U.S. Tariffs on Thailand: Reciprocal and GSP Eligibility

U.S. tariffs on Thailand imports in 2026 combine one of the highest Liberation Day IEEPA rates announced for any country (36%) with partial GSP eligibility for some product categories and active tariff pressure on Thailand’s key export sectors, hard disk drives, rubber, passenger vehicles, and processed foods. Understanding the IEEPA pause mechanics, GSP claim procedures, and sector-specific rate structures is essential for any importer with Thailand-origin supply chains.

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U.S.-Thailand Trade Snapshot in 2026

Thailand has been a significant U.S. import source since the 1980s, initially in textiles and subsequently in electronics and automotive components. The country’s tariff exposure in 2026 is significant: its 36% Liberation Day rate is among the highest announced for any country outside China, driven by its large trade surplus with the United States.

Thailand as a U.S. Trading Partner

The U.S. imported approximately $58 billion in goods from Thailand in 2024, making it approximately the 13th-largest import source. Thailand’s export profile to the U.S. is diverse: hard disk drives from Seagate and Western Digital Thailand operations, passenger vehicles assembled for export, natural rubber, tires, processed seafood, and jewelry. Our current U.S. tariff rates by country page compares Thailand’s tariff profile to other Southeast Asian exporters. The nearshoring and friendshoring strategy analysis covers Thailand’s role as an alternative to China sourcing in specific categories.

Key Import Categories from Thailand

  1. Hard disk drives and data storage (HTS Chapter 84): Seagate, Western Digital HDD assembly.
  2. Passenger vehicles (HTS Chapter 87): Toyota, Honda, Isuzu Thailand-assembled models.
  3. Rubber and tires (HTS Chapter 40): natural rubber, auto tires, technical rubber articles.
  4. Processed foods and seafood (HTS Chapter 3, 16): canned tuna, shrimp, pineapple.
  5. Jewelry and gemstones (HTS Chapter 71): silver jewelry, colored stones, gold articles.
  6. Electrical machinery and components (HTS Chapter 85): transformers, switches, wire harnesses.

Current U.S. Tariff Stack on Thailand Imports

Thailand’s tariff profile is characterized by a high IEEPA announced rate, partial GSP eligibility for certain goods, and elevated MFN base rates on apparel and footwear that stack significantly with IEEPA.

Statutory Authorities in Play

IEEPA Liberation Day (Executive Order 14257, April 2025)

Announced a 36% reciprocal rate on Thai goods, one of the highest among Southeast Asian countries. Under the 90-day pause, reduced to 10% baseline. If the pause expires, 36% reinstates. The gap between pause (10%) and post-pause (36%) is 26 percentage points, one of the largest IEEPA rate swings for any major import source country. Tracked via Federal Register.

Generalized System of Preferences (GSP)

Thailand is partially eligible for GSP benefits under the Trade Act of 1974. Some Thai product categories retain GSP duty-free access (Form A Certificate of Origin required). Others have been removed from GSP eligibility in prior USTR reviews for IP and labor standard concerns. See USTR GSP for current eligible product list.

MFN/NTR base rates

Hard disk drives (HTS 8471.70), 0% MFN. Natural rubber (HTS 4001), 0% MFN. Passenger vehicles (HTS 8703), 2.5% MFN. Rubber tires, 2.5-4.5%. Canned tuna, 12.5%. Jewelry (HTS 71), 6.5-7% MFN.

Section 232 steel and aluminum

Thai steel and aluminum face 25% and 10% respectively, applicable to relevant categories.

How the Rates Layer on a Single Entry

A Thailand-assembled Toyota Hilux pickup truck (HTS 8704.31) during the IEEPA pause:

  1. MFN base rate (trucks): 25% (U.S. “chicken tax” applies to pickups).
  2. IEEPA baseline (pause): +10%.
  3. Section 232 auto: +25%.
  4. Effective rate (during pause): 60%.

Passenger vehicles (2.5% MFN) face lower absolute rates but the same IEEPA + Section 232 stack. Hard disk drives are more favorable: 0% MFN + 10% IEEPA = 10% during pause. Our Captain tariff tracker monitors Thailand-specific rate changes across all categories.

Top Affected HTS Chapters and Sectors

Thailand’s export sectors vary significantly in their tariff exposure profile. Electronics (HDD) face manageable IEEPA-only exposure; vehicles face the compounded Section 232 + IEEPA stack; rubber and tires face moderate combined rates; and processed foods carry meaningful base MFN rates plus IEEPA.

Hard Disk Drives and Electronics (Ch 84-85)

Seagate and Western Digital operate their largest HDD assembly facilities in Thailand. U.S. data center operators, PC assemblers, and backup storage providers rely on Thailand-origin HDDs as the primary supply source for mechanical hard drive products. HDDs enter at 0% MFN; IEEPA adds 10-36% depending on pause status. For a $100M annual HDD procurement, the swing from 10% (pause) to 36% (post-pause) is $26M in additional duties. Our how to calculate U.S. tariffs guide covers electronics tariff calculation methodology.

Passenger Vehicles and Auto Parts (Ch 87)

Thailand is the largest automotive producer in Southeast Asia, with Toyota, Honda, Isuzu, and Ford all operating significant assembly operations. Thailand-assembled vehicles face Section 232 at 25% plus IEEPA, a significant stack on top of MFN rates of 2.5% (passenger cars) to 25% (light trucks/pickups). This makes Thailand-origin vehicles among the most highly tariffed in the U.S. import landscape post-2025.

Rubber and Tires (Ch 40)

Thailand is the world’s largest natural rubber producer and a major tire manufacturer. Natural rubber (HTS 4001) enters at 0% MFN; IEEPA at 10-36% applies. Pneumatic tires face MFN rates of 2.5-4.5% plus IEEPA. Combined effective rates on tires during the pause: 12.5-14.5%; post-pause: 38.5-40.5%. U.S. auto parts distributors and OEM tire buyers with Thailand-origin supply chains should model both rate scenarios.

Seafood and Processed Foods (Ch 3, 16)

Canned tuna is one of Thailand’s highest-volume exports to the U.S., Thailand processes a significant share of global tuna catch into retail canned products. Canned tuna (HTS 1604.14) faces an MFN rate of 12.5%; IEEPA adds 10-36%. Combined post-pause rate: 48.5%, dramatically increasing landed cost for private-label and branded canned tuna importers. Our trade advisory services team models seafood tariff scenarios.

GSP Eligibility for Thailand: Current Status

Thailand’s GSP status is partial and product-specific. Not all Thailand-origin goods qualify, and the program requires active origin documentation to claim.

Which Thailand Products Retain GSP Treatment

Thailand remains GSP-eligible for a subset of manufactured goods where USTR has not removed eligibility for IP or labor concerns. Eligible product categories are listed on the USTR GSP program page by HTS subheading. GSP-eligible Thai goods enter at 0% MFN; IEEPA applicability to GSP goods varies by exemption status. Check CBP GSP for current claim procedures.

How to Claim GSP on Eligible Entries

GSP claims require a Form A (Certificate of Origin) issued by Thai customs authorities, showing Thailand as the country of origin and the product as qualifying under GSP criteria. Importers claim GSP preference on the entry by entering the SPI (Special Program Indicator) “A” in the tariff classification field. Our tariff and customs duty consulting team verifies GSP eligibility by HTS subheading and prepares claim documentation.

How Importers Calculate Landed Cost on Thailand-Origin Goods

Thailand landed cost modeling requires three dimensions: IEEPA pause vs. post-pause rate, GSP eligibility check by HTS code, and Section 232 applicability for vehicles and steel. The combination of high announced IEEPA rate (36%) and significant MFN rates on vehicles and seafood creates meaningful worst-case exposure.

Worked Example

Annual procurement of $10M in Thailand-origin canned tuna (HTS 1604.14, MFN 12.5%): Pause (10% IEEPA): 22.5% effective = $2.25M duty. Post-pause (36% IEEPA): 48.5% effective = $4.85M duty. Delta: $2.6M on a single category purchase program. The Captain tariff tracker monitors Thailand-specific IEEPA status in real time. Our tariff consulting firm team provides Thailand-specific landed cost modeling.

Common Landed-Cost Pitfalls

  • Failing to model the 36% post-pause IEEPA rate on high-MFN-base categories like canned tuna and pickups.
  • Claiming GSP on products that have been removed from Thailand’s GSP eligibility list without verifying current USTR published list.
  • Overlooking the “chicken tax” 25% MFN rate on light trucks and pickup truck classifications for Thailand-assembled vehicles.
  • Missing Section 232 auto applicability on Thailand-assembled passenger vehicles and trucks.

Mitigation Strategies for Importers Sourcing from Thailand

Thailand-origin importers have limited structural mitigation tools absent an FTA, but GSP optimization, FTZ deferral, and nearshoring contingencies provide meaningful risk management.

GSP Claim Optimization

For Thailand-origin goods that retain GSP eligibility, active GSP claims reduce MFN base rates to 0%. Combined with monitoring whether IEEPA applies to GSP-eligible goods (subject to USTR exemption decisions), GSP optimization can meaningfully reduce effective rates on qualifying categories.

Nearshoring Contingencies

Thailand’s 36% post-pause IEEPA rate is high enough that diversification to Indonesia (32%), Malaysia (24%), or Vietnam (46%) on a rate basis, or to India (26%) for certain textiles and foods, may provide landed cost advantages. The nearshoring and friendshoring strategy framework structures origin-by-origin analysis for Thailand importers evaluating supply chain alternatives.

FTZ Admission for High-Volume HDD and Electronics

For high-volume HDD and electronics procurement from Thailand, Foreign Trade Zone admission defers IEEPA duty payments. Given the magnitude of the potential rate swing (10% to 36%), FTZ admission provides operational flexibility to delay withdrawal until IEEPA status is clearer, or until rate changes are reflected in pricing negotiations with domestic buyers.

Importers managing multi-origin supply chains can benchmark landed costs across our full country tariff series: European Union, Taiwan, Mexico, Brazil, Japan, South Korea, and Canada.

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Frequently Asked Questions

What is the current U.S. tariff rate on Thailand imports?

During the 90-day IEEPA pause: MFN base rate + 10%. Thailand’s announced Liberation Day rate of 36% reinstates if the pause expires. Hard disk drives face 0% MFN + 10% IEEPA = 10% (pause). Vehicles face 2.5% MFN + 25% Section 232 + 10% IEEPA = 37.5% (pause). Canned tuna faces 12.5% MFN + 10% IEEPA = 22.5% (pause). GSP-eligible products may enter at 0% MFN plus applicable IEEPA. Check the Captain tariff tracker for current HTS-level rates.

Are Thailand tariffs still in effect in 2026?

Yes. IEEPA (10% pause baseline) applies to all Thailand-origin goods. Section 232 autos (25%), steel (25%), and aluminum (10%) are active. GSP partial eligibility continues for qualifying product categories. The 36% Liberation Day rate reinstates if the 90-day pause expires without a negotiated resolution.

Which HTS chapters carry the highest U.S. tariff on Thailand-origin goods?

Highest effective rates: pickup trucks (Ch 87, “chicken tax” 25% MFN + 25% Section 232 + IEEPA); canned tuna (Ch 16, 12.5% MFN + IEEPA); tires (Ch 40, 2.5-4.5% MFN + IEEPA + Section 232 steel if applicable); jewelry (Ch 71, 6.5-7% MFN + IEEPA). Hard disk drives (Ch 84) carry the most favorable profile at 0% MFN + IEEPA only.

How does the tariff stack layer on a single entry?

MFN base rate + IEEPA (10% pause / 36% post-pause) + Section 232 (25% for autos; 25% steel; 10% aluminum) = effective rate on customs value. GSP reduces the MFN base to 0% for eligible product categories. Each layer is additive, applied to the same declared customs value.

Can I use an FTZ to defer U.S. tariffs on Thailand imports?

Yes. Foreign Trade Zones defer IEEPA and Section 232 duty payments on Thailand-origin goods. For HDD and electronics importers facing the 10% to 36% IEEPA swing risk, FTZ admission provides deferral flexibility. Goods admitted during the pause and withdrawn post-pause pay the higher rate at withdrawal, FTZ timing strategy must be actively managed.

Are Thailand tariffs eligible for drawback or refund?

IEEPA and Section 232 duties paid on Thailand-origin goods qualify for manufacturing drawback (99% recovery under 19 USC 1313) when imported goods are incorporated into exported products. For U.S. data storage companies that import Thailand-origin HDDs and export finished storage systems, manufacturing drawback programs can recover IEEPA costs on exported portions of production.

How often do U.S. tariff rates on Thailand change?

IEEPA rates have changed multiple times since April 2025, with Thailand’s 36% rate pending reinstatement if the pause expires. Section 232 TRQ rates update quarterly. GSP eligibility changes when USTR conducts annual reviews. The Captain tariff tracker provides Thailand-specific rate monitoring and alerts.

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How to Calculate U.S. Import Tariffs (Ad Valorem, Specific, Compound)

Calculating the correct tariff before a shipment arrives is one of the most valuable steps an importer can take. Errors in duty estimation lead to cash flow surprises, post-entry audits, and costly penalties. This guide explains the three main tariff calculation methods used by U.S. Customs and Border Protection (CBP), walks through the stacking of multiple duty programs, and shows how to apply them to real entries.

Why Tariff Calculation Matters in 2026

The U.S. tariff landscape has grown significantly more complex since 2018. A single entry may carry: a base Most Favored Nation (MFN) rate, a Section 232 rate on steel or aluminum content, a Section 301 rate on Chinese-origin goods, a Liberation Day IEEPA rate, and an antidumping (AD) or countervailing duty (CVD) rate from a USITC order. Missing any one of these layers understates landed cost. Working with a tariff consulting firm that models all applicable programs simultaneously reduces this risk.

Step 1: Determine the HTS Classification

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Every tariff calculation starts with the correct 10-digit Harmonized Tariff Schedule (HTS) subheading. The classification governs the applicable MFN rate, any special program rates, and eligibility for FTA preferences. Misclassification is the most common cause of duty underpayment or overpayment. CBP issues binding rulings that are legally binding for the specific importer and product and protect against penalty in post-entry audits. Classification follows the six General Rules of Interpretation (GRI) applied in sequence.

Step 2: Establish the Customs Value

All ad valorem and compound tariff calculations use the customs value as their base. The primary method is transaction value under 19 U.S.C. §1401a: the price actually paid or payable, adjusted upward for packing costs paid by the buyer, selling commissions, assists (tooling or materials provided free to the manufacturer), and royalties the buyer must pay as a condition of sale.

When transaction value is not applicable (related-party transactions, barter), CBP applies secondary methods in order: transaction value of identical goods, transaction value of similar goods, deductive value, computed value, and fall-back. Our trade advisory services team regularly assists importers in defending or optimizing their customs valuation methodology.

First Sale Valuation

Under CBP’s First Sale program, importers may use the price paid at the first arm’s-length sale in the distribution chain (the manufacturer’s sale to the middleman) rather than the higher importer-paid price. This lower base reduces the ad valorem duty and also reduces the base on which Section 301, IEEPA, and other percentage-rate programs are calculated, compounding the savings.

The Three Tariff Calculation Methods

Ad Valorem Tariffs

An ad valorem tariff is expressed as a percentage of customs value. It is the most common method in the U.S. HTS. For example, HTS 6203.42.4011 (men’s cotton denim trousers) carries a 16.6% MFN rate.

Formula: Duty = Customs Value x Ad Valorem Rate

A shipment with a $50,000 customs value owes $50,000 x 16.6% = $8,300 in MFN duty. If the goods are of Chinese origin and subject to Section 301 List 3 at 25%, that adds $12,500. Any IEEPA rate stacks further on top.

Specific Tariffs

A specific tariff is charged per unit of measure regardless of value. Examples include crude oil (5.25 cents per barrel) and avocados ($0.047 per kilogram). Specific tariffs become proportionally more burdensome when commodity prices fall.

Formula: Duty = Quantity x Specific Rate

A shipment of 10,000 kilograms of avocados at $0.047/kg owes $470 in MFN duty regardless of market price.

Compound Tariffs

Compound tariffs combine an ad valorem and a specific component, appearing in textile, footwear, and certain agricultural categories. A rubber-soled shoe upper might carry “12.5% + $0.20/pair.” Both components are calculated on the same entry and summed.

Formula: Duty = (Customs Value x Ad Valorem Rate) + (Quantity x Specific Rate)

Stacking Multiple Tariff Programs

A 2026 import entry from China may carry four or more concurrent tariff programs. The calculation follows this sequence:

  1. Determine the MFN rate from the HTS 10-digit subheading.
  2. Check Section 232 applicability: steel (Ch. 72-73, 25%), aluminum (Ch. 76, 10%), copper (Ch. 74, 25%), or autos (Ch. 87 specified headings, 25%).
  3. Check Section 301 applicability: if origin is China, identify the List (1-4A) and applicable rate.
  4. Check IEEPA Liberation Day rate: 10% Annex I for most countries, or the applicable Annex II country rate (145% for China as of mid-2026).
  5. Check AD/CVD orders: search the CBP AD/CVD search tool and ITA Enforcement and Compliance database.
  6. Check FTA preferential rate: USMCA, KORUS, etc. reduce or eliminate the MFN layer only — they do not offset Section 232, 301, or IEEPA.

The Captain tariff tracker automates this multi-program calculation for any HTS code and country of origin combination.

Worked Example: Steel Pipe Fitting from China

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Product: Steel pipe fitting, HTS 7307.93.9000, origin China, customs value $100,000.

Program Rate Duty on $100,000
MFN (ad valorem) 4.3% $4,300
Section 232 (steel articles) 25% $25,000
Section 301 List 3 (China) 25% $25,000
IEEPA Liberation Day (China) 145% $145,000
Total duty 199.3% $199,300

The combined effective rate of 199.3% makes this product economically unimportable from China at most market prices. This type of analysis drives sourcing diversion to alternative countries. For context on current rates by country, see our current U.S. tariff rates by country reference.

Post-Entry Duty Recovery

Importers who overpay duties have recovery options. The duty drawback program allows refund of duties paid on imported goods that are subsequently exported or destroyed. IEEPA-specific mechanisms are addressed in our guide on IEEPA tariff refunds. Protests filed within 90 days of CBP liquidation can contest the classification, value, or applicable rate.

Frequently Asked Questions

What is an ad valorem tariff?

An ad valorem tariff is a duty expressed as a percentage of the customs value of imported goods. It is the most common tariff type in the U.S. HTS. The duty equals the customs value multiplied by the applicable rate.

What is the difference between a specific and compound tariff?

A specific tariff is charged per unit of measure (for example, $0.05 per kilogram) regardless of value. A compound tariff combines a percentage component and a per-unit component; both are calculated and summed for the total duty owed.

How is customs value determined?

The primary method is transaction value: the price paid or payable for the goods when sold for export to the United States, adjusted for additions such as packing, assists, royalties, and proceeds of resale under 19 U.S.C. §1401a.

Can multiple tariff programs apply to the same shipment?

Yes. A single entry from China may carry an MFN rate, Section 232, Section 301, IEEPA Liberation Day, and AD/CVD rates simultaneously. All applicable rates are calculated on the same customs value and summed; there is no offsetting between programs.

What is First Sale valuation and how does it reduce duties?

First Sale allows an importer to declare the factory sale price (the first arm’s-length sale in the chain) as the customs value rather than the higher importer-paid price. Because most tariff programs are ad valorem percentages calculated on customs value, a lower value base reduces the total duty owed across all stacked programs.

What is a binding ruling and why do I need one?

A CBP binding ruling is a written decision committing CBP to a specific HTS classification for a particular importer and product. It provides certainty before importation and protects against penalty in post-entry audits. Submit requests through the CBP Ruling Request program with full product description and supporting technical documentation.

How do I challenge a CBP duty assessment?

File a protest with CBP within 180 days of the date of liquidation (finalization) of the entry. The protest can contest the classification, value, applicable rate, or any other matter affecting the amount of duty. If CBP denies the protest, appeal to the Court of International Trade.

Get Precise Tariff Analysis for Your Import Program

Tariff calculation errors compound at scale. A 1% misclassification on a $10 million annual import program means $100,000 in mismeasured duty exposure. Our tariff consulting team provides HTS classification reviews, tariff stacking analysis, and customs value optimization. Trade advisory services from CargoTrans are available for importers at every volume level.

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U.S. Tariffs on Brazil: Steel Quotas and Reciprocal Rate

U.S. tariffs on Brazil imports in 2026 are anchored by Section 232 steel tariffs administered through a Tariff Rate Quota system, a structure that gives Brazil an allocated volume of steel exports at 0% before the 25% over-quota rate applies, combined with the IEEPA Liberation Day baseline rate. Brazil is a top-fifteen U.S. import source with a concentrated export profile in steel, agricultural commodities, aircraft, and petroleum. This guide covers every applicable tariff authority and the operational strategies importers use to manage Brazil-origin tariff exposure.

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U.S.-Brazil Trade Snapshot in 2026

Brazil’s trade relationship with the United States is shaped by its position as the world’s leading exporter of soybeans, sugar, coffee, and orange juice, and as a major global steel producer. U.S. tariff exposure for Brazil-origin goods is concentrated in steel, where Section 232 TRQ mechanics matter significantly, and in agricultural commodities, where MFN and IEEPA baseline rates apply.

Brazil as a U.S. Trading Partner

The U.S. imported approximately $38 billion in goods from Brazil in 2024, making it approximately the 12th-largest import source. Brazil’s export mix to the U.S. is commodity-heavy: semi-finished steel slabs (the single largest Brazil export to the U.S.), soybeans, crude oil, aircraft (Embraer), coffee, and iron ore dominate the trade flow. Unlike China or the EU, Brazil does not face a high announced IEEPA rate, its Liberation Day rate of 10% is at the universal baseline, reflecting a relatively smaller bilateral trade surplus. Our current U.S. tariff rates by country page provides context.

Key Import Categories from Brazil

  1. Semi-finished steel and steel mill products (HTS Chapter 72): slabs, billets, hot-rolled coil.
  2. Iron ore and ferroalloys (HTS Chapter 26): iron ore pellets, ferrosilicon, ferrochrome.
  3. Soybeans and agricultural commodities (HTS Chapter 12): soybeans, cotton, tobacco.
  4. Aircraft and aerospace components (HTS Chapter 88): Embraer regional jets, aircraft parts.
  5. Coffee (HTS Chapter 9): green coffee, roasted coffee, instant coffee.
  6. Crude oil and petroleum products (HTS Chapter 27).

Current U.S. Tariff Stack on Brazil Imports

Brazil’s tariff profile is defined by the Section 232 steel TRQ, which creates a quarterly quota fill dynamic, combined with IEEPA at the 10% baseline rate that affects all categories.

Statutory Authorities in Play

IEEPA Liberation Day (Executive Order 14257, April 2025)

Brazil’s announced reciprocal rate was 10%, the universal baseline rate, not an elevated country-specific rate. This means Brazil faces the same IEEPA rate as the 90-day pause rate: 10% on all goods unless specifically exempted. Verified via Federal Register.

Section 232 steel (Trade Expansion Act §232)

  • Brazil operates under a quarterly Tariff Rate Quota for steel. Within-quota steel enters at 0%.
  • Over-quota steel faces 25%. Brazil’s TRQ is one of the most actively managed in the Section 232 program because semi-finished steel slabs (a Brazil specialty) are critically needed by U.S. steel mills that lack sufficient domestic slab production. Monitor the CBP steel TRQ fill rates quarterly, when the TRQ fills, the rate jumps from 0% to 25% mid-quarter.

Section 232 aluminum (10%)

Brazilian aluminum face 10% Section 232. Brazil is a significant aluminum producer.

MFN/NTR base rates

Soybeans enter at 0% MFN. Coffee at 0% MFN. Aircraft at 0% MFN (HTS 88.02). Steel at 0-5% MFN depending on product form.

How the Rates Layer on a Single Entry

Brazil-origin semi-finished steel slabs (HTS 7207.12) imported within the quarterly TRQ:

  1. MFN base rate: 0%.
  2. Section 232 (within TRQ): 0%.
  3. IEEPA baseline: +10%.
  4. Effective rate (within TRQ): 10%.

The same slabs imported after the quarterly TRQ fills:

  1. MFN base rate: 0%.
  2. Section 232 (over TRQ): +25%.
  3. IEEPA baseline: +10%.
  4. Effective rate (over TRQ): 35%.

The TRQ fill date is therefore the pivotal operational variable for Brazil steel importers. Our Captain tariff tracker monitors Brazil TRQ fill status in real time.

Top Affected HTS Chapters and Sectors

Brazil’s tariff exposure concentrates in steel (Section 232 TRQ) and agricultural commodities (IEEPA baseline), with aircraft representing a high-value category that enters at low effective rates.

Semi-Finished Steel and Steel Mill Products (Ch 72-73)

Brazil is the primary global supplier of semi-finished steel slabs to U.S. integrated steel mills that use slabs as feedstock for rolling operations. Companies like Nucor, ArcelorMittal USA, and Cleveland-Cliffs import Brazil-origin slabs to supplement domestic slab production. Section 232 TRQ mechanics make slab import planning extremely time-sensitive: quota exhaustion mid-quarter can shift a $200/ton landed cost advantage to a $50/ton disadvantage overnight when the over-quota rate kicks in. Our steel and aluminum tariffs guide covers Section 232 TRQ mechanics. Our Section 232 tariffs analysis covers the exclusion petition process for over-quota situations.

Iron Ore and Ferroalloys (Ch 26, 72)

Brazil’s Vale is the world’s largest iron ore producer. U.S. steel mills that operate blast furnace operations (increasingly rare but still active) import Brazil-origin iron ore and pellets. Iron ore itself carries 0% MFN and may be exempted from IEEPA, importers should verify current exemption status. Ferroalloys (ferrosilicon, ferrochrome, ferromanganese) face MFN rates of 1.5-5% plus IEEPA baseline.

Soybeans and Agricultural Commodities (Ch 12)

Brazil is the world’s largest soybean exporter and competes directly with U.S. soybeans in global markets. U.S. imports of Brazil soybeans are rare (the U.S. is an exporter). However, Brazilian soy-derived products, soybean oil (Ch 15), soy protein concentrates (Ch 23), do enter the U.S. and face IEEPA baseline plus MFN rates of 0-7.9%. Coffee (Ch 9) enters at 0% MFN, the U.S. does not produce coffee and applies no MFN duty to coffee imports. IEEPA baseline at 10% applies unless a coffee-specific exemption is in effect.

Aircraft and Aerospace Components (Ch 88)

Embraer is Brazil’s most high-value U.S. export by per-unit value, E175 and E190 regional jets sold to U.S. airlines like American Eagle, SkyWest, and Envoy face 0% MFN. IEEPA 10% baseline applies unless aircraft are specifically exempted. For a $25 million Embraer E175, a 10% IEEPA duty represents $2.5 million in additional cost per aircraft, a significant purchase price increment for regional aviation economics. Embraer and U.S. airlines have been active in seeking IEEPA aircraft exemptions through USTR and Commerce channels.

Section 232 Steel TRQ System: How Brazil’s Quota Works

The Brazil Section 232 steel TRQ is unlike any other bilateral trade arrangement in the U.S. tariff system. Understanding the quarterly quota mechanics is essential for Brazil steel importers.

Brazil’s Quarterly Quota Allocation

Brazil’s steel TRQ is allocated quarterly based on historical import volumes. The quarterly allocation is published by CBP at the start of each quarter. When cumulative Brazil steel entries reach the quarterly quota, CBP switches to collecting the 25% over-quota deposit on subsequent entries. Importers must track CBP quota utilization daily during the final weeks of each quarter to time shipment arrivals appropriately. Early-quarter arrivals secure within-quota rates; late-quarter arrivals risk over-quota exposure.

Over-Quota Penalty Rate

The over-quota rate of 25% Section 232 + 10% IEEPA = 35% effective rate on customs value. For a $1,000,000 CIF slab entry, the cost delta between within-quota (10% IEEPA = $100,000) and over-quota (35% = $350,000) is $250,000. Shipment timing strategy, including vessel routing, arrival port selection, and customs entry filing timing, can determine which quota applies to a given shipment. Our tariff consulting firm team advises on TRQ timing strategy for Brazil steel importers.

How Importers Calculate Landed Cost on Brazil-Origin Goods

Brazil landed cost modeling requires two scenarios for steel: within-TRQ (0% Section 232 + 10% IEEPA = 10%) and over-TRQ (25% Section 232 + 10% IEEPA = 35%). For agricultural and aircraft imports, the analysis is IEEPA baseline plus MFN.

Worked Example

A Brazilian steel slab purchase: $500,000 CIF, within quarterly TRQ = $50,000 duty (10%). Same purchase, TRQ exhausted = $175,000 duty (35%). Our Captain tariff tracker and tariff and customs duty consulting team model TRQ timing scenarios and monitor CBP utilization reports for Brazil steel importers.

Common Landed-Cost Pitfalls

  • Not monitoring CBP TRQ fill status weekly during the final month of each quarter.
  • Assuming aircraft imports are IEEPA-exempt without verifying current exemption status.
  • Forgetting that IEEPA 10% applies even within the Section 232 TRQ window for steel.
  • Overlooking Section 232 aluminum (10%) on Brazilian aluminum products, Brazil has significant aluminum smelting capacity.

Mitigation Strategies for Importers Sourcing from Brazil

Brazil-origin importers have several targeted mitigation tools, especially in the steel sector where Section 232 TRQ management and the exclusion process provide structured relief pathways.

TRQ Quota Management and Shipment Timing

The primary mitigation tool for Brazil steel importers is within-TRQ shipment scheduling. Working with logistics providers to time vessel arrivals and customs entry filings within the quota window reduces Section 232 exposure from 25% to 0%. Our trade advisory services team provides TRQ monitoring and shipment timing advisory for Brazil steel programs.

Section 232 Exclusion Process

For specific Brazil-origin steel products not covered by the TRQ or for over-quota situations, the Section 232 tariffs exclusion process provides product-specific relief. Brazil slab has historically received exclusion support given the structural shortage of U.S. domestic slab production, U.S. steel mills have successfully argued that Brazil slabs are not domestically available in sufficient quantity.

First Sale for Export

For Brazil imports transacting through commodity trading intermediaries, First Sale for Export reduces the dutiable value to the producer’s mill price rather than the trader’s selling price. For steel slab purchases through steel trading companies, First Sale can reduce the duty base by 5-15%.

Importers managing multi-origin supply chains can benchmark landed costs across our full country tariff series: Thailand, Malaysia, Mexico, Taiwan, Indonesia, Japan, South Korea, Vietnam, Canada, and India.

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Frequently Asked Questions

What is the current U.S. tariff rate on Brazil imports?

Brazil-origin goods face a 10% IEEPA baseline rate (Brazil’s Liberation Day announced rate was 10%, the universal baseline). Steel imports face Section 232 TRQ mechanics: 0% within-quota + 10% IEEPA = 10% effective; 25% over-quota + 10% IEEPA = 35% effective. Aluminum faces 10% Section 232 + 10% IEEPA = 20%. Agricultural commodities (soybeans, coffee) and aircraft carry 0% MFN + 10% IEEPA unless specifically exempted. Use the Captain tariff tracker for current rates.

Are Brazil tariffs still in effect in 2026?

Yes. IEEPA (10% baseline) applies to all Brazil-origin goods unless specifically exempted. Section 232 steel TRQ and the 25% over-quota rate are active. Section 232 aluminum (10%) is active. There is no U.S.-Brazil FTA providing preferential duty rates.

Which HTS chapters carry the highest U.S. tariff on Brazil-origin goods?

Highest effective rates: steel (Ch 72-73) at 35% when over-quota (25% Section 232 + 10% IEEPA); aluminum (Ch 76) at 20% (10% Section 232 + 10% IEEPA). Agricultural commodities (Ch 9, 12) and aircraft (Ch 88) face only the 10% IEEPA baseline plus any applicable MFN rate, generally 0-7% MFN depending on specific product.

How does the tariff stack layer on a single entry?

For steel within TRQ: 0% Section 232 + 10% IEEPA = 10%. For steel over TRQ: 25% Section 232 + 10% IEEPA = 35%. For aluminum: 10% Section 232 + 10% IEEPA = 20%. For other goods: MFN base rate + 10% IEEPA = effective rate. Each percentage applies additively to the same declared customs value.

Can I use an FTZ to defer U.S. tariffs on Brazil imports?

Yes. Foreign Trade Zones defer Section 232 and IEEPA duty payments until goods are withdrawn for U.S. consumption. For steel slab importers facing TRQ uncertainty, FTZ admission can provide operational flexibility, but the rate paid at withdrawal reflects the rate in effect at withdrawal, not admission. If goods are admitted within TRQ and the next quarter’s TRQ fills before withdrawal, over-quota rates do not retroactively apply to previously admitted goods.

Are Brazil tariffs eligible for drawback or refund?

Section 232 and IEEPA duties paid on Brazil-origin steel qualify for manufacturing drawback (99% recovery under 19 USC 1313) when U.S. steel mills produce finished steel products incorporating Brazil-origin slabs and export those products. For U.S. steel producers with active export programs, manufacturing drawback on Brazil-origin slab inputs is one of the most valuable drawback categories in the U.S. steel industry.

How often do U.S. tariff rates on Brazil change?

The Section 232 steel TRQ allocation changes quarterly. IEEPA rates are set by executive order and can change with limited advance notice. Section 232 exclusion petition outcomes can change the applicable rate for specific products. The Captain tariff tracker monitors Brazil TRQ fill rates and IEEPA changes in real time.

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Current U.S. Tariff Rates by Country (Live Table)

Tracking effective U.S. import tariff rates by country of origin is one of the most operationally demanding tasks for compliance teams in 2026. The base Most Favored Nation (MFN) rate, Section 232 and Section 301 programs, the Liberation Day IEEPA framework, and active antidumping and countervailing duty (AD/CVD) orders all contribute to a rapidly shifting composite rate. This page explains how the rate structure works and provides a country-by-country summary of key programs and current exposure levels.

How U.S. Tariff Rates Work by Country of Origin

U.S. tariff rates are product-specific first and country-specific second. The same HTS subheading may carry a zero rate under a free trade agreement for one country, a 25% Section 301 rate for Chinese-origin goods, and a 10% Liberation Day baseline for most others. The composite effective tariff rate is the sum of all applicable programs, not a choice between them.

Layer 1: MFN Base Rate

The MFN base rate from the Harmonized Tariff Schedule applies to all WTO members and other countries on the U.S. normal trade relations list. Rates range from zero for many technology products and raw materials to over 30% for certain apparel, footwear, and sugar products. This is the starting point for any tariff calculation. The authoritative published schedule is maintained by the U.S. International Trade Commission (USITC) at the HTS Online database.

Layer 2: Preferential (FTA) Rates

Goods qualifying for originating status under a U.S. free trade agreement receive a reduced or zero MFN rate. Active U.S. FTAs include USMCA (Canada and Mexico), KORUS (South Korea), the U.S.-Japan Trade Agreement 2020, and agreements with Singapore, Australia, Chile, Colombia, Peru, and several others. Preferential rates reduce only the MFN component; they do not offset Section 232, Section 301, or IEEPA tariffs, which are imposed under separate statutes.

Layer 3: Remedial Tariffs (232, 301, IEEPA)

These programs represent the most significant tariff exposure for most importers in 2026:

  • Section 232: 25% on steel articles (Chapters 72-73), 10% on aluminum (Chapter 76), 25% on copper (Chapter 74), and 25% on autos and auto parts (Chapter 87 specified headings). Country-specific TRQ arrangements exempt quota volumes for certain allies.
  • Section 301: Applies only to Chinese-origin goods at rates from 7.5% to 25%+ depending on the applicable List.
  • IEEPA Liberation Day: 10% baseline (Annex I) on imports from nearly all countries, with country-specific rates (Annex II) for major deficit partners. China currently faces 145% under IEEPA.

Layer 4: AD/CVD Orders

Antidumping and countervailing duty orders are product and country-specific and can carry rates well above 100%. Active orders cover a wide range of Chinese, Vietnamese, Indian, and other origin goods in solar, steel, seafood, and other categories. Rates vary by manufacturer within the same country. The CBP AD/CVD search tool and the ITA Enforcement and Compliance database are the authoritative sources for current cash deposit rates.

Current Tariff Exposure by Major Trading Partner

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The summary below reflects the primary tariff programs as of mid-2026. For product-specific exact rates, use the Captain tariff tracker.

China

China faces the most complex tariff stack available. MFN rates apply at the product level. Section 301 rates of 7.5% to 25%+ apply across virtually all categories. The IEEPA Liberation Day rate on Chinese goods reached 145% by May 2025. Combined effective rates on many manufactured goods exceed 150%, making Chinese sourcing economically prohibitive for large product categories. Understanding Section 301 tariffs on China is foundational to any China supply chain analysis. The Liberation Day tariff framework adds further layers that interact with Section 301.

Our complete guide to U.S. tariffs on China covers every statutory authority, the current rate stack, and step-by-step mitigation strategies.

Canada

Canada benefits from USMCA zero rates on most qualifying originating goods. Section 232 TRQs apply to steel and aluminum: volumes within the annual quota face zero Section 232, while above-quota volumes face 25%. The Liberation Day 10% baseline applies to non-USMCA-qualifying Canadian goods. Transshipment enforcement has increased scrutiny of Canadian entries containing Chinese-origin inputs that do not meet USMCA rules of origin.

See the U.S. tariffs on Canada guide for a full breakdown of USMCA eligibility, Section 232 TRQ mechanics, and the Liberation Day framework.

Mexico

Mexico mirrors Canada under USMCA for qualifying goods. Section 232 TRQs apply to steel and aluminum similarly. A significant enforcement priority in 2025-2026 has been Chinese-origin goods transshipped through Mexico without undergoing substantial transformation, which are subject to the full Chinese tariff stack regardless of the Mexican point of export.

Our U.S. tariffs on Mexico guide details USMCA qualification requirements, the executive orders on fentanyl, and nearshoring considerations.

European Union

EU goods were assigned a 20% Liberation Day Annex II rate, paused at 10% as of April 9, 2025. Section 232 steel and aluminum tariffs apply at 25% on volumes outside TRQs. No FTA between the U.S. and EU currently exists (the TTIP negotiations concluded without agreement). The rate trajectory for EU goods depends on bilateral trade deal progress throughout 2026.

The U.S. tariffs on EU guide covers Section 232 steel and aluminum, the Liberation Day rate trajectory, and sector-by-sector exposure for European exporters.

Vietnam

Vietnam was assigned the highest Annex II rate of any major trading partner: 46%, paused at 10% during negotiations. Active AD/CVD orders cover Vietnamese solar panels, steel, catfish, and shrimp. Vietnam has been the primary China-plus-one beneficiary since 2018; the high Annex II rate and active AD/CVD coverage mean that alternative sourcing to Vietnam requires careful tariff modeling before commitment. See our analysis of the China-Plus-One strategy for how Vietnam compares with other alternatives.

Our U.S. tariffs on Vietnam guide covers the 46% reciprocal rate, active AD/CVD orders, and circumvention risk for importers sourcing through Vietnamese factories.

India

India was assigned a 26% Annex II rate under Liberation Day, paused at 10%. A preliminary bilateral deal framework announced in early 2026 may reduce this rate. Section 232 applies to Indian steel and aluminum. India has no FTA with the United States. Active AD/CVD orders cover certain Indian steel and chemical products.

The U.S. tariffs on India guide provides a full breakdown of the 26% Annex II rate, the preliminary bilateral framework, and Section 232 exposure for Indian steel and aluminum.

Japan

Japan was assigned a 24% Annex II rate, paused at 10%. The U.S.-Japan Trade Agreement 2020 provides preferential rates on certain agricultural and industrial goods at the MFN layer but does not offset Section 232 or IEEPA. Section 232 TRQs apply to Japanese steel under the 2022 arrangement.

Our U.S. tariffs on Japan guide covers the 24% Annex II rate, U.S.-Japan Trade Agreement 2020 preferences, and Section 232 steel TRQ mechanics.

South Korea

South Korea faces a 25% Annex II rate (paused at 10%) plus Section 232 for steel quantities above the KORUS TRQ. The KORUS FTA provides MFN-layer preferences on many manufactured goods. South Korean auto exports to the U.S. face the new Section 232 auto tariff for non-USMCA qualifying content.

The U.S. tariffs on South Korea guide details KORUS FTA eligibility, Section 232 steel TRQ mechanics, and auto tariff exposure for Korean-assembled vehicles.

Taiwan

Taiwan was assigned a 32% Annex II rate under Liberation Day, paused at 10% during negotiations. Taiwan is the dominant global source for advanced semiconductors. A Section 232 investigation targeting semiconductor imports directly raises the stakes for Taiwanese chipmakers and their U.S. buyers. No U.S.-Taiwan FTA exists. The U.S. tariffs on Taiwan guide covers the semiconductor Section 232 risk, the reciprocal rate structure, and compliance considerations for tech importers.

Brazil

Brazil was assigned a 10% Annex II rate under Liberation Day. Section 232 steel TRQs apply to Brazilian flat-rolled and semi-finished steel exports within historical quota volumes; above-quota volumes face 25%. Brazil also faces Section 201 safeguard tariffs on certain steel and solar products. Active AD/CVD orders cover Brazilian citric acid and certain steel products. See the U.S. tariffs on Brazil guide for a full breakdown of the Section 232 TRQ mechanics and GSP eligibility status.

Thailand

Thailand was assigned a 36% Annex II rate under Liberation Day, paused at 10% during negotiations. Thailand relies heavily on exports of hard disk drives, rubber, seafood, and automotive parts to the U.S. market. Partial GSP eligibility has historically reduced MFN rates on certain Thai goods, though the current GSP status requires verification. Our U.S. tariffs on Thailand guide covers the reciprocal rate framework, GSP eligibility categories, and affected HTS sectors.

Indonesia

Indonesia was assigned a 32% Annex II rate, paused at 10%. Indonesia’s primary U.S. exports include apparel, footwear, rubber, and seafood. GSP partial eligibility applies to select categories. Active AD/CVD orders cover certain Indonesian steel and biodiesel products. The U.S. tariffs on Indonesia guide covers the full reciprocal rate structure, GSP eligibility, and sector-specific tariff exposure.

Malaysia

Malaysia was assigned a 24% Annex II rate, paused at 10%. Malaysia is a major semiconductor packaging and assembly hub, particularly in Penang. A Section 232 investigation targeting semiconductor imports creates direct exposure for Malaysian chip packaging facilities. No U.S.-Malaysia FTA is in force. Our U.S. tariffs on Malaysia guide covers the semiconductor Section 232 risk, the reciprocal rate, and supply chain implications for tech importers.

How to Find the Current Rate for a Specific Product

No static reference remains accurate for long in the current environment. The most reliable verification sequence is:

  1. USITC HTS Online: authoritative MFN rate and any FTA column rates for the 10-digit HTS subheading.
  2. CBP ACE portal: shows all applicable rates and programs for a specific HTS/origin entry.
  3. Federal Register: all IEEPA proclamations and Section 232/301 actions are published here by Federal Register number.
  4. ITA Enforcement and Compliance: current AD/CVD cash deposit rates by manufacturer and country of origin.
  5. Captain tariff tracker: our daily-updated tracker aggregates all four sources into a single lookup for any HTS and origin combination.

Factoring Tariffs Into Total Cost of Ownership

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Procurement teams increasingly model tariff exposure as a core component of total cost of ownership alongside unit cost, lead time, quality, and logistics. At combined effective rates above 50%, the economics of alternative sourcing often become compelling even when factory prices in alternative countries are 20-30% higher.

Our trade advisory services team builds total cost models that incorporate all tariff layers, logistics differentials, FTZ and First Sale optimization, and drawback potential to produce fully loaded landed cost comparisons across sourcing scenarios. For importers currently weighing China versus Vietnam versus India alternatives, a tariff consulting engagement typically covers current effective rates, expected rate trajectory, qualifying rules of origin, and AD/CVD risk in each candidate country.

Frequently Asked Questions

Where can I find the current U.S. tariff rate for my product?

The USITC HTS Online gives the published MFN rate. CBP’s ACE portal shows the combined duty for an entry. The Federal Register is authoritative for IEEPA, Section 232, and Section 301 program rates. The ITA database covers AD/CVD. Our Captain tariff tracker aggregates all of these for quick product-level lookup.

What is the effective tariff rate on Chinese imports in 2026?

The effective rate varies by product but typically comprises MFN (product-specific), Section 301 (7.5% to 25%+), and IEEPA Liberation Day (145% as of mid-2026), plus any AD/CVD order rates. Combined effective rates on many manufactured goods from China exceed 150%.

Does USMCA eliminate all tariffs from Canada and Mexico?

USMCA eliminates MFN duties on qualifying originating goods but does not eliminate Section 232 steel and aluminum tariffs (which apply under a separate TRQ structure) or Liberation Day IEEPA tariffs on non-qualifying goods. Chinese-origin content transshipped without substantial transformation does not qualify for USMCA treatment.

Why does Vietnam have a 46% tariff rate?

Vietnam was assigned a 46% reciprocal rate under Liberation Day Annex II based on USTR’s trade deficit formula. This rate is paused at 10% during bilateral negotiations, but the 46% remains the scheduled rate if negotiations fail. The high rate reflects the large bilateral trade deficit the U.S. runs with Vietnam.

Do FTA preferential rates offset Section 232 tariffs?

No. FTA rates reduce or eliminate only the MFN component. Section 232 is imposed under the Trade Expansion Act of 1962, a separate legal authority. A Canadian steel product that is zero-rated under USMCA for its MFN duty still owes Section 232 on volumes above the TRQ threshold.

How often do U.S. tariff rates change?

MFN rates change rarely. Remedial tariff rates change frequently: Section 232 exclusions are updated quarterly, Section 301 exclusions have expiration dates, and IEEPA rates have been modified multiple times throughout 2025-2026. AD/CVD rates change at each annual review. Daily monitoring of Federal Register and CBP publications is necessary for import programs with ongoing exposure.

Stay Current on Tariff Rates

In a tariff environment that changes daily, static references decay quickly. Our Captain tariff tracker and trade advisory team provide real-time rate monitoring and alerts for importers with ongoing exposure across multiple programs and countries of origin.

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Section 232 Tariffs: Steel, Aluminum, Copper and Auto Duties Explained

Section 232 tariffs are import duties authorized by the Trade Expansion Act of 1962 when the U.S. Department of Commerce determines that imports threaten national security. The program covers steel, aluminum, copper, and autos. Rates run from 25% to 50% depending on the product and country of origin. For U.S. importers, these duties stack on top of Section 301 and Reciprocal Tariff Act rates, compounding landed cost pressure across multiple supply chains.

Under 19 USC §1862, the president can impose duties or quotas after a DOC investigation concludes that import volumes endanger domestic industrial capacity. The Bureau of Industry and Security (BIS) within the DOC administers the program and publishes all actions in the Federal Register.

Which Products Fall Under Section 232 in 2026

Section 232 coverage has expanded significantly since 2018. The four active product categories are below.

Steel and Steel Derivatives (HTS Chapter 72, 73)

A 25% tariff on steel mill products took effect March 23, 2018 (Proclamation 9705). HTS Chapters 72 and 73 cover hot-rolled coil, cold-rolled sheet, structural beams, pipes, tubes, and fabricated steel products. Several countries negotiated quota agreements in exchange for tariff exemptions. Those exemptions have been narrowed or eliminated for most trading partners in 2026. Work the steel and aluminum tariffs guide for current country-specific rates.

Aluminum and Aluminum Derivatives (HTS Chapter 76)

Aluminum entered the Section 232 program at 10% in March 2018 (Proclamation 9704). The rate was raised to 25% for most countries in 2026. HTS Chapter 76 covers primary aluminum, alloyed aluminum, plates, sheets, foil, tubes, and pipes. Derivative products (parts made primarily from aluminum) are also covered.

Copper and Copper-Intensive Products (HTS Chapter 74)

A 50% Section 232 tariff on copper was announced in 2026. HTS Chapter 74 covers refined copper, copper alloys, wire, rods, plates, and tubes. This is the highest Section 232 rate applied to any commodity. Importers sourcing copper wire, bus bars, or heat exchangers should recalculate landed costs immediately. Review the full copper tariff breakdown for HTS-level detail.

Autos and Auto Parts (HTS Chapter 87)

A 25% tariff on passenger vehicles and auto parts took effect in 2026. HTS Chapter 87 covers passenger cars, light trucks, and a defined list of auto parts. The parts list includes engines, transmissions, body stampings, axles, and suspension components. Vehicles qualifying under USMCA are subject to different treatment depending on regional content percentages.

Current Section 232 Rates and Duty Stacking

The table below shows the active Section 232 rates as of 2026:

  • Steel: 25% (most countries); higher for certain steel derivative products
  • Aluminum: 25% (most countries)
  • Copper: 50%
  • Autos and auto parts: 25%

Section 232 duties are additive. An importer bringing in Chinese steel pays the Section 232 steel duty (25%) plus Section 301 list duties (if the HTS code appears on a Section 301 list) plus the Reciprocal Tariff Act rate (145% for China). The combined rate can exceed 170% on affected steel products. Use the Captain tariff tracker to calculate stacked duties by HTS code and country of origin before each purchase order.

How the Section 232 Exclusion Process Works

BIS operates the Section 232 exclusion portal under 15 CFR Part 705. Importers, manufacturers, and other interested parties can request product-specific exclusions. An approved exclusion lets a named company import a defined product at zero Section 232 duty.

Eligibility Criteria

To qualify, the requester must show that the product is not produced in the U.S. in sufficient quantities, not produced in adequate quality, or not available in a timely manner from domestic sources. The request must identify the specific HTS subheading and describe the product in technical terms that match the actual import.

BIS Exclusion Portal Walkthrough

File the exclusion request through the BIS Section 232 exclusion portal. The submission requires a company profile, product description, quantity requested, domestic supplier objection process, and supporting documentation. After submission, domestic steel or aluminum producers can file objections within 30 days. BIS adjudicates the record and issues a determination published in the Federal Register. The USITC provides data support for BIS on many requests.

Common Rejection Reasons

BIS rejects exclusion requests when domestic availability is not adequately disproven, when the product description does not precisely match the HTS subheading, or when a domestic producer successfully objects with capacity evidence. Requests without specific mill certifications or technical specs are also frequently denied.

Section 232 vs Section 301 vs Section 122

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These three tariff authorities overlap but have different legal bases and triggers.

  • Section 232: National security threat to domestic industry. No expiration. Applies globally with country-specific carveouts. BIS administers.
  • Section 301: Unfair trade practices by a foreign government. China-specific in current application. USTR administers. See the full Section 301 tariffs on China analysis for list-by-list breakdowns.
  • Section 122: Balance-of-payments emergency. Maximum 15% rate. Maximum 150-day duration. Has not been used as a comprehensive surcharge in modern trade history.

The Reciprocal Tariff Act adds a fourth layer based on bilateral trade deficits. All four programs can apply simultaneously to a single shipment. The Trump tariff tracker shows live stacked rates for your HTS codes across all four authorities.

How Importers Reduce Section 232 Exposure

Three mechanisms reduce or defer Section 232 duties without changing the HTS classification:

  1. Foreign-Trade Zone (FTZ): Goods admitted to an FTZ before a rate proclamation takes effect enter at the pre-proclamation rate. FTZs also eliminate duties on goods re-exported without entering U.S. commerce.
  2. Customs bonded warehouse: Duties are deferred until withdrawal for consumption. If a rate drops or an exclusion is granted, the importer can withdraw at the lower rate.
  3. Section 232 exclusion: Company-specific exclusions eliminate the duty entirely for approved products and quantities.

A tariff consulting firm can identify which mechanism applies to your product and model the savings against setup costs. The trade advisory services team runs the landed cost comparison across all three options before recommending a strategy.

Frequently Asked Questions

Are Section 232 tariffs still active in 2026?

Yes. Section 232 tariffs on steel and aluminum remain fully active in 2026. Copper and auto parts were added in 2026. No sunset date applies. Congress can modify the program through legislation, but the executive orders implementing current rates remain in force.

What is the current Section 232 tariff rate on steel?

The base rate is 25% for most countries. Some country-specific agreements set different rates or quotas. Check the Federal Register for the most recent proclamation applying to your supplier’s country of origin.

Can I file a Section 232 exclusion request as an importer?

Yes. Importers, manufacturers, and purchasers of steel and aluminum products can file exclusion requests through the BIS Section 232 exclusion portal. The process requires product-specific documentation and a showing that domestic supply is insufficient.

Do Section 232 tariffs stack with Section 301 China tariffs?

Yes. If a Chinese steel product appears on a Section 301 list, both the Section 232 rate and the Section 301 rate apply. The Reciprocal Tariff Act rate also stacks. All three are cumulative on top of the base HTSUS Column 1 duty.

Is there a Section 232 refund mechanism?

There is no standalone refund program for Section 232 duties. However, Section 232 duties are generally eligible for duty drawback under 19 USC §1313, meaning importers who re-export finished goods can recover up to 99% of duties paid on the imported inputs.

What HTS codes are covered by Section 232 copper?

Section 232 copper covers HTS Chapter 74, which includes refined copper (7401-7403), copper alloys (7403-7407), copper plates, sheets, strip, and foil (7409-7410), copper tubes and pipes (7411), and copper wire (7408). Check the specific proclamation for the exact HTS subheadings covered.

How long does a Section 232 exclusion request take?

BIS targets 90 days for a determination, but complex requests with objections from domestic producers can take 6-12 months. Plan procurement timelines accordingly. An approved exclusion is retroactive to the date of filing, so duties paid during the review period can be recovered.

Section 232 exposure is predictable when you map it by HTS code before placing orders. The tariff consulting firm team runs HTS-level Section 232 analysis as part of every import cost review. The trade advisory services team then models exclusion eligibility, drawback recovery, and FTZ deferral to find the lowest landed cost path.

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Section 232 vs 301 vs 122: Which Tariff Authority Applies to Your Imports?

Three tariff authorities — Section 232, Section 301, and Section 122 — form the backbone of the remedial tariff environment U.S. importers face in 2026. Each derives from a different statute, targets different policy objectives, and covers different products and countries. Understanding which authority applies to a given import is the first step in any tariff analysis and the foundation of any mitigation strategy.

The Key Distinction Before Diving In

Section 232 is a national security tool. Section 301 is an unfair trade practices tool. Section 122 is a balance-of-payments emergency tool. They can and do coexist on the same customs entry — a Chinese steel part might simultaneously owe duties under all three relevant frameworks. Starting with this distinction prevents the common mistake of treating them as alternatives.

Section 232: National Security Tariffs

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Section 232 of the Trade Expansion Act of 1962 authorizes the President to impose import restrictions after the Secretary of Commerce and the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce (DOC) investigate and determine that an article is being imported in quantities or under circumstances that threaten to impair national security. BIS evaluates factors including domestic production capacity, the defense industrial base’s requirements, and the impact of imports on those requirements.

Current Section 232 Programs

  • Steel articles (HTS Chapters 72-73): 25% ad valorem from most countries. Country-specific tariff-rate quotas (TRQs) exist for Canada, Mexico, the EU, Japan, and others, allowing quota volumes at zero or reduced rates.
  • Aluminum articles (HTS Chapter 76): 10% from most countries, with TRQ arrangements for certain allies.
  • Copper and copper articles (HTS Chapter 74): 25%, announced in 2025 as part of the expanding national security review of critical minerals.
  • Autos and auto parts (HTS Chapter 87, specified subheadings): 25%, with a phase-in for USMCA-qualifying content.

Section 232 does not inherently target a single country. The current programs apply globally with country-specific exceptions negotiated as TRQs. The Federal Register publishes quarterly TRQ fill-rate data. Product exclusions are available for specific HTS subheadings where the product is not available in sufficient quantity, quality, or timeliness from domestic producers. Approved general approved exclusions (GAEs) are available for use by any importer. Working with a tariff consulting firm to identify applicable GAEs or pursue new exclusion requests often delivers measurable duty savings.

Section 232 Process

A Section 232 action requires a formal Commerce Department investigation, a report finding a national security threat, and a Presidential proclamation implementing the remedy. The process is more deliberate than IEEPA because it requires the BIS investigation step. Once proclaimed, Section 232 duties are indefinite.

Section 301: Unfair Trade Practice Tariffs

Section 301 of the Trade Act of 1974 authorizes the Office of the U.S. Trade Representative (USTR) to investigate foreign government acts, policies, and practices that are unreasonable or discriminatory and burden or restrict U.S. commerce, and to take appropriate retaliatory action. Unlike Section 232, Section 301 targets a specific country and a specific set of practices.

Current Section 301 Program: China

The active Section 301 action targets China based on USTR’s 2018 investigation finding that China engages in unfair practices related to technology transfer, intellectual property, and innovation. The tariffs are organized by “List”:

  • Lists 1 and 2: 25% on approximately $50 billion in goods (industrial equipment, aerospace components)
  • List 3: 25% (raised from 10% in 2019) on approximately $200 billion in goods (consumer electronics, furniture, machinery)
  • List 4A: 7.5% on approximately $120 billion in goods (consumer electronics, apparel, footwear)

USTR’s 2024 four-year statutory review resulted in targeted rate increases on strategic categories: electric vehicles (100%), solar cells (50%), lithium batteries (25%), ship-to-shore cranes (25%), and medical gloves (25%).

Section 301 and the Liberation Day IEEPA Stack

Beginning April 2025, the IEEPA Liberation Day rate stacked additively on Section 301 for Chinese goods. For a product subject to 25% Section 301 and 145% IEEPA, the combined remedial tariff is 170%, on top of the applicable MFN rate. Understanding Liberation Day tariffs is therefore inseparable from Section 301 analysis for Chinese-origin goods. See our review of Section 301 tariffs on China for the full product list and rate history.

Section 301 Exclusion Process

USTR has operated rolling exclusion request processes for Section 301. An exclusion removes the tariff for a specific HTS subheading and typically expires after one year. Exclusion requests must demonstrate that the product is not reasonably available from non-Chinese sources or that the tariff causes severe economic harm. The USITC publishes analysis supporting exclusion determinations.

Section 122: Balance-of-Payments Tariffs

Section 122 of the Trade Act of 1974 grants the President authority to impose a temporary import surcharge when the United States is experiencing “large and serious” balance-of-payments deficits or a significant depreciation in the exchange value of the dollar. This authority is less well-known because it has not been formally invoked since 1971 (under President Nixon as part of the Smithsonian Agreement framework). It received renewed attention in 2025 as a possible alternative legal basis for the Liberation Day tariff framework.

Key Constraints of Section 122

  • Rate cap: Section 122 limits the surcharge to a maximum of 15%.
  • Duration cap: The surcharge can last no more than 150 days without Congressional action.
  • Universal application: Section 122 does not allow country-specific differentiation; it applies to all imports equally.

These constraints explain why the Liberation Day framework used IEEPA rather than Section 122. IEEPA has no statutory rate cap, no time limit once an emergency is declared, and allows country-specific rate differentiation — all essential for the Annex II country-specific reciprocal rate structure with rates exceeding 100% for China. The USITC has published comparative analysis of IEEPA and Section 122 scope and limitations for interested parties.

Side-by-Side Comparison

Feature Section 232 Section 301 Section 122
Statute Trade Expansion Act 1962 Trade Act of 1974 Trade Act of 1974
Authority President after DOC/BIS investigation USTR (President may direct) President
Basis National security threat Unfair trade practices Balance-of-payments deficit
Country scope Global (with country TRQ exceptions) Country-specific (China currently) Universal (no country distinction)
Product scope Steel, aluminum, copper, autos Thousands of HTS codes from China All imports
Rate cap None statutory None statutory 15% maximum
Duration Indefinite until revoked Indefinite (4-year review cycle) Maximum 150 days
Current status Active: steel 25%, Al 10%, Cu 25%, autos 25% Active: 7.5-25%+ on Chinese goods Inactive (last used 1971)

Decision Tree: Which Authority Applies?

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  1. Is the product steel, aluminum, copper, or an auto/auto part? If yes, check for Section 232 applicability and any applicable TRQ for the country of origin.
  2. Is the country of origin China? If yes, identify the Section 301 List and applicable rate for the specific HTS subheading.
  3. Does the Liberation Day IEEPA rate apply? It applies to all origins: 10% Annex I for most countries, the applicable Annex II rate (145% for China as of mid-2026) for named countries.
  4. Is there an active AD/CVD order? Check ITA Enforcement and Compliance for any order covering the specific product and country combination.

The sum of all applicable rates is the effective composite tariff. Use the Captain tariff tracker to run this assessment for any HTS and origin combination. Our trade advisory services team provides authority-by-authority mitigation analysis for importers managing concurrent exposure across multiple programs.

Mitigation Strategies by Authority

Each tariff authority has distinct mitigation pathways:

  • Section 232: Product exclusion applications to BIS, reclassification to a non-covered subheading, sourcing from TRQ-exempt country volumes, FTZ use for melted-and-poured origin tracing.
  • Section 301: USTR exclusion requests for specific HTS subheadings, First Sale valuation to reduce the dutiable base, drawback on subsequent exports, sourcing diversification to non-China origins.
  • IEEPA (Liberation Day): Annex III product-level carve-out monitoring, bilateral deal memo tracking for country rate reductions, FTZ deferral pending exclusion rulings or court decisions.

Frequently Asked Questions

What is the difference between Section 232 and Section 301 tariffs?

Section 232 is a national security tariff under the Trade Expansion Act of 1962, currently applied globally to steel (25%), aluminum (10%), copper (25%), and autos (25%). Section 301 is an unfair trade practices tariff under the Trade Act of 1974, currently applied only to Chinese-origin goods at rates from 7.5% to 25%+. Both can apply to the same entry from China.

Does Section 301 apply to countries other than China?

No active Section 301 orders apply to countries other than China as of mid-2026. While Section 301 can be used against any country, the current action targets China specifically in response to USTR’s 2018 investigation findings on technology transfer and IP practices.

What is Section 122 and why is it not used?

Section 122 authorizes a temporary up-to-15% universal import surcharge for up to 150 days to address balance-of-payments deficits. It has not been formally invoked since 1971. The 15% rate cap and 150-day time limit make it unsuitable for the Liberation Day framework, which required country-specific rates exceeding 100% on an indefinite basis — capabilities IEEPA provides but Section 122 does not.

Can Section 232 and Section 301 both apply to the same Chinese steel shipment?

Yes. A Chinese steel fitting, for example, carries Section 232 (25%), Section 301 (25%), and IEEPA Liberation Day (145%) simultaneously. All applicable rates are calculated on the same customs value and summed. The combined effective rate on some Chinese steel products exceeds 200%.

How do I get a Section 232 product exclusion?

Submit an exclusion request to BIS through the Section 232 exclusion portal. The request must demonstrate that the product is not produced in the U.S. in sufficient quantity, quality, or timeliness. Approved exclusions become General Approved Exclusions (GAEs) available for any importer to use. Monitor the Federal Register for newly published GAEs that may cover your product.

Are Section 301 tariffs permanent?

Section 301 tariffs are indefinite but subject to mandatory four-year statutory review by USTR. Reviews can raise rates, reduce them, add product categories, or terminate the action. The 2024 review raised rates on strategic goods. The next review cycle is expected in 2028.

Authority-Specific Tariff Guidance

With three overlapping authorities and distinct mitigation pathways for each, the most efficient approach is a structured program review. Our tariff consulting team maps every applicable authority for your product portfolio and identifies priority mitigation actions by authority. Trade advisory services from CargoTrans cover Section 232 exclusion applications, Section 301 exclusion strategy, and IEEPA deferral planning.

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Section 122 Tariffs: Balance-of-Payments Authority and 2026 Implementation

Section 122 tariffs are import surcharges authorized by the Trade Act of 1974 §122 (19 USC §2132) when the United States faces a large and serious balance-of-payments deficit. The president can impose a surcharge of up to 15% on all dutiable imports without congressional approval. The surcharge can stay in place for up to 150 days before Congress must act to extend it. Section 122 has never been used as a comprehensive surcharge in modern U.S. trade history, but its legal framework is fully operational and is a known tool in the presidential trade toolbox for 2026.

Unlike IEEPA (used for the Reciprocal Tariff Act) or Section 232 (used for steel and aluminum), Section 122 requires no national security finding. It requires only a Treasury determination that the U.S. BoP deficit is large enough to warrant emergency action.

Statutory Limits on Section 122

Three hard limits define the Section 122 authority:

  1. Rate cap: Maximum 15%. The surcharge cannot exceed 15% on any dutiable import. Unlike IEEPA, which has no statutory rate ceiling, Section 122 gives importers a predictable worst-case number.
  2. Duration cap: Maximum 150 days without congressional extension. The 150-day clock starts on the date the proclamation takes effect. After 150 days, the surcharge automatically expires unless Congress passes authorizing legislation.
  3. BoP trigger: The U.S. Secretary of the Treasury and the USTR must determine that the U.S. faces a large and serious BoP deficit. The IMF’s Articles of Agreement framework defines what constitutes a BoP crisis for consultation purposes. The International Monetary Fund must be notified, though its approval is not required.

Section 122 vs IEEPA vs Section 232 vs Section 301

Each statutory authority has a different trigger, scope, and rate ceiling. Importers need to understand which law is activating which duty on their shipment.

When the President Picks Section 122 Over IEEPA

IEEPA (the International Emergency Economic Powers Act) is the authority behind the current Reciprocal Tariff Act. Check IEEPA tariff refunds for the limited recovery options available outside of standard drawback and has no statutory rate ceiling. In theory, an IEEPA tariff could exceed 15%. Section 122 is rate-capped at 15% but requires a shorter legal process and a narrower trigger (BoP vs. national emergency). A president might choose Section 122 when:

  • The administration wants a surcharge framed as a BoP corrective measure rather than a national emergency action
  • The rate needed is at or below 15%
  • The policy timeline is intended to be short (under 150 days) as a negotiating lever

The Section 232 tariffs guide explains the national security pathway. The Section 301 tariffs on China article covers the unfair trade practices pathway. Section 122 sits alongside those as a third distinct statutory tool. The Trump tariff tracker maps live rates from all four authorities to your open shipments.

2026 Implementation Context

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As of 2026, Section 122 has not been activated for a comprehensive surcharge. The current tariff environment is driven by IEEPA (Reciprocal Tariff Act), Section 232 (steel, aluminum, copper, autos), and Section 301 (China-specific). However, Section 122 remains a live legal option. The U.S. trade deficit has reached levels that could satisfy the statutory trigger. Importers working with the Captain tariff tracker can monitor Federal Register proclamations in real time to detect a Section 122 activation before shipments depart origin.

If Section 122 is activated, the surcharge applies to all dutiable imports regardless of country of origin. Unlike Section 301 (China only), a Section 122 surcharge hits Mexico, Canada, the EU, and every other trading partner simultaneously. That scope makes it the highest-impact short-term trade tool available under current law.

How Importers Respond to a Section 122 Surcharge

Because a Section 122 surcharge is time-limited and applies universally, the response strategy differs from country-specific or product-specific tariffs.

Cost Pass-Through Scenarios

At 15% maximum, the Section 122 rate is lower than most Section 301 rates and far below the Reciprocal Tariff Act rate on China. For many product categories, the landed cost increase is passable to customers without absorbing it entirely. Model the pass-through by product margin and customer price sensitivity before the surcharge hits.

FTZ and Bonded Warehouse Deferral

Goods admitted to a Foreign-Trade Zone or entered into a customs bonded warehouse before the Section 122 proclamation effective date lock in pre-surcharge duty treatment. For FTZ goods, duties apply at the rate in effect when goods leave the zone and enter U.S. commerce. For bonded warehouse goods, duties apply at the rate in effect at withdrawal. If a Section 122 surcharge is announced with a delayed effective date (common in trade policy), importers have a window to move inventory into either structure. Talk to the trade advisory services team to model whether the setup cost of FTZ admission or bonded entry justifies the duty savings over a 150-day window.

Documentation Needed at Entry

A Section 122 surcharge is collected at CBP entry. The importer of record is responsible for paying the correct rate. Entry documents must reflect the dutiable value correctly, as the surcharge is calculated on the same dutiable value as the Column 1 duty. Ensure commercial invoices, packing lists, and customs entries are consistent before filing.

Frequently Asked Questions

What is a Section 122 tariff?

A Section 122 tariff is a temporary import surcharge authorized under the Trade Act of 1974 §122 (19 USC §2132). The president can impose it when the U.S. faces a large and serious balance-of-payments deficit. The surcharge applies to all dutiable imports regardless of country of origin, up to a maximum of 15%.

What is the maximum rate under Section 122?

15%. Unlike IEEPA, which has no statutory rate ceiling, Section 122 is hard-capped at 15%. This gives importers a predictable maximum exposure when modeling worst-case landed costs.

How long can a Section 122 surcharge stay in place?

150 days without congressional action. After 150 days, the surcharge automatically expires unless Congress passes legislation to extend it. This built-in expiration makes Section 122 a short-term tool, not a structural tariff program.

Does Section 122 require congressional approval?

No, for the initial 150-day period. The president can impose the surcharge unilaterally after the Treasury/USTR BoP determination. Congressional approval is required only to extend the surcharge beyond 150 days.

Is Section 122 the same as IEEPA tariffs?

No. IEEPA (International Emergency Economic Powers Act) requires a national emergency declaration and has no statutory rate ceiling. Section 122 requires a balance-of-payments finding and caps the rate at 15%. The current Reciprocal Tariff Act operates under IEEPA authority, not Section 122.

How do FTZs help against Section 122 duties?

Goods admitted to a Foreign-Trade Zone before the Section 122 proclamation effective date are not subject to the surcharge when they enter U.S. commerce, provided the zone admission predates the proclamation. This allows importers to front-load inventory into FTZ status before a known effective date.

Can Section 122 tariffs be refunded?

No established refund mechanism exists for Section 122 duties. The automatic expiration after 150 days means the surcharge simply stops applying going forward. Duties collected during the active period are not refunded unless a court order or subsequent executive action specifically authorizes it.

A Section 122 surcharge is short, sharp, and predictable in its mechanics. The Captain tariff tracker monitors Federal Register proclamations in real time. The trade advisory services team models 150-day exposure windows against your import calendar and identifies which shipments benefit from FTZ or bonded warehouse deferral before a proclamation effective date arrives.

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Section 301 Tariffs: China Duties, Exclusions and Refund Process

Section 301 tariffs are U.S. import duties imposed on Chinese goods under the authority of the Trade Act of 1974 §301 (19 USC §2411-2420). The Office of the U.S. Trade Representative (USTR) initiated the program in 2018 after investigating China’s unfair trade practices in technology transfer, intellectual property, and innovation. The result was four tariff lists covering roughly $370 billion in annual Chinese imports. In 2026, Section 301 duties stack on top of the Reciprocal Tariff Act rates, bringing total China tariffs to 145% for most affected goods.

Section 301 is China-specific. It does not apply to imports from other countries. Every Section 301 shipment uses an HTS subheading in the 9903.88 series to identify the applicable list and rate. U.S. Customs and Border Protection (CBP) collects the duties at the time of entry.

Section 301 Lists and HTS Code Coverage

USTR created four tariff lists between 2018 and 2019, each covering a different tranche of Chinese goods by HTS code.

How to Check If Your HTS Code Is on a Section 301 List

Search the USTR Section 301 list database by 10-digit HTS subheading. If your subheading appears on List 1, 2, 3, or 4A, the corresponding rate applies on top of all other duties. Use the China to U.S. tariff calculator to check total stacked duty rates by HTS code before placing purchase orders.

HTS Subheading 9903.88 Explained

Every Section 301 entry uses a special HTS subheading in the 9903.88 series as an additional classification. CBP applies the rate associated with that subheading on top of the standard Column 1 duty. The subheading identifies which list applies:

  • List 1 ($34B goods): 25% rate. Covers industrial machinery, aerospace components, and high-tech goods.
  • List 2 ($16B goods): 25% rate. Covers semiconductors, chemicals, and plastics.
  • List 3 ($200B goods): 25% rate (raised from 10% in May 2019). Covers consumer goods, furniture, seafood, and a wide range of manufactured products. This list represents the largest share of affected import value.
  • List 4A ($120B goods): 7.5% rate (reduced from 15% under the Phase 1 deal in January 2020). Covers consumer electronics, apparel, footwear, and other consumer goods.

Current Section 301 Rates in 2026

In 2026, Section 301 rates themselves have not changed since 2020. What changed is the stacking environment. The Reciprocal Tariff Act added a 145% baseline on Chinese goods through executive order. The combined rate on a List 3 product from China is:

  • Base HTSUS Column 1 duty (varies by product, often 0-6%)
  • Section 301 List 3: 25%
  • Reciprocal Tariff Act: 145%
  • Total: 170%+ before Section 232 stacking

For steel and aluminum products subject to both Section 301 and Section 232, add 25% more. This level of stacked tariffs has made direct China sourcing economically viable only for products with no alternative supply chain. The Trump tariff tracker calculates your full stacked rate by HTS code before you place the order. Work with a tariff consulting firm to map your full duty stack before committing to a sourcing decision.

Section 301 Exclusion Process and Reinstatement

USTR grants product-specific exclusions that allow named importers to bring in covered goods at zero Section 301 duty. Exclusions are time-limited and company-specific or product-specific depending on the batch.

Active Exclusions in 2026

USTR has reinstated some exclusions that expired during 2021-2023. The active exclusion set changes with each USTR Federal Register notice. Importers must verify that their specific HTS subheading and product description match an active exclusion before claiming it at entry.

How to Request a New Exclusion

USTR opens exclusion request windows on a list-by-list basis. During an open window, importers submit a request describing the product, the volume needed, and why no adequate domestic or third-country source exists. Domestic producers can object. USTR issues a determination published in the Federal Register. Approved exclusions apply retroactively to the request date.

Section 301 Refund Eligibility and CIT Litigation Status

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The Court of International Trade (CIT) has been hearing consolidated challenges to the Section 301 List 3 and 4A tariffs in In Re Section 301 Cases. Importers who preserved their refund claims by filing protests with CBP may recover duties if the court rules in their favor. This is active litigation. The outcome is uncertain. Do not make sourcing or cash flow decisions based on an assumed refund. Consult legal counsel with CIT experience before relying on this pathway.

Separately, Section 301 duties are eligible for duty drawback under 19 USC §1313. Importers who re-export finished goods manufactured with Section 301 inputs can recover up to 99% of duties paid. This is a confirmed pathway, unlike the CIT litigation. See the IEEPA tariff refunds page for context on what refund mechanisms are confirmed vs pending.

Mitigation Strategies for Importers

Four strategies reduce Section 301 exposure without abandoning China sourcing entirely:

  1. First Sale for Export: Value the import at the manufacturer’s first sale price rather than the middleman price. This lowers the dutiable value and reduces the absolute dollar amount of Section 301 duties. The First Sale for Export program requires documentation of the transaction chain.
  2. Customs bonded warehouse: Defer duties while waiting for exclusion decisions or rate changes. Duties apply at the rate in effect at withdrawal, not at entry.
  3. Sourcing diversification: Shift production to Mexico (USMCA), Vietnam, India, or other countries not subject to Section 301. Verify that the country of origin determination supports the shift before moving purchase orders.
  4. Duty drawback: Recover up to 99% of Section 301 duties paid on inputs used in goods that are subsequently exported. File within 5 years of export.

The trade advisory services team models all four options against your current HTS code mix and exports volume to find the highest-ROI combination.

Frequently Asked Questions

Are Section 301 tariffs still in effect in 2026?

Yes. All four Section 301 lists remain active. USTR has not revoked any list. The rates from 2018-2020 remain in place, now stacked under the Reciprocal Tariff Act framework.

Which lists do Section 301 tariffs cover?

Four lists: List 1 ($34B, 25%), List 2 ($16B, 25%), List 3 ($200B, 25%), and List 4A ($120B, 7.5%). Lists 4B was proposed but never implemented. Check your HTS subheading against all four lists.

How do I check if my HTS code is hit by Section 301?

Search the USTR Section 301 list database by 10-digit HTS subheading. If your subheading appears on any list, the associated rate applies on all shipments of that product from China.

Can I get a Section 301 refund?

Two pathways exist. First, duty drawback: recover up to 99% of duties on inputs used in re-exported goods (confirmed pathway). Second, CIT litigation refund if the court rules for plaintiffs (uncertain, pending). Do not count on the litigation pathway without legal advice.

How do I file a Section 301 exclusion request?

USTR opens request windows by list. Submit through the USTR exclusion portal during an open window. Describe the product, volume, and lack of domestic or third-country alternatives. USTR publishes determinations in the Federal Register.

Do Section 301 tariffs stack with reciprocal tariffs?

Yes. In 2026, both apply simultaneously. A List 3 product from China pays 25% (Section 301) plus 145% (Reciprocal Tariff Act) plus the base Column 1 rate plus any Section 232 rate. All are additive.

What is HTS subheading 9903.88?

HTS 9903.88 is the special classification subheading series used to collect Section 301 duties at CBP. Each specific subheading under 9903.88 identifies which Section 301 list applies to the entry. The subheading is entered in addition to the standard product HTS code.

Section 301 exposure on China sourcing is reducible. The China to U.S. tariff calculator shows your full stacked duty rate by HTS code in seconds. The trade advisory services team maps exclusion eligibility, drawback recovery, and sourcing alternatives to cut your total landed cost.

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U.S. Tariffs on Taiwan: Semiconductor Section 232 and Reciprocal

U.S. tariffs on Taiwan imports in 2026 combine the IEEPA Liberation Day reciprocal rate with a pending Section 232 semiconductor investigation that, if finalized, would add a 25%+ tariff layer to the most critical supply chain in the global technology sector. Taiwan supplies over 60% of the world’s logic semiconductors and nearly all of the most advanced chips below 5nm. The tariff and trade policy environment surrounding Taiwan-origin imports is therefore not just a cost question, it is a strategic technology supply chain question for the entire U.S. economy.

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U.S.-Taiwan Trade Snapshot in 2026

Taiwan’s role in U.S. trade is disproportionate to its size. A self-governing island with a population of 23 million exports more high-technology goods to the United States than any country except China, EU, and Japan, driven almost entirely by semiconductor production and electronic manufacturing services.

Taiwan as a U.S. Trading Partner

The U.S. imported approximately $113 billion in goods from Taiwan in 2024, the seventh-largest import source. Taiwan Semiconductor Manufacturing Company (TSMC) alone accounts for a meaningful fraction of this total through direct chip sales and embedded in finished electronics. Other major Taiwan exporters include Foxconn (electronics manufacturing), Delta Electronics (power systems), and HIWIN (linear motion components). Our current U.S. tariff rates by country page provides context on Taiwan’s rate profile relative to other Asian trading partners.

Key Import Categories from Taiwan

  1. Semiconductors and integrated circuits (HTS Chapter 85, subheadings 8541-8542): logic chips, memory, analog ICs.
  2. ICT equipment and computers (HTS Chapter 84-85): servers, network equipment, laptops.
  3. Machine tools and precision manufacturing equipment (HTS Chapter 84): machining centers, EDM machines.
  4. Plastics and plastic articles (HTS Chapter 39): engineering plastics, packaging.
  5. Bicycles and related components (HTS Chapter 87): high-end road and mountain bikes.
  6. Optical instruments and medical equipment (HTS Chapter 90): endoscopes, optical lenses.

Current U.S. Tariff Stack on Taiwan Imports

Taiwan’s tariff profile in 2026 is defined by IEEPA, and the pending Section 232 semiconductor investigation that could fundamentally change landed cost for the most important technology supply chain in the world.

Statutory Authorities in Play

IEEPA Liberation Day (Executive Order 14257, April 2025)

Announced a 32% reciprocal rate on Taiwanese goods. Under the 90-day pause, reduced to 10% baseline. Taiwan’s announced rate reflects its large bilateral trade surplus with the U.S. If the pause expires, 32% reinstates. Monitored via Federal Register.

Section 232 semiconductor investigation (Trade Expansion Act §232)

Initiated in 2025, the investigation covers HTS Chapter 85 subheadings 8541 (discrete semiconductors, diodes, transistors) and 8542 (integrated circuits). Proposed tariff rates of 25%+ would apply to Taiwan-origin semiconductors if the investigation concludes with a Presidential proclamation. The BIS administers Section 232 investigations. For TSMC and other Taiwan foundries, a 25% semiconductor Section 232 would represent the largest single tariff event in U.S. technology trade history.

Section 232 steel (25%) and aluminum (10%)

Applicable to Taiwan-origin steel and aluminum products stacked on MFN rates.

MFN/NTR base rates

Semiconductors (HTS 8541-8542) typically enter at 0% MFN. ICT equipment generally 0-3.5%. Machine tools 0-5%. Bicycles 5.5-11%.

How the Rates Layer on a Single Entry

A Taiwan-origin advanced processor (HTS 8542.31, MFN 0%) during the IEEPA pause:

  1. MFN base rate: 0%.
  2. IEEPA baseline (90-day pause): +10%.
  3. Effective rate (pause): 10%.

If the pause expires (32% reinstates): 0% + 32% = 32% on customs value. If Section 232 semiconductor tariff additionally applies (25%): 0% + 32% + 25% = 57% effective rate. A $1,000,000 shipment of advanced chips would carry $570,000 in duties at the combined rate, potentially doubling the cost of critical components used in U.S. AI infrastructure, defense systems, and consumer electronics. Our Captain tariff tracker monitors IEEPA and Section 232 semiconductor developments.

Top Affected HTS Chapters and Sectors

Taiwan’s tariff exposure concentrates overwhelmingly in semiconductors and electronics, the categories that define Taiwan’s entire export economy to the United States.

Semiconductors and Integrated Circuits (Ch 85, HTS 8541-8542)

Taiwan produces more than 60% of global logic semiconductor capacity and over 90% of the most advanced chips below 5nm (all through TSMC). Taiwan-origin chips flow into virtually every high-technology product sold in the U.S., from iPhones and servers to medical devices and automotive systems. IEEPA at 10-32% plus a potential Section 232 at 25% would represent an unprecedented cost shock to U.S. technology supply chains. No alternative supply exists at comparable scale or technology capability on a short timeline. The Section 232 semiconductor investigation outcome is the single most consequential pending tariff decision for U.S. technology importers. Our Section 232 tariffs guide covers the investigation framework and exclusion process.

ICT Equipment and Consumer Electronics (Ch 84-85)

Taiwan’s electronics manufacturing services sector, led by Foxconn, Pegatron, Quanta, and Compal, produces servers, laptops, and networking equipment for Apple, Dell, HP, Cisco, and others. ICT equipment faces 0-3.5% MFN plus IEEPA. Given the high per-unit values of servers ($5,000-$50,000+ per unit), even a 10% IEEPA rate creates significant cost pressure on data center procurement. The Reciprocal Tariff Act analysis covers IEEPA’s impact on technology imports.

Machine Tools and Precision Equipment (Ch 84)

Taiwan is a major producer of CNC machining centers, EDM wire-cut machines, and precision grinding equipment, particularly from the Taichung manufacturing cluster. Machine tool imports face 0-5% MFN plus IEEPA. For U.S. precision manufacturers investing in machining capacity, IEEPA adds to capital equipment costs for products that have no domestic equivalent at comparable price points.

Bicycles and Components (Ch 87)

Taiwan produces the majority of the world’s high-end road, mountain, and gravel bikes, brands including Giant, Merida, Trek-sourced, and Specialized-sourced frames. Bicycle frames face MFN rates of 11% plus IEEPA. Combined rates during the pause (11% + 10% = 21%) are among the highest for any Taiwan-origin product category outside steel. Our how to calculate U.S. tariffs guide covers compound tariff calculation.

Section 232 Semiconductor Investigation: What Taiwan Exporters Need to Know

The Section 232 semiconductor investigation represents the most significant pending tariff risk for Taiwan-origin imports. Understanding the investigation timeline and potential exclusion mechanisms is critical for importers of any Taiwan-origin technology product.

Investigation Scope and Timeline

The BIS investigation covers semiconductors broadly, including both discrete devices (HTS 8541) and integrated circuits (HTS 8542). The investigation analyzes whether U.S. semiconductor imports threaten national security under the Trade Expansion Act of 1962. A Presidential proclamation following the investigation could impose tariffs immediately or after a brief phase-in period. The BIS Section 232 page tracks investigation status and public comment periods. Our tariff and customs duty consulting team monitors investigation developments and advises on exclusion petition timing.

How Semiconductor Tariffs Would Stack

If Section 232 semiconductors are enacted at 25%, the combined tariff on Taiwan-origin chips would be: 0% MFN + 32% IEEPA (post-pause) + 25% Section 232 = 57% effective rate. For comparison, the current pause rate of 10% IEEPA + 0% Section 232 = 10%. The swing from 10% to 57% would fundamentally alter the economics of U.S. AI infrastructure buildout, defense electronics procurement, and consumer technology pricing. TSMC’s Arizona fab expansion (planned for 2nm production by 2028) is partly a hedge against this risk, U.S.-produced chips would not face Section 232.

How Importers Calculate Landed Cost on Taiwan-Origin Goods

Taiwan landed cost modeling requires running three scenarios: current IEEPA pause (10%), post-pause IEEPA (32%), and post-pause plus Section 232 semiconductor (57% for chips). For capital planning purposes, semiconductor importers should model all three.

Worked Example

A $5,000,000 CIF annual procurement of Taiwan-origin server processors (HTS 8542.31): IEEPA pause (10%) = $500,000 duty. Post-pause IEEPA (32%) = $1,600,000. Post-pause + Section 232 semiconductor (57%) = $2,850,000. Planning procurement inventory forward under the pause rate, and evaluating FTZ admission, can substantially reduce exposure during rate uncertainty periods. Our trade advisory services and tariff consulting firm teams provide Taiwan-specific scenario planning.

Common Landed-Cost Pitfalls

  • Planning capital equipment budgets at 10% IEEPA pause rate without contingency for 32% post-pause.
  • Ignoring Section 232 semiconductor investigation risk on chip procurement decisions made today.
  • Missing that TSMC’s Arizona fabs produce U.S.-origin chips, sourcing from the Arizona fab avoids Taiwan-origin tariff exposure.
  • Failing to check IEEPA exemption status for specific HTS subheadings, some technology products have received temporary exemptions.

Mitigation Strategies for Importers Sourcing from Taiwan

Taiwan-origin tariff mitigation is constrained by the lack of an FTA and the near-impossibility of immediately substituting Taiwan-origin semiconductor supply. However, several strategies reduce short-term exposure.

Section 232 Exclusion Petitions

If Section 232 semiconductors are enacted, the exclusion process will be critical for technology importers. Exclusions for products with no U.S.-available equivalent, which describes most advanced chips below 5nm, should be filed immediately upon proclamation. Our Section 232 tariffs guide covers the exclusion petition process. Our trade advisory services team prepares exclusion petitions.

FTZ Admission for High-Value Shipments

Foreign Trade Zones defer IEEPA and Section 232 duty payments on Taiwan-origin electronics and chips until withdrawal for U.S. consumption. For high-value semiconductor procurement, where per-shipment values may exceed $10-50 million, FTZ deferral represents meaningful cash flow optimization. Goods admitted before a rate increase and withdrawn after remain subject to the higher rate at withdrawal, so FTZ timing strategy requires monitoring rate change signals.

U.S. Fab Sourcing Strategy

TSMC’s Arizona fabs (currently producing 4nm, expanding to 2nm) produce U.S.-origin chips that are entirely exempt from Taiwan-origin tariffs. For procurement teams with multi-year horizons, qualifying supply transitions from TSMC Taiwan to TSMC Arizona provide permanent tariff exemption. Intel’s U.S. domestic foundry service offers a similar alternative for some product categories.

Importers managing multi-origin supply chains can benchmark landed costs across our full country tariff series: Thailand, Malaysia, Mexico, Indonesia, Brazil, South Korea, Vietnam, Canada, and India.

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Frequently Asked Questions

What is the current U.S. tariff rate on Taiwan imports?

During the 90-day IEEPA pause: MFN base rate + 10%. Semiconductors (0% MFN) effectively face 10%. Taiwan’s announced Liberation Day rate of 32% applies if the pause expires. Section 232 semiconductor tariffs (25%+) would additionally apply if the ongoing BIS investigation results in a Presidential proclamation. Check the Captain tariff tracker for current rates by HTS code.

Are Taiwan tariffs still in effect in 2026?

Yes. IEEPA (10% pause baseline) applies to all Taiwan-origin goods. Section 232 steel (25%) and aluminum (10%) are active. The Section 232 semiconductor investigation is ongoing, a proclamation would impose additional tariffs on HTS 8541-8542 products. There is no U.S.-Taiwan FTA currently in force.

Which HTS chapters carry the highest U.S. tariff on Taiwan-origin goods?

Current highest effective rates: bicycles (Ch 87), 11% MFN + 10-32% IEEPA; steel (Ch 72-73), 25% Section 232 + IEEPA; machinery (Ch 84), 0-5% MFN + IEEPA. Semiconductors (Ch 85, HTS 8541-8542) currently face 0% MFN + 10% IEEPA during the pause, but face the highest potential exposure if Section 232 semiconductor tariffs are enacted (25% additional).

How does the tariff stack layer on a single entry?

MFN base rate + IEEPA reciprocal (10% pause / 32% post-pause) + Section 232 (25% steel; 10% aluminum; 25%+ semiconductors if enacted) = effective rate on customs value. Each layer applies additively to the same declared value. For semiconductors post-investigation, the maximum potential stack is 0% + 32% + 25% = 57%.

Can I use an FTZ to defer U.S. tariffs on Taiwan imports?

Yes. FTZs defer IEEPA and Section 232 duty payments until goods are withdrawn for U.S. consumption. For high-value semiconductor and electronics procurement, FTZ deferral provides significant cash flow benefits. Rate volatility risk (goods admitted at 10% IEEPA, withdrawn at 32%) means FTZ timing strategy must be actively managed with real-time rate monitoring via the Captain tariff tracker.

Are Taiwan tariffs eligible for drawback or refund?

IEEPA duties on Taiwan-origin goods qualify for manufacturing drawback (99% recovery under 19 USC 1313) when imported goods are incorporated into exported products. For U.S. technology companies that import Taiwan chips and export finished electronics globally, manufacturing drawback programs can recover substantial IEEPA costs on the re-exported portion of production. Our trade advisory services team structures drawback programs.

How often do U.S. tariff rates on Taiwan change?

IEEPA rates for Taiwan have changed multiple times since April 2025. The Section 232 semiconductor investigation outcome could impose a new tariff layer with as little as a few weeks of notice following Presidential proclamation. The Captain tariff tracker provides real-time Taiwan-specific monitoring for both IEEPA changes and Section 232 investigation developments.

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U.S. Tariffs on Mexico: USMCA Stack and Trump 25% IEEPA Order

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U.S.-Mexico Trade Snapshot in 2026

Mexico surpassed China and Canada to become the United States’ top import source in 2023, a position maintained through 2026. The depth of U.S.-Mexico supply chain integration, particularly in autos, electronics, agriculture, and medical devices, means that tariff friction between the two countries has direct consequences for U.S. manufacturing costs and consumer prices.

Mexico as a U.S. Trading Partner

The U.S. imported approximately $505 billion in goods from Mexico in 2024, with automotive products, electronics, and agricultural goods representing the largest categories. Mexico’s position as the top U.S. import source reflects decades of nearshoring investment, preferential access under NAFTA/USMCA, and geographic advantages for just-in-time supply chains. The nearshoring and friendshoring strategy analysis covers why Mexico has become the primary destination for supply chain diversification from China. Our current U.S. tariff rates by country page compares Mexico’s tariff profile to other major trade partners.

Key Import Categories from Mexico

  1. Motor vehicles and auto parts (HTS Chapter 87): pickup trucks, SUVs, auto parts from Tier-1 suppliers.
  2. Electronics and electrical equipment (HTS Chapter 85): TVs, computers, wire harnesses, medical electronics.
  3. Agricultural products and food (HTS Chapters 7-21): avocados, tomatoes, berries, beer, spirits.
  4. Medical devices (HTS Chapter 90): surgical instruments, catheters, diagnostic equipment.
  5. Industrial machinery (HTS Chapter 84): engines, compressors, HVAC equipment.
  6. Steel and aluminum products (HTS Chapters 72-73, 76): structural steel, flat-rolled products.

Current U.S. Tariff Stack on Mexico Imports

The USMCA/non-USMCA determination is the central tariff question for every Mexico-origin entry. The 25-point rate differential between USMCA-qualifying (0%) and non-USMCA (25%) goods makes rules-of-origin compliance worth more per shipment than any other single cost factor in Mexico supply chains.

Statutory Authorities in Play

USMCA (United States-Mexico-Canada Agreement)

Goods meeting CBP USMCA rules of origin enter at 0%. Automotive ROO requires 75% regional value content plus labor value content thresholds. Non-automotive goods require tariff classification change (from covered HTS headings) and may have additional regional value content requirements under 19 CFR Part 182.

IEEPA Mexico executive order (February 2025)

Applied a 25% tariff on Mexican goods citing fentanyl trafficking and border security as authority triggers under IEEPA (50 USC §1701). USMCA-qualifying goods are carved out from the IEEPA rate, only non-USMCA goods face the 25%. This creates a binary tariff landscape: 0% (USMCA) or 25% (non-USMCA) on most product categories.

Section 232 steel and aluminum

  • Mexican steel and aluminum within the USMCA TRQ enter at 0%.
  • Over-quota volumes face 25% steel / 10% aluminum. See CBP quota monitoring for TRQ fill status.

Section 232 autos

Mexico-assembled vehicles and auto parts that meet USMCA ROO avoid Section 232. Non-USMCA Mexico-assembled vehicles face the 25% Section 232 auto tariff. Given Mexico’s deep auto industry integration, most automotive production meets USMCA ROO, but the Tier-1 parts supply chain contains non-USMCA components that require analysis.

MFN/NTR base rates

Applicable only when goods don’t claim USMCA or IEEPA applies, pre-USMCA MFN rates on Mexico goods were generally 0-5% for most manufactured goods.

How the Rates Layer on a Single Entry

A Mexico-assembled TV that qualifies under USMCA:

  1. USMCA preferential rate: 0%.
  2. IEEPA Mexico order: Exempt (USMCA carve-out).
  3. Effective rate: 0%.

The same TV assembled in Mexico without meeting USMCA regional value content (e.g., using too many non-USMCA Asian components):

  1. USMCA: Not eligible (fails ROO).
  2. IEEPA Mexico order: 25%.
  3. Effective rate: 25% on customs value.

The 25-percentage-point difference is the most significant binary tariff split in U.S. trade, USMCA qualification is worth approximately $250,000 per $1 million in Mexico-origin imports. Use the Captain tariff tracker to verify current IEEPA Mexico rates and any product-specific exemptions.

Top Affected HTS Chapters and Sectors

Mexico’s tariff exposure concentrates in sectors where USMCA qualification is most complex, automotive, electronics, and processed foods, and where non-USMCA goods previously paid near-zero MFN rates and now face 25% IEEPA.

Autos and Auto Parts (Ch 87)

Mexico is the world’s seventh-largest vehicle producer and the largest source of U.S. auto imports. GM, Ford, Stellantis, Nissan, Toyota, Honda, BMW, and Volkswagen all operate major assembly plants in Mexico. USMCA automotive ROO (75% regional value content) applies to passenger vehicles and light trucks. Most Mexico-assembled vehicles meet this threshold, and avoid both Section 232 and IEEPA as USMCA-qualifying goods at 0%. However, the Tier-1 and Tier-2 auto parts supply chain contains components sourced from Asia that may not meet USMCA ROO for the component level, creating parts-level tariff exposure even where finished vehicles qualify. Our USMCA rules of origin analysis covers automotive ROO in detail.

Electronics and Electrical Equipment (Ch 85)

Mexico’s electronics sector, centered in Guadalajara, Monterrey, Juárez, and Tijuana, produces TVs, computers, wire harnesses, power supplies, and consumer electronics for the U.S. market. Electronics USMCA ROO requires tariff classification change plus regional value content. Asian-origin components (displays, semiconductors) create ROO compliance complexity, a TV with a Korean display panel and Japanese chips may not meet USMCA RVC even when assembled in Mexico. Importers must verify component-level USMCA qualification or face 25% IEEPA on finished goods.

Agricultural Products and Beverages (Ch 7-21, Ch 22)

Mexican agricultural exports, avocados (now the largest U.S. import), tomatoes, berries, and cucumbers, are overwhelmingly USMCA-qualifying (agricultural goods have simpler ROO based on tariff shift). Beer, tequila, and mezcal (Ch 22) from Mexico are well-established USMCA-qualifying products. However, processed food products with complex ingredient sourcing may face USMCA compliance questions that require manufacturer-level ingredient documentation. Our tariff and customs duty consulting team handles food product USMCA origin analysis.

Medical Devices (Ch 90)

Mexico has become a leading global medical device manufacturer, exporting approximately $15 billion annually in surgical instruments, catheters, stents, and diagnostic devices to the U.S. Medical devices are among the most USMCA-qualified categories: most are produced from regional inputs with limited Asian-origin components. USMCA qualification preserves the 0% rate on a high-value, high-margin export category. Importers of Mexico-origin medical devices should maintain active USMCA certification programs given the 25% IEEPA alternative rate.

How Importers Calculate Landed Cost on Mexico-Origin Goods

Mexico landed cost modeling has two distinct scenarios: USMCA-qualifying (0%) and non-USMCA (25% IEEPA). The critical analysis is whether each specific product and supplier meets USMCA ROO, and documenting that qualification through supplier certifications updated at minimum annually.

Worked Example Using the Tariff Calculator

Use CargoTrans Captain’s tariff calculator and our Captain tariff tracker to model Mexico-origin goods by HTS code and USMCA status. For a $2,000,000 CIF auto parts entry (HTS 8708): USMCA qualifying = 0% = $0 duty. Non-USMCA = 25% IEEPA = $500,000 duty. Plus potential 25% Section 232 on applicable auto parts: additional $500,000. Total non-USMCA exposure: $1,000,000 on a $2,000,000 entry.

Common Landed-Cost Pitfalls

  • Accepting Mexican supplier USMCA certificates without verifying the underlying ROO analysis and component sourcing.
  • Missing that some auto parts categories require both tariff classification change AND regional value content, not just one.
  • Overlooking IEEPA Mexico order applicability on goods that previously paid 0% MFN under NAFTA/USMCA.
  • Failing to update USMCA certifications annually, expired certifications expose importers to post-entry CBP audits with retroactive duty assessment.
  • Not separating USMCA-qualifying and non-USMCA goods in the same commercial invoice.

Mitigation Strategies for Importers Sourcing from Mexico

Mexico’s primary mitigation strategy is USMCA qualification optimization, ensuring as many goods as possible meet ROO for 0% access. Beyond that, Section 232 exclusions and IEEPA tariff refund monitoring provide additional tools.

USMCA Qualification and Rules-of-Origin Optimization

For products on the margin of USMCA qualification, USMCA rules of origin analysis by our team identifies component-level sourcing changes that enable USMCA qualification. Substituting a USMCA-origin display panel for an Asian-origin equivalent, for example, can shift a TV from 25% non-USMCA to 0% USMCA. The incremental component cost is often far less than the 25% duty savings on finished goods value.

IEEPA Tariff Refund Monitoring

The IEEPA tariff refunds page tracks any refund mechanisms announced for duties paid on the IEEPA Mexico executive order. If exemptions or refunds are issued for specific categories, early filing is critical. Our tariff consulting firm team monitors IEEPA Mexico order developments in real time.

First Sale for Export

For Mexico imports transacting through intermediaries, First Sale for Export can reduce the dutiable value base. For non-USMCA goods where IEEPA 25% applies, First Sale reduces the customs value, and therefore the duty base, by eliminating intermediary markups. On a 25% rate, a 15% First Sale reduction in value reduces duty by approximately 15% as well.

Importers managing multi-origin supply chains can benchmark landed costs across our full country tariff series: Thailand, Malaysia, European Union, Taiwan, Brazil, Indonesia, Japan, South Korea, Vietnam, and India.

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Frequently Asked Questions

What is the current U.S. tariff rate on Mexico imports?

USMCA-qualifying goods: 0%. Non-USMCA goods: 25% IEEPA (under the February 2025 executive order). Steel within USMCA TRQ: 0%; over-quota: 25% Section 232. Mexico-assembled vehicles and auto parts meeting USMCA automotive ROO: 0%; non-USMCA: 25% Section 232. The USMCA qualification determination controls whether a shipment pays 0% or 25%, making it the most valuable compliance question in Mexico-origin trade. Use the Captain tariff tracker for real-time rates.

Are Mexico tariffs still in effect in 2026?

Yes. The IEEPA Mexico executive order (25% on non-USMCA goods) remains active. USMCA provides 0% access for qualifying goods, but the underlying IEEPA tariff exists as the default for non-qualifying entries. Section 232 steel and aluminum TRQs are also active. Mexico’s tariff environment is more bifurcated (0% vs. 25%) than any other major U.S. trading partner.

Which HTS chapters carry the highest U.S. tariff on Mexico-origin goods?

Highest exposure is on non-USMCA goods in any category at 25% IEEPA. Specifically: non-USMCA electronics (Ch 85) at 25%; non-USMCA auto parts (Ch 87) at 25% IEEPA + 25% Section 232; steel over TRQ (Ch 72-73) at 25% Section 232. USMCA-qualifying versions of all these categories enter at 0%.

How does the tariff stack layer on a single entry?

For USMCA-qualifying goods: 0% (supersedes MFN and IEEPA). For non-USMCA goods: MFN base rate + 25% IEEPA. For non-USMCA auto parts also subject to Section 232: MFN + 25% IEEPA + 25% Section 232. Each percentage applies to the same declared customs value base (additive, not compounded).

Can I use an FTZ to defer U.S. tariffs on Mexico imports?

Yes. Foreign Trade Zones defer IEEPA and Section 232 duty payments until goods enter U.S. commerce. For importers facing the non-USMCA 25% IEEPA rate, FTZ deferral reduces duty cash flow requirements. However, FTZs do not eliminate duty liability for non-USMCA goods, they defer it. USMCA-qualifying goods (0% duty) gain no duty benefit from FTZ admission.

Are Mexico tariffs eligible for drawback or refund?

The IEEPA tariff refunds page tracks any refund mechanisms for IEEPA Mexico order duties. Section 232 and IEEPA duties paid on Mexico-origin goods qualify for manufacturing drawback under 19 USC 1313 when incorporated into exported products. Contact our trade advisory services team for a drawback analysis.

How often do U.S. tariff rates on Mexico change?

The IEEPA Mexico executive order has been modified multiple times since February 2025, USMCA carve-outs, product-specific exemptions, and potential rate adjustments have occurred. Section 232 TRQ allocations update quarterly. USMCA rules-of-origin determinations are durable but require annual certification renewal. The Captain tariff tracker monitors Mexico-specific rate changes in real time.

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