other assumptions hold. The July action followed the expiration of the temporary 10% Section 122 surcharge. Replacing a 10% layer with a 12.5% layer increases that layer by 2.5 percentage points. It does not, by itself, confirm your SKU’s total duty rate, current classification, or eligibility for an exception. Existing China Section 301 duties and any other applicable measures still need to be checked.
Are there exceptions to the new China tariff?
Yes. CBP explicitly lists exceptions; the question is whether your product meets their conditions. The guidance identifies product provisions under U.S. note 52, including specified civil aircraft and pharmaceutical-use articles and a provision covering certain Section 232-related articles. Use the legal description and conditions, not a broad label such as “electronics,” to assess a possible exception.
One listed provision is no longer useful for a new shipment: the in-transit exception under 9903.05.85 required qualifying goods to be entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. Eastern Time on July 28, 2026. That window has closed.
These exceptions concern the July measure. Qualifying for one does not automatically remove other duties or fees. Ask your broker to identify the specific provision and supporting documents for any exception used in your budget.
What to collect for each SKU before you book
Verification goes fast when the documents are complete and slow when they are not. Collect them before you ask anyone for a number.
Ask your supplier for:
- Product name, materials, and material composition by percentage
- What the product is used for, in plain terms
- Photos of the product and its packaging
- The HS code they declare, and where it came from: who assigned it, based on what
- Origin information and whatever documentation supports it
Confirm on your side:
- The entry documents from your last shipment, including the HTS code that was declared
- The duty assumptions inside your current cost sheet
- Your shipping plan: target ship date, expected consumption-entry date, mode, port of entry, and delivery terms
- Dimensions, weights, quantities, and declared value
Hand to your forwarder or broker:
- The full SKU list with the documents above
- Delivery terms (DDP, FOB, or other) and the destination address
- Which costs you need inside the updated number: duties included or not, final delivery included or not
One caution. This list exists to collect facts, not to steer the outcome. You are documenting what the product is. Leave the question of which code it belongs to open until someone qualified answers it.
How to check official tariff sources before asking your broker
Use these free sources to prepare a focused question:
- Base classification and rate: Search the current USITC HTSUS. Read the product description and relevant notes, not just the displayed percentage.
- Existing China Section 301 lists: Consult the USITC China Tariffs reference, then check the applicable Chapter 99 provisions and exclusions. This reference is not a complete calculation of all import duties.
- July measure and exceptions: Use CBP CSMS #69326983 alongside the current HTSUS legal notes. USTR’s announcement above provides the policy background and a link to the notice.
- Comparable classification decisions: Search CBP CROSS for products with similar construction and use. A ruling for a similar-looking product is not automatically applicable to yours; check its facts and current status.
- Advance certainty: Where appropriate, consider a CBP binding ruling request through eRulings. Follow CBP’s rulings guidance; a ruling applies to the facts and conditions it addresses, not every product in a broad category.
A list search helps only if the underlying classification is correct. Finding a code on an older list does not establish every duty payable, and not finding it there does not rule out the separate July measure.
What to ask about a DDP quote or broker’s duty estimate
If you buy DDP with an all-in price, start with the quote. Ask the provider to state in writing whether it includes the July duty or relies on an exception, when the quote expires, and who pays any difference if the duty assumptions change before entry. If an exception is assumed, ask for its basis. Use the validity stated on your actual quote, not a general rule about how long freight prices last.
If you are the importer of record (IOR), ask your broker to review the product-level assumptions. You can copy this request:
“For the attached SKU list, product documents, and planned entry date, please review: (1) the proposed HTSUS classification and country of origin, (2) whether the July 2026 Section 301 duty or a specified exception applies, (3) the other duties and fees applicable to each SKU, and (4) any missing documents or unresolved assumptions. Please distinguish a preliminary estimate from conclusions supported by the documents reviewed.”
Keep the written response with the product documents and quote. A broker’s review supports your decision; it is not a guarantee that CBP will accept an entry unchanged.
The roles are different: a licensed customs broker or trade counsel can advise, but the importer of record retains the responsibility to exercise reasonable care. CBP makes the final classification and valuation determinations, as explained in its recordkeeping guidance. Ever Ocean’s role here is to organize documents, coordinate with the broker, and update the freight quote—not issue a binding customs determination.
Copy this SKU tariff-verification record
Create one record per SKU and attach the supporting documents. Fill it in after the review, not from memory.
| Field | What to record |
|---|---|
| SKU and product specification | SKU, description, material composition, use, and the version of the photos or specification reviewed. |
| Origin | Country of origin and the documents supporting it. |
| Classification | Reviewed 10-digit HTSUS code, rationale or relevant ruling, reviewer, and review date. |
| Applicable duty layers | Base rate; each applicable Chapter 99 heading and rate; Section 232 or AD/CVD review where relevant; links to the supporting provisions. |
| Exceptions or exclusions | The specific provision, qualifying conditions, supporting evidence, and any expiration date—or “not established.” |
| Entry and valuation assumptions | Expected consumption-entry date, entered value, and any facts still awaiting confirmation. |
| Fees and quote terms | MPF/HMF assumptions, included and excluded costs, delivery terms, quote validity, and agreed treatment of duty differences. |
| Review outcome | Written response and reviewer details; whether the estimate remains preliminary; outstanding questions and who will resolve them. |
Recheck the record if the product, origin, planned entry date, or applicable rules change. Keep the earlier version so you can see why the budget was revised.
How to update your import-duty budget: an illustrative example
Consider a hypothetical China-origin backpack shipment with an entered value of $20,000. For this calculation only, assume the classification review supports a 17.6% base rate, a 25% existing China Section 301 duty, and the new 12.5% duty. Also assume no relevant exclusion or exception, no Section 232 or AD/CVD duty, and a formal ocean entry subject to MPF and HMF during FY2026.
These are modeling assumptions, not a classification or duty-rate determination for backpacks generally. The example does not assign a tariff code to your product or represent an actual customer quote.
- Duty rate assumed: 17.6% + 25% + 12.5% = 55.1%.
- Duty: $20,000 × 55.1% = $11,020.
- MPF: $20,000 × 0.3464% = $69.28, within the FY2026 minimum and maximum.
- HMF: $20,000 × 0.125% = $25.
- Duties and these customs fees: $11,114.28. This is not the full landed cost; it excludes freight, insurance, brokerage, delivery, and any other applicable charges.
If the only change from an earlier estimate were replacing a 10% layer with 12.5%, the difference would be $20,000 × 2.5% = $500. That comparison works only if the entered value, remaining duty layers, and treatment of the product are unchanged.
For your own budget, use the reviewed rates from the SKU record and the fees applicable on the actual entry date. The calculation is straightforward once the assumptions are sound.
Three things can still move the final number after you have the confirmed rate:
- Quote validity and the exchange rate. A confirmed duty applied to a stale quote is still a stale number. Freight benchmarks move on their own weekly clock; the current reads sit in our China–USA freight market update.
- If your delivery terms change, who owes which cost changes with them.
- On DDP terms, how the difference gets settled when duty assumptions break is a contract question, and it belongs in writing before you accept the quote.
When to hold the booking
These are reasons to pause a booking until the issue is resolved:
- Your supplier cannot say where the product is made, or cannot back the answer up
- The HS code comes from “we have always declared it this way,” and nobody can say who chose it
- The declared code does not match what the product is
- Your broker needs more documents to answer, and the documents are not coming
- The quote has expired, or it leaves both the duty assumptions and responsibility for later differences unclear
A pause may delay the shipment. An unresolved duty assumption can be more expensive, especially when the order’s margin is narrow.
The part you can control
The policy is out of your hands. Whether the check happens before the cargo moves is not.
If you are pricing the next shipment now, send us your SKU list and product documents. Include your destination, delivery terms, and planned shipping date. We organize the documents for broker review, coordinate outstanding questions, and update your DDP quote with its scope, validity, and documented duty assumptions.
FAQ
Is 12.5% the total US import tariff on goods from China?
No. It is an additional duty for covered China-origin goods under heading 9903.05.31. The product’s base rate, existing China Section 301 duties, other applicable measures, and exceptions determine the total. Customs fees are separate.
Does the July tariff apply based on the shipping date or arrival date?
Neither date alone decides it. CBP’s guidance specifies entry for consumption, or withdrawal from warehouse for consumption, from the stated effective time. Ask your broker which entry date and provisions apply to your shipment. The July 28 deadline for the listed in-transit exception has already passed.
My supplier gave me an HS code. Is that enough to calculate my duty?
No. Ask who assigned it and on what basis. The supplier’s code is a starting point; the US entry needs the appropriate HTSUS classification for the actual product, plus review of the applicable additional duties and exceptions.
I ship DDP with an all-in price. Do I still need to check anything?
Yes. Obtain written confirmation of the included duties and fees, any exception assumed, quote validity, and responsibility for differences. Also clarify who is acting as importer of record; a DDP price alone does not answer that question.
This article is general information, not legal or customs advice. The linked sources support the rules and fee references discussed; the calculation is illustrative, not a product-specific determination. Check the current HTSUS and official guidance for the planned entry date. Licensed customs brokers and trade counsel can advise, the importer of record retains its reasonable-care obligations, and CBP makes the final determinations.
