China-origin goods pay Section 301 (List-specific 7.5-25%) plus Section 122 (15%) plus base MFN. Effective rates 22-42% through July 24, 2026 expiration. After Section 122 expires, China-origin goods continue to pay Section 301 plus base MFN.
This guide covers Section 301 + Section 122 Stacking on China Imports. The Section 301 program targets China-origin goods at rates of 7.5-25% across Lists 1-4A, with periodic exclusion processes.
For SMB importers paying Section 301, mitigation options include reclassification, supply-chain shifts, USMCA qualification on Mexican production, and exclusion requests where available.
Worked example – List 3 product at 25% Section 301
China-origin industrial machinery, base MFN 2.5%, List 3 covered. Effective rate: 2.5% + 25% (Section 301) + 15% (Section 122) = 42.5% effective through July 24.
Worked example – List 4A product at 7.5% Section 301
China-origin apparel, base MFN 16.5%, List 4A covered. Effective rate: 16.5% + 7.5% + 15% = 39% effective.
What changes after July 24
Section 122 expires (statutorily, unless Congress acts). Section 301 continues. Effective rates drop by 15% – significant relief for high-Section-301 product categories.
Successor scenario implications
If Section 232 sectoral expansions cover specific China-origin products, those products may move from Section 301 + Section 122 stack to Section 232 + Section 301 stack – effective rates depend on Section 232 coverage and rate.
Frequently asked questions
Does Section 301 still apply in 2026?
Yes. Section 301 has no statutory expiration and continues in force. The current administration has indicated periodic adjustments but not termination.
Can I file a Section 301 exclusion request?
Periodic exclusion processes have run since 2018; the current process status varies. We track active and pending exclusion windows.
How does Section 301 stack with Section 122?
Both apply to China-origin goods. Section 122 (15%) plus Section 301 (List-specific 7.5-25%) plus base MFN. Effective rates often 22-42%.
Can shifting from China to Vietnam or Mexico help?
Yes – provided substantial transformation actually occurs in the new origin country. Misclaimed origin exposes you to retroactive Section 301 plus Section 1592 penalties.
How do you help with Section 301 work?
We run classification audits, supply-chain shift feasibility analyses, USMCA qualification reviews, and exclusion requests. Engagements typically $5,000-$15,000 fixed-fee per project.
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