The layer cake: five charges that stack on Chinese imports
Every Chinese product entering the US runs through the same five questions. Most people stop after the second one and quote a number that is 12.5 points too low — the gap the July 2026 action opened.
- MFN base rate. The standard US tariff on that HTS code, applied to all WTO members without a preferential FTA rate. China's MFN status has not been revoked (despite periodic legislative proposals to do so), so Chinese goods get the same base rate as goods from Germany, Japan, or Brazil. Most industrial products land between 0% and 8%, with a few outliers above 15%.
- Section 301 — the China lists. Additional duties imposed specifically on Chinese-origin goods under USTR's finding that China's intellectual property practices and technology-transfer policies are unreasonable and burden US commerce. These are the 7.5% and 25% numbers everyone talks about. They apply to virtually every HTS code on the four Section 301 lists, with narrow product-specific exclusions.
- Section 301 — the forced-labour action, in force 24 July 2026. A separate determination, not an extension of the China lists. USTR applied it to roughly 60 economies, China included, at +12.5% additive on the MFN rate. It stacks with the China lists — a List 1 machine at 25% becomes 37.5% — and it does not stack with Section 232, so steel, aluminium, copper, autos and auto parts, lumber and semiconductors pay 232 and skip this layer. It replaced the 10% Section 122 surcharge that lapsed the same day, which is why the figure is 12.5% rather than a round number.
- Anti-dumping / countervailing duties (AD/CVD). Factory-specific penalty deposits imposed when the Department of Commerce finds that a Chinese product is being sold below fair value (dumping) or with countervailable subsidies. Unlike the MFN and Section 301 rates, which are the same for all Chinese exporters of a given HTS code, AD/CVD rates vary by factory. Two Chinese brake-rotor factories making the identical product can face AD margins of 3% and 94% respectively depending on whether they cooperated with Commerce's investigation.
- Section 232 (steel, aluminum, copper). 50% on articles wholly or nearly wholly of metal and 25% on derivatives whose metal content exceeds 15% by value — both charged on the full customs value since 6 April 2026, not on the metal inside the article. The measure is product-based, so it applies to every origin; the UK rates and the 200% rate on Russian aluminum are the negotiated exceptions. For China the 232 duty piles on top of everything else, and the 12.5% forced-labour layer drops out where 232 already applies. Finished assemblies with incidental metal content are no longer automatically clear — the 15% threshold decides that, and the tier ladder is set out in the Section 232 guide.
The total effective rate on a Chinese import is the sum of whichever of these five layers apply. For most consumer goods it is MFN + the China list + the 12.5% forced-labour layer, with no AD/CVD and no 232. For industrial metal products it can be all five. There is exactly one subtraction in the whole stack, and it matters: where Section 232 applies, the forced-labour layer drops out. A steel article does not get both. The table below shows the real numbers.
Product-by-product: what you actually pay, October 2026
These are representative rates for the most commonly imported Chinese goods in each category. The "Total" column is the rate on your CBP Form 7501, assuming no active exclusion and no AD/CVD (AD/CVD is noted separately where it commonly applies).
| Product Category | HTS Chapters | MFN Base | 301 List (Rate) | Forced-labour 301 | Total Effective | AD/CVD Risk | Calculator |
|---|---|---|---|---|---|---|---|
| Electronics (phones, laptops) | 8471, 8517 | 0% (ITA) | List 4A (0%, suspended) | +12.5% | 12.5% | Low | Calc → |
| Electronics (PCBs, networking) | 8534, 8517.62 | 0–3% | List 1 (25%) | +12.5% | 37.5–40.5% | Low | Calc → |
| Apparel & Textiles | 61, 62, 63 | 8–32% | List 3 (7.5%) | +12.5% | 28–52% | Low | Calc → |
| Industrial Machinery | 84 (exc. 8471) | 0–4.2% | List 1 (25%) | +12.5% | 37.5–41.7% | Medium (bearings) | Calc → |
| Furniture | 9401, 9403 | 0–8% | List 3 (7.5%) | +12.5% | 20–28% | High (A-570-890) | Calc → |
| Plastics & Articles | 39, 40 | 0–6.5% | List 3 (7.5%) | +12.5% | 20–26.5% | Low | Calc → |
| Auto Parts | 8708, 8483, 8511 | 2.5% | List 1 (25%) | Not added (232 autos) | 27.5% | High (brakes, bearings) | Hub → |
| Steel Articles | 73 | 0–7% | List 1 (25%) | Not added (232 steel) | ~57% (+25% 232) | Very High | Calc → |
| Aluminum Articles | 76 | 0–5.7% | List 1 (25%) | Not added (232 alu) | ~35.7% (+10% 232) | High | Calc → |
| Toys, Games, Sporting Goods | 9503–9506 | 0–4.5% | List 3 (7.5%) | +12.5% | 20–24.5% | Low | Calc → |
Four things jump out. First, the spread from cheapest to most expensive is 12.5% (phones that used to clear at zero) to ~57% (steel carrying both Section 232 and the China list) — same origin, same lane, a 44-point gap driven entirely by what the product is. Second, the MFN base rate is almost never the number you pay; Section 301 dominates for industrial goods, and since July 2026 there are two Section 301 actions doing the dominating. Third, the forced-labour layer is why nothing enters free any more — it is not a China tariff, so "source it elsewhere" only moves you between tiers, never back to zero. Fourth, where Section 232 applies the forced-labour column reads "not added": steel, aluminium and auto parts genuinely do not pay both. If someone tells you "China tariffs are 25%," ask which China tariffs, and then ask which tier.
Section 301 explained — the four lists, in plain English
The USTR's Section 301 action against China was announced in four stages between 2018 and 2019. Each "list" is a set of HTS codes, and each list carries its own surcharge rate. Here's what matters for importers in 2026:
- List 1 — 25%, no changes since 2018. Covers industrial goods: machinery, engines, electrical equipment, auto parts, medical devices, and certain electronics components including PCBs and networking gear. This is the list that hits Chinese industrial machinery, auto parts, and bare electronics components the hardest. The 25% rate has never been reduced, and USTR has given no indication it will be.
- List 2 — 25%, no changes. Covers plastics, chemicals, rubber goods, and some metals. Plastics articles from China (Chapter 39) are caught here, which is why the effective rate on Chinese plastic goods is often 25–32% once you add the 6.5% MFN base.
- List 3 — originally 25%, reduced to 7.5% under the Phase One deal (2020), held at 7.5% ever since. This is the big consumer-goods list: apparel and textiles, footwear, furniture, toys, home goods, and most finished consumer products. The 7.5% rate is fragile — it exists because the Phase One agreement has not been formally terminated, but USTR has signaled repeatedly that a return to 25% is under active consideration. If you sell Chinese consumer goods to the US market, build your model at both 7.5% and 25% and see which one your margins survive. For the full history, see Section 301 China Tariffs Guide.
- List 4A — 15%, suspended indefinitely. Would have covered phones, laptops, toys, and footwear — essentially all remaining consumer goods not on earlier lists. Was announced but never imposed, and the suspension has held for six years. For importers of ITA-covered electronics (phones, laptops), List 4A's suspension is the only reason the effective rate is 0% instead of 15%. If List 4A were ever unsuspended, it would be the single most consequential tariff change for the consumer electronics trade since the ITA itself.
- List 4B — never imposed. Covered a handful of additional codes. Functionally irrelevant in 2026.
The key strategic fact for importers: Lists 1 and 2 at 25% are settled policy and unlikely to change without major legislation or a Phase Two trade deal (neither of which appears imminent). List 3 at 7.5% is the volatile one — it was reduced as part of a deal that is now widely considered ineffective, and its future depends on the outcome of the ongoing USTR exclusion review and broader US-China trade policy. If you're importing List 3 goods (apparel, furniture, plastics articles), the policy risk is asymmetrically large.
The de minimis cliff: how the $800 line closed
For years, Section 321 was the quiet cheat code for Chinese imports. A shipment valued at $800 or less per person per day entered the US with zero duty, zero tax, and zero MPF — regardless of what product it was or where it came from. A $799 dress from a Chinese factory paid nothing; a $12,000 container of the same dresses paid the full freight. The economic incentive to structure shipments under $800 was enormous, and CBP spent years watching it happen. Then it stopped: the exemption was suspended with effect from 29 August 2025, for every country of origin rather than China alone.
The suspension was written up as indefinite in June 2026: after the Supreme Court struck down the IEEPA tariff authority on 20 February 2026, a same-day executive order moved the suspension onto a different statutory footing, so it did not resume. Duty is due from the first dollar. The 2026 Section 321 reform page tracks the position — for most Chinese-goods importers the practical takeaway is that de minimis is gone, not merely unreliable. Budget for duty on everything.
What of Entry Type 86, the electronic entry type built for Section 321? The infrastructure still exists, but with the exemption suspended there is no duty-free lane for it to serve. For the thresholds that are still standing, check the Global De Minimis Guide and the Cliff Detector, which cross-references your shipment value against de minimis rules across 7 markets simultaneously.
Anti-dumping and countervailing duties: where the rate breaks 40%
The rate table above shows the MFN + 301 total. For several product categories, anti-dumping and countervailing duties add a third layer that can double the effective rate. These are the most consequential AD/CVD orders affecting Chinese imports to the US, organized by product:
- Wooden bedroom furniture (A-570-890). The big one. AD margins: 0% for cooperating factories, 216% for the China-wide entity rate. In effect since 2005, reviewed annually, and aggressively enforced. If you're importing Chinese wooden bedroom furniture, this AD order defines your landed cost far more than the 7.5% Section 301 surcharge. See China → US Furniture for the calculator and AD primer.
- Brake rotors (A-570-846). Chinese cast-iron brake rotors: AD margins from 0% (cooperating) to 43.5% (non-cooperating). CVD margins add another 6–12%. On a $10,000 shipment of brake rotors, the AD deposit alone could be $4,350 — and that's before the 2.5% MFN and 25% Section 301.
- Tapered roller bearings (A-570-601). Chinese bearings: AD margins from 0% to 92.8%. This order covers a narrow set of HTS subheadings within 8482, but if your Chinese bearings fall under it, the AD math dominates everything else.
- Aluminum extrusions (A-570-967 / C-570-968). Chinese extruded aluminum products: AD margins 0–374% in extreme cases. CVD adds another 14–374%. These numbers sound absurd, but they're real — the China-wide non-cooperating entity rate for aluminum extrusions is one of the highest in Commerce's AD/CVD inventory.
- Steel nails, wire rod, pipe, and tube. Multiple AD/CVD orders across various steel product categories. Too many to list individually; search the ITA's AD/CVD database by your specific HTS code before sourcing Chinese steel products. The AD orders layer on top of the 25% Section 232 steel tariff and the 25% Section 301, which together already push Chinese steel over 50%.
The AD/CVD system operates on a different logic from regular tariff rates. AD/CVD deposits are collected at entry as cash deposits, held by CBP, and only finalized when Commerce completes its annual administrative review — which can take two to three years. If the final rate is lower than the deposit, the difference is refunded with interest. If it's higher, the importer pays the difference. The practical reality: most importers treat the deposit as a cost and don't count on a refund. If a refund comes, it's upside. If it doesn't, the model was built assuming it wouldn't.
One more thing worth knowing: anti-dumping orders attach to the exporter, not just the product. If Factory A has a 0% AD rate and Factory B has a 45% AD rate, you can buy from Factory A and pay the MFN + 301 rate with no AD deposit at all. The AD rate is factory-specific, not country-wide (the "China-wide entity rate" applies only to exporters who did not cooperate with Commerce's investigation). This is why experienced Chinese-goods importers verify their factory's AD status before placing the purchase order — a 45-point swing on the same product from a different factory a few kilometers away changes the profitability of the entire shipment.
The exclusion landscape: what's available, and what isn't
Since 2018, USTR has operated an exclusion process for Section 301 tariffs. Importers can request that a specific 10-digit HTS code be excluded from the Section 301 surcharge, typically on grounds that the product is not available from non-Chinese sources or that the tariff causes disproportionate economic harm. Thousands of exclusions have been granted, and thousands more have been denied. Most exclusions are temporary — 12 to 18 months — and many that were granted and later expired were not renewed.
What's covered in October 2026: active exclusions are concentrated in medical supplies (PPE, certain medical devices), a narrow set of electronics components, and specific industrial inputs where domestic production capacity doesn't exist. Consumer goods exclusions are rare and getting rarer — USTR's general posture since the Phase One deal has been to narrow the exclusion program rather than expand it.
What's under review: USTR announced a comprehensive exclusion review for Q3 2026 covering several hundred HTS codes. The outcome is uncertain, but the review itself signals that at least some changes to the exclusion list are coming. The Section 301 guide tracks the current exclusion list and the status of pending reviews.
The practical advice for importers: check the USTR exclusion portal for your specific 10-digit code before you quote a landed cost. An active exclusion on a List 1 product reduces the rate from 27.5% (2.5% MFN + 25% 301) to 2.5% — a 25-point swing that determines whether the product is sourceable from China at all. If no exclusion exists, assume the full Section 301 rate applies. Exclusions are not granted retroactively, so you can't claim one on a shipment that already cleared.
Section 232: steel and aluminum — a global tariff that China can't avoid
Section 232 of the Trade Expansion Act of 1962 allows the President to impose tariffs on national-security grounds. The measure began in 2018 at 25% on steel and 10% on aluminum and has been rebuilt twice since: the rate rose to 50% in June 2025, and on 6 April 2026 the duty base moved from the value of the metal in an article to its full customs value. These tariffs are product-based, so they apply to every origin. The country carve-outs that once existed — the EU, Japanese, Korean and other tariff-rate quotas, and the Australian, Argentine and Brazilian arrangements — were revoked in March 2025, leaving the UK rates and the 200% rate on Russian aluminum as the remaining exceptions. China never had an exemption, and Chinese steel and aluminum articles pay the full surcharge.
When Section 232 applies, it layers on top of MFN and Section 301. A Chinese steel pipe under HTS Chapter 73 that would otherwise pay 2.5% MFN + 25% Section 301 = 27.5% instead pays 2.5% + 25% + 25% = 52.5%. All three rates are computed on the same customs value, so the effective rate is their sum and not a compound. One correction to the pre-2026 arithmetic: the forced-labour layer added in July 2026 does not stack with Section 232. A steel article picks up 232 and the China list, and the 12.5% layer stays out entirely — which is why the steel row in the table above is unchanged by it.
The line is no longer drawn at the HTS chapter, and this is the single most expensive thing that changed in April 2026. Until then the rule was easy to state: Section 232 reached articles of steel or aluminum, not products that merely contained them, so a Chinese brake caliper under 8708.30 paid MFN and Section 301 but no 232, while a steel I-beam under 7216 paid all three layers. The metals regime now reaches derivative products as well, and the test is the metal share of the article by value — above 15% and the derivative tier charges 25% on the full customs value, at or below 15% and the article stays outside. For the brake caliper the answer now depends on how much of its value is metal, not on which chapter it sits in. The Section 232 guide works through the thresholds and the tiers.
The Mexico question: nearshoring is real, but it's not a loophole
The Chinese tariff stack has driven a significant share of US-bound manufacturing to Mexico. The logic is straightforward: a Chinese auto part at 27.5% effective vs a Mexican auto part at 0% under USMCA. The 27.5-point gap more than covers the labor-cost difference for many product categories. The Guanajuato, Nuevo León, and Aguascalientes automotive and industrial clusters have absorbed billions in redirected investment as a result.
But the geography of trade is sometimes misleading. A Chinese-owned factory in Mexico producing parts from Chinese-origin steel and Chinese-made subcomponents, then finishing and assembling them in Mexico, can generate a USMCA-origin product if the assembly in Mexico crosses the substantial-transformation threshold. The rules are technical — regional value content, tariff shift, specific manufacturing process requirements — and CBP's enforcement posture on potential transshipment through Mexico has tightened considerably since 2023. A product that is merely inspected, repacked, or lightly processed in Mexico does not become Mexican origin and does not shed the Chinese tariff stack.
For importers evaluating the China-vs-Mexico sourcing decision, the IMMEX Nearshoring guide covers the IMMEX program, the USMCA origin rules, and the landed cost math in detail. The short version: nearshoring works when the manufacturing process in Mexico is real — stamping, welding, assembly, testing — not when it's a box-swap. CBP's increased audits of Mexican-origin claims in 2024–2026 mean the distinction matters more than ever.
How to calculate your real rate — a worked example
Here's a concrete example to pull the layers together. Take a hypothetical shipment:
- Product: 500 units of CNC-machined aluminum pump housings for industrial water pumps
- HTS classification: 8413.91.9080 (parts of pumps, Chapter 84)
- MFN base rate: 0% (many pump parts are duty-free)
- Section 301 — China list: List 1, 25%
- Section 301 — forced-labour layer: +12.5%, additive on the MFN base, in force since 24 July 2026
- Section 232 aluminum: Does not apply — the article is classified under Chapter 84 (machinery), not Chapter 76 (aluminum). The aluminum content is incidental to the classification.
- AD/CVD: No specific AD/CVD order covers this subheading
- Goods value (FOB Shanghai): $25,000
- Ocean freight + insurance to Long Beach: $1,200
- CIF value (entered value for customs): $26,200
Duty calculation: $26,200 × 37.5% (0% MFN + List 1 at 25% + the 12.5% forced-labour layer) = $9,825. Merchandise Processing Fee: $26,200 × 0.3464% = $90.76. Harbor Maintenance Fee (ocean freight, 0.125%): $32.75. Total customs cost: $9,948.51. Landed cost: $26,200 + $9,948.51 = $36,148.51. Effective rate: 38.0% on CIF. The supplier's invoice said $25,000. Your actual cost to get those pump housings into your US warehouse: over $36,000 — 45% above the supplier price. That's the difference between FOB and landed, and it's the number your margin model needs.
Now change one variable: the pump housings are machined in Taiwan instead of China, using the same aluminum stock. The China lists drop off — they reach Chinese origin only — and the forced-labour layer stops being additive and becomes a floor: Taiwan sits in the fill-to-10 tier, so duty is 10% of value rather than zero. Duty: $26,200 × 10% = $2,620. MPF: $90.76. HMF: $32.75. Total customs: $2,743.51. Landed: $28,943.51. The origin change saves $7,205 on one container. Same part, same process, different factory location — but note that even the better answer is no longer zero, which is the part most sourcing models still get wrong. Knowing both your product's China list and your origin tier is worth more than any freight negotiation.
Run your own numbers on the Landed Cost Calculator or use the corridor-specific calculators on each China→US product page: Electronics, Apparel, Furniture, Machinery, Plastics.
What to watch, Q3 2026 and beyond
The China–US tariff landscape is not static. Here's what could change the numbers in the table above over the next 12 months:
- USTR Section 301 exclusion review. The comprehensive review announced for Q3 2026 could grant new exclusions, restore expired ones, or narrow the program further. If your product's 10-digit code has an active exclusion, flag it — expirations usually don't give much warning, and a lapsed exclusion means the full Section 301 rate kicks in on the next entry.
- List 3 restoration to 25%. The 7.5% rate on apparel, furniture, toys, and other consumer goods exists at USTR's discretion. The Phase One deal's enforcement mechanism is effectively dead, and the political consensus for keeping consumer-goods tariffs low is weaker than it was. A restoration to 25% would be the single largest tariff action on Chinese goods since 2018 and would immediately reprice the entire consumer-goods import supply chain.
- De minimis reform — Section 321 narrowing. CBP's T86 program processes millions of low-value entries daily, and the political pressure to narrow the de minimis exemption for Chinese goods is bipartisan. The 2026 reform page tracks the latest. But budget as if the exemption doesn't exist — it's the safer bet right now.
- New AD/CVD investigations. Commerce opens new anti-dumping and countervailing-duty investigations regularly. If you're importing a Chinese product at scale and it's not yet subject to AD/CVD, it might be next — especially in metal-intensive categories where Chinese overcapacity is a known concern. Subscribe to the ITA's Federal Register notices or have your broker flag new investigations that cover your HTS codes.
- MFN revocation proposals. Legislation to revoke China's permanent normal trade relations (PNTR) status has been introduced in multiple Congresses and has never passed, but the proposal keeps resurfacing. If it ever passed, China's MFN base rates would be replaced by Column 2 rates (the Smoot-Hawley-era schedule, which runs 30–60% on most goods). The probability is low, but the impact would be catastrophic — an order of magnitude larger than any Section 301 change. Know your exposure so you're not surprised if the debate heats up.
- Section 122 expiration — today. Not specifically a China tariff, but it affects the math on every US import. The Section 122 10% global surcharge hits its 150-day statutory limit on July 24, 2026. After it expires, USTR's proposed Section 301 tariffs targeting 60 countries could refill the gap at potentially higher rates — and China is already named in the industrial-overproduction investigation. If you model your China-to-US landed costs, factor in the Section 122 removal and its likely Section 301 replacement.
The corollary to all this uncertainty: the rate that's right today might be wrong in six months. The calculators on this site — electronics, apparel, furniture, machinery, plastics — are verified against the current rate database on every verification cycle. Use them to build your baseline. Subscribe to the rate change feed. And check before every large purchase order — the only thing more expensive than spending 15 minutes rechecking is finding out after the shipment lands that the rate moved.
Frequently asked questions
What's the real total tariff rate on Chinese imports in 2026?
There is no single "real rate." It depends on your product's HTS chapter. Consumer electronics (phones, laptops) land at 12.5% — 0% MFN, List 4A still suspended, plus the 12.5% forced-labour layer in force since 24 July 2026. Apparel and textiles run 28–52% (MFN 8–32% + List 3 at 7.5% + the 12.5% layer). Industrial machinery is typically 37.5–41.7% (MFN 0–4.2% + List 1 at 25% + 12.5%). Steel articles from China can exceed 50% once Section 232 is added — and there the forced-labour layer drops out, because it does not stack with 232. The rate is set by your 10-digit HTS code, not by the word "China."
How do I know if my Section 301 rate is 7.5% or 25%?
Find your 10-digit HTS code on the USTR Section 301 lists. List 1 and 2 are at 25%. List 3 is at 7.5% (reduced from 25% under the Phase One deal). List 4A is 15% but suspended. List 4B was never imposed. If your code doesn't appear on any list, you pay the MFN rate only. Most Chinese industrial goods land on Lists 1 or 2; most consumer goods on List 3. A customs broker can confirm the code-to-list mapping definitively.
Can I avoid Section 301 by shipping through a third country?
No. Section 301 applies to Chinese-origin goods regardless of the shipping route. A product made in China, shipped to Vietnam, and re-exported to the US remains Chinese origin and still pays Section 301. Changing the country of origin requires substantial transformation — a change in name, character, or use — in the third country, not repackaging or relabeling. CBP has enforced this aggressively since 2018, with transshipment audits and penalties in the millions. If someone sells you a "simple transshipment solution," walk away.
What's the difference between the MFN rate and the Section 301 surcharge?
The MFN rate is the standard US tariff applied to all WTO members without a preferential trade agreement. It is set by the Harmonized Tariff Schedule and changes slowly through legislation and trade negotiations. Section 301 is a trade-remedy action administered by USTR rather than through the tariff schedule, and since July 2026 there are two of them: the China lists, which reach Chinese-origin goods only, and the forced-labour action, which reaches about 60 economies at +12.5%, +10%, or a 10–12.5% floor depending on origin. The total rate = MFN + the China list where it applies + the forced-labour layer + any applicable AD/CVD + Section 232 if the product is a steel or aluminium article — and where 232 applies, the forced-labour layer drops out.
Are Chinese consumer electronics still zero-duty?
Not any more — 12.5%. Phones and laptops are ITA products with bound zero MFN rates and Section 301 List 4A (which would have added 15%) is still suspended, so the headline MFN number remains zero. But the forced-labour Section 301 action of 24 July 2026 adds 12.5% to Chinese-origin goods, so a phone that cleared free in June now pays 12.5%. Bare PCBs, networking gear and non-ITA electronics from China stack List 1 at 25% on top of it, reaching 37.5%. The distinction is still made at the 10-digit HTS level. Check your code on the China → US Electronics calculator.
How does the anti-dumping deposit work in practice?
When you import a product subject to an AD order, CBP collects a cash deposit at the published margin rate for your specific exporter. For a cooperating factory with an individually determined rate, the deposit might be 3–10%. For a non-cooperating factory, it's the China-wide entity rate, which can be 40–200%+. The deposit is held by CBP and reconciled when Commerce completes its annual administrative review — a process that typically takes 2–3 years. If the final rate is lower, you get a refund with interest. If it's higher, you owe the difference. The practical advice: find a cooperating factory with a published low AD rate, and build your model around the deposit rate. If a refund comes, treat it as a bonus.