The US Section 301 tariffs on China — first imposed July 2018 under USTR investigation No. 301-0428 — remain the single largest variable cost for US buyers sourcing from Chinese factories. They are organised in four lists (1, 2, 3, 4A) with a fifth "List 4B" proposed but never activated. Most-favoured-nation (MFN) duty continues to apply, and since 2024 a layer of IEEPA reciprocal duties has been added on top. The stacked effective rate on most consumer goods from China in 2026 is approximately 33%, computed below.
| Layer | Authority | Typical rate (consumer goods) |
|---|---|---|
| MFN duty | HTSUS General duty rate | 0–8.6% |
| Section 301 (Lists 1, 2, 3) | USTR 301-0428 | 25% |
| Section 301 (List 4A) | USTR 301-0428 | 7.5% |
| IEEPA reciprocal surcharge (China-origin) | IEEPA / NFRA Reciprocal | 20% (most consumer goods) |
| Stacking note | Section 301 + IEEPA applied additively on the entered value | + IEEPA is on top of Section 301 |
HTS mapping for WanLong product lines. List 1 (25%): stainless cookware, kitchen utensils. List 2 (25%): plastic household items. List 3 (25%): luggage, handbags, paper products. List 4A (7.5%): consumer electronics, certain housewares. The Sept 2024 four-year review made targeted increases on EVs (100%), batteries, semiconductors, and select medical products — but left Lists 1–4A at their previous rates for most consumer goods categories. The Supreme Court ruled on the IEEPA layer in late 2025; most of the reciprocal duty was preserved, and a narrow IEEPA refund programme was opened in Q1 2026 for documented overpayments.
What to watch in late 2026. USTR's second four-year review of the original Section 301 lists opened a public comment window in March 2026 (USTR-2026-0007). Expect possible scope revisions to List 1/2/3 (notably on batteries, semiconductors, and personal protective equipment) by Q1 2027. Tariff engineering — small product or material changes designed to land a different HTS code — is under heightened CBP scrutiny, and any engineering must reflect a substantive transformation, not merely a cosmetic change.
Action items for buyers. (1) Maintain SKU-level HTS classification with the manufacturer's EIN on every commercial invoice. (2) For any HTS code on the borderline between two lists, file a Binding Ruling request with CBP. (3) Where possible, source from non-China origins (Vietnam, Indonesia, Mexico) — even partial substitution can reduce the effective duty rate.
What we are doing at WanLong. We work with licensed US customs brokers to pre-classify samples, and we provide a Letter of Supply with the manufacturer's EIN and the product's HTS code on every commercial invoice. For buyers seeking USMCA-relevant routing, our partner facility in Vietnam can deliver many of the same SKUs at HTS codes outside Section 301 scope.
Source: USTR 301-0428 (2018); USTR four-year review (Sept 2024); USTR-2026-0007 (March 2026); HTSUS 2026; CBP guidance
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