Executive Summary On September 2, 2026, the Office of the U.S. Trade Representative (USTR) published conforming amendments to four product exclusions from the Section 301 tariffs on China (91 FR 56538). The amendments reflect changes to ten-digit statistical reporting numbers in the Harmonized Tariff Schedule of the United States (HTSUS) that took effect on July 1, 2026, and are themselves effective as of that date. Their purpose, in USTR’s words, is to maintain the pre-existing product coverage of the exclusions: the products covered do not change, only the numbers used to report them. A fifth exclusion received a similar amendment on October 7, 2026. These exclusions belong to the set of 178 exclusions claimed under HTSUS 9903.88.69 and 9903.88.70, which run through 11:59 p.m. on November 9, 2026. This analysis explains what changed, how CBP has said affected entries can be handled, and what importers commonly consider when reviewing their classifications.

Update (November 2026): This article has been revised to correct the description of what a Section 301 exclusion removes, to correct the examples given for List 4A, and to add the October 7, 2026 amendment and CBP’s subsequent guidance. For the November 9, 2026 end date of the 178 exclusions, see our analysis of the expiry and the port fee decision.

USTR Updates China Section 301 Tariff Exclusions to Reflect HTSUS Changes

(USTR更新对华301条款关税排除清单以匹配HTSUS变更)

1 · The Section 301 Tariff Framework on China

The Four Lists

Since 2018, the U.S. has imposed Section 301 tariffs on approximately $370 billion worth of imports from China across four lists (Lists 1, 2, 3, and 4A), under the investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The base rates are 25 percent for Lists 1 through 3 and 7.5 percent for List 4A. Following the first statutory four-year review, rates on certain strategic products were raised in phases beginning in 2024, so some products now carry higher Section 301 rates.

Note: Many high-profile consumer electronics, such as cell phones and laptop computers, were placed on List 4B, which was suspended and never took effect. Whether a specific product is covered depends on its HTSUS classification.

The Exclusion Mechanism

USTR has periodically granted product exclusions from these tariffs. An exclusion removes only the Section 301 additional duty for goods that match its description. It does not make the goods duty-free: ordinary (Column 1) duties still apply, as do any other measures that cover the same goods, such as Section 232 duties, antidumping or countervailing duties, or other Section 301 actions. Exclusions are time-limited and have been extended several times.

An Important Clarification: the current exclusions are not spread proportionally across the four lists. All of them come from the same investigation and are claimed under two HTSUS Chapter 99 provisions: 164 product-specific exclusions under heading 9903.88.69, and 14 solar manufacturing equipment exclusions under heading 9903.88.70. USTR extended this set of 178 exclusions in a notice published December 1, 2025 (90 FR 55232), following the trade and economic arrangement announced by the White House on November 1, 2025. The extension covers goods entered for consumption, or withdrawn from warehouse for consumption, before 11:59 p.m. on November 9, 2026. In that notice, USTR reported that 147 of the 178 exclusions received comments supporting extension, many stating that the products remained available only in limited quantities outside China.

2 · What Changed: The HTSUS Update

Why Conforming Amendments Are Needed

The HTSUS is periodically updated, and the U.S. International Trade Commission (USITC) revises the ten-digit statistical reporting numbers from time to time to improve trade data. Because the scope of each exclusion is defined by a ten-digit statistical number together with a product description, a change to those numbers can leave an exclusion pointing to a code that no longer exists, even though the products themselves have not changed. Effective July 1, 2026, the USITC made such changes, and USTR issued conforming amendments so that the exclusions continue to cover the same products.

The September 2, 2026 Notice

USTR’s notice (91 FR 56538, FR Doc. 2026-17925) amends U.S. notes 20(vvv)(i)(4), 20(vvv)(i)(5), 20(vvv)(i)(6), and 20(vvv)(iv)(4) in subchapter III of chapter 99 of the HTSUS. All four are claimed under heading 9903.88.69. The amendments are effective as of July 1, 2026, the date the new statistical numbers took effect.

Source: USTR, 91 FR 56538 (September 2, 2026). According to CBP’s guidance, goods covered by the three pump-part exclusions were previously reported under 8413.91.9065, 8413.91.9085, or 8413.91.9096. The full note text in the notice’s Annex governs scope.

The October 7, 2026 Notice

On October 7, 2026, USTR published a further conforming amendment to one additional exclusion, U.S. note 20(vvv)(i)(20) (FR Doc. 2026-20511), also effective as of July 1, 2026. CBP’s guidance indicates that this exclusion concerns certain machine parts now reported under 8479.90.9591. Together, the two notices amend five of the 178 exclusions.

⚠️ Critical Takeaway: The conforming amendments do not add new products or remove existing ones. They update the reporting numbers so that goods that qualified before July 1, 2026 continue to qualify under the new numbers.

3 · CBP Implementation

Entry Guidance

CBP issued entry guidance on the September notice through the Cargo Systems Messaging Service (CSMS #69990649) and later updated it to cover all five amended exclusions (CSMS #70261629). According to the updated guidance, ACE began accepting the amended exclusions at 6:00 p.m. on October 23, 2026. Entries claiming one of these exclusions report heading 9903.88.69 together with the applicable new ten-digit statistical number.

Entries Filed Since July 1, 2026

Because the amendments took effect as of July 1, 2026 but were published later, some entries filed in the interval may not have claimed an exclusion that was available. CBP’s guidance states that importers who paid Section 301 duties on products covered by these exclusions may file a Post Summary Correction (PSC) if the entry is still within the PSC filing timeframe. For entries outside that window, other procedures, such as a protest after liquidation, may be relevant; which applies depends on the status of each entry.

Claims That Do Not Match

The reverse situation also matters. An exclusion claim that does not match both the statistical number and the product description in the note is not valid, and the Section 301 duty for the product’s list would be owed. Accurate pairing of the Chapter 99 heading and the ten-digit number is therefore part of ordinary entry review.

4 · What This Means for Logistics Providers

Classification Data

Customs brokers and logistics providers that maintain classification data for clients commonly update their product databases and entry templates when statistical numbers change, so that both the new ten-digit number and the corresponding Chapter 99 exclusion heading are reported together.

Entry Filing

For brokers filing on behalf of importers, the practical points are consistent with any exclusion claim: the product must match the exclusion’s written description, the ten-digit number must be the one in effect on the date of entry, and the claim should follow CBP’s current CSMS guidance.

Client Communication

Because only five exclusions were affected, the issue is narrow. Providers often confirm with the relevant clients whether any of their products fall under the pump-part, plastics, or machine-part exclusions, and whether any entries since July 1, 2026 may warrant correction.

5 · Implementation Considerations

The following points are commonly reviewed by importers of products in the affected categories. They are offered for information, not as a checklist.

Matching Products to the Amended Notes

Importers often compare the ten-digit numbers used on their entries since July 1, 2026 against the amended notes, and confirm that the products also meet the written product descriptions.

Reviewing Entries Filed Since July 1, 2026

Where an eligible product was entered without claiming the exclusion, the status of each entry (unliquidated, within the PSC window, or liquidated) determines which correction route is available, as described in CBP’s guidance.

Keeping the Exclusion Term in View

The amended exclusions are part of the 178 exclusions that cover entries before 11:59 p.m. on November 9, 2026. Whether they continue beyond that date depends on any further USTR notice. Importers commonly follow the Federal Register, USTR’s Section 301 pages, and CBP’s CSMS messages for these decisions.

Seeking Classification Support

For specific classification or implementation questions, USTR’s notices direct readers to CBP at traderemedy@cbp.dhs.gov. Licensed customs brokers can also review entry data and classification.

⚠️ Critical Takeaway: The amendments are technical and narrow, but because exclusion coverage depends on exact ten-digit numbers, a change in reporting numbers affects whether a claim can be accepted on an entry.

6 · Conclusion: A Technical Update That Preserves Coverage

USTR’s conforming amendments keep five Section 301 exclusions aligned with the July 1, 2026 statistical reporting changes. The covered products are unchanged; the numbers used to report them have moved. CBP has issued entry guidance, ACE accepts the amended exclusions, and CBP has described the PSC route for eligible entries where duties were paid.

Key Takeaways

The Bottom Line

For most importers of Chinese goods, these amendments change nothing. For importers of the specific pump parts, plastic articles, and machine parts involved, they determine which ten-digit numbers support an exclusion claim from July 1, 2026 onward. Businesses that would like an outside review of their classifications or entry history may find it useful to work with a customs broker or trade compliance partner familiar with Section 301 exclusions.

The message is clear: the conforming amendments preserve the existing coverage of five Section 301 exclusions under new HTSUS statistical numbers, effective July 1, 2026, within the 178 exclusions that run through November 9, 2026.

This analysis reflects USTR’s Notice of Conforming Amendments to Product Exclusions (91 FR 56538, September 2, 2026), USTR’s Notice of Conforming Amendment to Product Exclusion (FR Doc. 2026-20511, October 7, 2026), USTR’s Notice of Product Exclusion Extensions (90 FR 55232, December 1, 2025), and CBP CSMS #69990649 and #70261629. Exclusion scope is governed by the full text of the U.S. notes in subchapter III of chapter 99 of the HTSUS. USTR may publish further notices, and CBP may update its guidance through CSMS. Organizations should consult with customs counsel and licensed customs brokers for guidance tailored to their specific products and circumstances.