New U.S. Section 301 Tariffs: What Importers Should Check Before Shipping

Trade update

On July 23, 2026, the Office of the U.S. Trade Representative announced a new Section 301 tariff action covering imports from 60 economies. The measure took effect at 12:01 a.m. Eastern Time on July 24, 2026, replacing the expiring 10% temporary global tariff. For U.S. importers and project buyers, the headline is less important than the operating question: does the current quote still match the duty treatment, entry date, and shipment plan?

What changed

The action is based on Section 301 of the Trade Act of 1974 and USTR's forced-labor investigations. USTR says the covered economies failed to impose or effectively enforce a prohibition on imports made with forced labor. The business result is a new tariff structure that keeps a broad duty floor in place after the temporary 10% global surcharge expired.

For purchasing teams, this is not just a compliance headline. It affects landed-cost math, DDP pricing, shipment timing, supplier comparisons, and whether a quote issued before July 24 still protects margin.

How the tariff bands work

USTR created three practical rate groups. The exact duty result still depends on country of origin, HTS classification, existing duty rate, and whether the product appears in the exemption annex.

Compared with the expiring 10% temporary global tariff, the rate change is not the same for every country. The 10% group generally keeps the same headline surcharge level for non-exempt goods. The 12.5% group creates a 2.5 percentage-point increase for non-exempt goods that were previously modeled under the temporary 10% surcharge. The MFN offset group is product-specific: the extra Section 301 duty depends on the existing MFN rate, so some products may receive only a small add-on and some may receive no Section 301 add-on at all.

Why China-origin goods need a fresh landed-cost check

China and Hong Kong are in the 12.5% group. That does not mean every product automatically increases by 12.5 percentage points from the last quote. Many buyers were already working under a temporary 10% global surcharge that expired on July 24. For non-exempt China-origin goods, the more useful planning comparison is often the move from the expiring 10% surcharge to the new 12.5% Section 301 rate.

The safer workflow is to stop using old quote templates until the duty line has been reviewed. Check the HTS code, origin, existing duty rate, Section 232 exposure, product-specific exemptions, and the actual entry date. A quote that was accurate last week may not be accurate after the vessel cutoff.

This matters even more for custom metal products, fencing systems, gates, hardware, machined parts, and project cargo. A small percentage change can decide whether a delivered quote still works after ocean freight, customs entry, drayage, warehousing, and final delivery are included.

Exemptions: do not rely on broad labels

The public headlines mention energy, fertilizer, food, raw materials, Section 232 goods, and trade-agreement carveouts. That is useful background, but importers should not treat those categories as blanket exemptions. The final treatment is controlled by the HTS provisions and notes in the Federal Register notice and its annexes.

• Not covered by the action: informational materials, donations, and accompanied baggage.
• Section 232 overlap: articles and parts already subject to certain Section 232 tariff programs are not subject to these Section 301 duties. The notice lists categories including steel, aluminum, copper, certain vehicles and vehicle parts, wood products, medium- and heavy-duty vehicles and parts, and semiconductor articles.
• USMCA: Canada and Mexico goods entered free of duty under USMCA are carved out under the listed HTS notes.
• CAFTA-DR textile/apparel: certain textile and apparel goods from Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, and Nicaragua entered free of duty under CAFTA-DR are carved out.
• Annex exemptions: the annex lists HTS provisions for products such as certain foods, raw materials, industrial inputs, fertilizers, energy products, civil aircraft items, and pharmaceutical-use products. The HTS code matters more than the product nickname.
• Textile TRQs: USTR directed future tariff-rate quotas for Bangladesh, Cambodia, Indonesia, and Malaysia. Until those TRQs are established, the applicable 10% Section 301 tariff still applies to covered textile and apparel imports.
• Patented pharmaceuticals: the notice includes a separate HTS modification effective July 31, 2026 for patented pharmaceutical articles. This should be checked by HTS code, not described broadly as “all pharmaceuticals.”

In-transit goods: the timing is narrow

USTR included a short in-transit rule. Goods loaded at the foreign port before 12:01 a.m. Eastern Time on July 24, 2026, and already in the final mode of transportation to the United States may avoid the new additional duty if they are entered for consumption or withdrawn from warehouse for consumption before 12:01 a.m. Eastern Time on July 28, 2026.

That timing should be checked against the bill of lading, loading record, carrier timeline, and entry status. Do not assume a booked shipment qualifies just because production finished before the effective date.

Key dates importers should keep in front of the team

A buyer-side checklist before booking or quoting

1. Confirm country of origin. Do not assume the supplier country and origin are the same.
2. Confirm the HTS code with your broker. Product description alone is not enough for duty planning.
3. Check whether the economy is in the 10%, 12.5%, or MFN offset group.
4. Review the exemption annex by HTS code. Broad category language can create false confidence.
5. Check Section 232 overlap. Metal, vehicle, wood, semiconductor, and related goods may need special review.
6. Recalculate landed cost. Update DDP, delivered, and resale margin assumptions before issuing a firm quote.
7. Check the vessel loading date and entry date. The in-transit rule is timing-specific.
8. Keep the commercial invoice, packing list, origin support, and product spec consistent.
9. Ask for written broker confirmation on edge cases. This is especially important for mixed-origin assemblies and custom metal products.
10. Build a price-review clause into active quotes. Tariff rules can change faster than production schedules.

What this means for sourcing decisions

The new tariff does not automatically make one sourcing country better than another. It does make lazy comparisons more dangerous. A supplier with a lower ex-works price may lose its advantage after duty, inland freight, customs complexity, rework risk, or delivery uncertainty. A higher unit price may still win if the total delivered cost is cleaner and the lead time is more predictable.

For industrial buyers, the right comparison is still total cost, not factory price. That means material, tooling, packaging, duty, freight, documentation, quality control, storage risk, and delivery reliability all need to sit in the same calculation.

How EONE uses this update with project buyers

For fencing systems, gates, hardware, custom metal fabrication, casting, machining, and project supply programs, EONE can help organize the product information buyers need before a broker review: product description, material, finish, dimensions, packing data, country-of-origin support, and shipment timing. For DDP or delivered-cost discussions, we also check whether an old tariff assumption is still safe before a quote is finalized.

EONE does not replace the importer of record, customs broker, or trade counsel. Our job is to keep the manufacturing and logistics information clean enough for the responsible filing parties to make decisions without wasting days on avoidable corrections.