Recover the China Duty You Overpaid.
We find, file, and defend your Section 301 relief — USTR exclusion requests, exclusion-to-entry matching, and retroactive refunds on entries that were liquidated at the full List 1 through 4A rate.
Trusted by leading importers & manufacturers
Section 301 is the statute (Section 301 of the Trade Act of 1974) that USTR used to impose additional duties on roughly $370 billion of China-origin goods across Lists 1, 2, 3, and 4A, collected through Chapter 99 subheadings like 9903.88.01. An exclusion is a product-specific carve-out that USTR grants so a defined article, described by its physical characteristics and tied to an 8- or 10-digit HTS line, is relieved from that extra duty.
CargoTrans works both sides of the exclusion: we prepare and file exclusion requests during USTR comment windows with the four-factor case USTR actually weighs (availability outside China, severe economic harm, strategic importance, and whether the product is covered by China industrial programs), and we run an HTS classification review so your goods are described against the exact language of any active or reinstated exclusion. This desk coordinates directly with our tariff and customs duty consulting team so exclusion strategy sits inside a full duty-reduction plan, run through our tariff and trade advisory desk, rather than standing alone.
The larger money is usually retroactive. When USTR grants or reinstates an exclusion, it applies back to a stated effective date, so duties already paid on entries filed after that date can be reclaimed by post-summary correction on unliquidated entries or by protest under 19 U.S.C.
4-factor
USTR exclusion case
180-day
Protest refund window
24h
Response time
Six advisory services our trade team uses to secure exclusions, match them to your entries, and recover Section 301 duty you should not have paid.
We pull your China-origin entries and quantify Section 301 duty by HTS line, List, and 9903.88 subheading.
We test each product against active, reinstated, and expired exclusions and flag where a new request is worth filing.
We prepare USTR exclusion requests and identify entries eligible for retroactive refund before their deadlines.
We file post-summary corrections, protests, and refund claims, and flag exclusions on your forward entries.
We watch USTR actions and liquidation dates so no exclusion or refund window passes unclaimed.
Section 301 duty is not a fixed cost of buying from China, it is a surcharge that exclusions, refunds, and sourcing decisions can lawfully reduce, but only if someone reads the exclusion text and watches the deadlines.
CargoTrans turns that into a claimed position: the right exclusion, matched to the right entry, filed before the window closes.
The real-time Control Tower gives your team a live view of China-origin entries, the 9903.88 duty on each, and which lines touch an active or expiring exclusion, so a refund window surfaces as an alert instead of a missed deadline discovered at year-end.
Behind it, Captain Trade Advisory ties each exclusion position to the entry it applies to, and our Captain Trade Compliance module keeps the eligibility rationale attached to the entry so the refund claim and the record CBP sees never drift apart.
Every exclusion match is documented against the literal USTR product description as the entry is filed, so when CBP reviews a post-summary correction or protest, the eligibility rationale is already on the record rather than reconstructed after a rejection.
Because our advisors sit beside the brokers who file your entries, a denied exclusion, a rate advance, or a challenged refund is handled by the team that built the position, so the answer to a CBP question is consistent with the entry and the classification behind it.
Section 301 tariffs are the additional duties USTR imposed on China-origin goods under Section 301 of the Trade Act of 1974, collected through Chapter 99 subheadings such as 9903.88.01 on top of the normal HTS rate. An exclusion is a product-specific relief that USTR grants after a public process, removing that additional duty for a narrowly defined article tied to an HTS line. Exclusions are not automatic and they are not permanent: they have an effective date, an expiration date, and precise product language. If your goods fall outside that language, or the exclusion has lapsed, the surcharge still applies. CargoTrans identifies which exclusions touch your products, matches them to your actual entries, and files the requests and refunds needed to claim the relief.
Qualification turns on the exact product description in the exclusion, not the HTS code alone. USTR exclusions are written around physical characteristics, dimensions, function, and sometimes end use, and CBP applies them literally. Two products under the same 10-digit HTS number can differ in whether they qualify, because one matches the exclusion language and the other does not. We compare your article against the exact text of active and reinstated exclusions, document the rationale line by line, and tell you honestly where a match holds and where it does not. That documented eligibility analysis is also what protects a refund claim, because CBP can and does reject claims filed on a product that never met the exclusion wording.
Often yes, when an exclusion applies retroactively to a date before your entries were filed. USTR exclusions carry an effective date, and duty paid on covered entries after that date can be reclaimed. The mechanism depends on the entry's status: an unliquidated entry can be corrected through a post-summary correction, while a liquidated entry generally requires a protest under 19 U.S.C. 1514, which must be filed within 180 days of liquidation. The deadline is the trap. Most missed refunds are not denied, they are simply never filed because no one tracked the liquidation date. We pull your entries, match them to the exclusion's effective window, and file the correct instrument before the window closes.
They rest on different legal authorities and follow different processes. Section 301 duties come from USTR action under the Trade Act of 1974 and are relieved through USTR product exclusions and the refund mechanisms tied to them. IEEPA tariffs come from a different presidential authority under the International Emergency Economic Powers Act, and any refund of those duties follows its own rules and any relief that authority provides. Because a single China-origin shipment can carry more than one layer of additional duty, the two have to be analyzed separately. CargoTrans handles Section 301 exclusions here and addresses the IEEPA layer through our IEEPA tariff refund work, so each duty is claimed under the authority that actually governs it rather than lumped together.
USTR opens exclusion or reinstatement processes in defined comment windows, published through the Federal Register and a USTR portal. A request describes the specific product, ties it to an HTS subheading, and argues the factors USTR weighs: whether the product is available from sources outside China, whether the Section 301 duty causes severe economic harm to the requester or U.S. interests, whether the product is strategically important or tied to China industrial programs like Made in China 2025, and comparable considerations. Other parties can file responses supporting or opposing the request. We build the product description and the supporting evidence, file within the window, and monitor the docket, because a request that is imprecise or thinly supported is the one USTR denies.
When an exclusion expires and USTR does not extend it, the additional Section 301 duty resumes on your goods from the expiration date forward, even though nothing about the product changed. This is why exclusion relief cannot be treated as a permanent rate cut. We track the expiration and reinstatement calendar for the exclusions that matter to you, flag entries filed during any gap, and advise on next steps: a new exclusion request if a window reopens, a sourcing or origin change to move the goods outside the China surcharge, or drawback where the goods are re-exported. The goal is that an expiration is a planned event you saw coming, not a duty increase you discover on a liquidation notice.
Directly. Section 301 duties apply based on whether the good is a product of China, which is a country-of-origin question governed by substantial transformation, not simply where it shipped from. Goods assembled or finished in a third country may or may not escape the China surcharge depending on whether the processing there substantially transformed them. Getting this wrong in either direction is costly: claiming a non-China origin that does not hold exposes you to penalties and evasion findings, while conceding China origin you could have avoided means paying duty you never owed. We coordinate exclusion work with a rigorous origin analysis so your Section 301 position rests on an origin determination that would survive CBP scrutiny.
The reach depends on the exclusion's effective date and each entry's liquidation status, not on a single fixed lookback. If an exclusion is effective as of a past date, entries filed on or after that date and covered by the exclusion are candidates. Unliquidated entries can be corrected while they remain open. Liquidated entries fall under the 180-day protest clock that runs from the date of liquidation. There has also been litigation at the Court of International Trade over the broader List 3 and 4A actions that affected refund posture for many importers. We assess each entry individually, because the recoverable amount is defined by which entries are still inside a live filing window, and that requires reading liquidation dates, not estimating.
A broker's core job is releasing your shipment, and many file entries accurately without ever running an exclusion or refund analysis, because that is advisory work, not transactional filing. The result is that exclusions go unclaimed and refund windows close quietly. CargoTrans is both a licensed broker and a trade advisory firm, so we can review the entries your current broker filed, identify exclusion matches and retroactive refunds that were missed, and either file the recovery or coordinate it. If you move filing to us, the exclusion strategy and the entry are handled by one team. Either way, the point is to stop leaving Section 301 money on the table that a documented exclusion would have recovered.
It starts with your China-origin entry data. We identify every HTS line carrying a Section 301 surcharge, tie each to its List and 9903.88 subheading, and quantify the annualized duty so you see where the cost concentrates. We then test those lines against active, reinstated, and recently expired exclusions to find matches, and check liquidation dates to flag entries still inside a refund window. The review ends with a ranked picture: which exclusions to pursue, which entries can be reclaimed and by when, and where a sourcing or origin change would cut forward exposure. The first 30-minute review is free and carries no obligation, and it is usually enough to show whether real recovery is on the table.
Yes, and it is often the most durable relief. Because Section 301 applies to products of China, shifting genuine production or substantial transformation to another country can move goods outside the surcharge, provided the origin change is real and documented rather than a paper transshipment. We model the landed-cost impact of sourcing alternatives, pressure-test the origin claim against substantial transformation standards so it would survive CBP review, and build the supporting documentation. This is a different lever from exclusions and refunds, which address goods that remain China origin. Used together, exclusions recover past and present duty on China-origin goods while a defensible sourcing shift reduces the exposure on what you import next.
It begins with a free 30-minute exposure review. Share your recent China-origin entries and product descriptions, and we will quantify your Section 301 duty, flag exclusion matches, and identify entries still eligible for a retroactive refund, with no obligation. From there we scope the work: USTR exclusion requests where a window is open, refund filings on entries inside their deadlines, and forward-entry flags so relief is claimed at filing. Because our brokers file entries daily, we move from analysis straight to recovery without handing your program to another firm. Most importers start because a liquidation notice, a duty spike, or a supplier change made China exposure suddenly worth quantifying.
