Section 301 Apparel and Footwear Industry Deep Dive

Apparel and footwear from China fell on List 4A at 7.5% Section 301. Combined with high apparel base MFN (16-32%) and Section 122 (15%), effective rates often exceed 39-50%. Mitigation: First Sale for Export valuation, supplier shifts to Vietnam/Bangladesh, CAFTA-DR origin from Central American production.

This guide covers Section 301 Apparel and Footwear Industry Deep Dive. 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.

List 4A apparel and footwear coverage

Most consumer apparel and footwear from China fell under List 4A at 7.5% (originally 15%). Includes knit and woven apparel, footwear, accessories.

Combined effective rate

Base MFN 16-32% + Section 301 7.5% + Section 122 15% = 38.5-54.5% effective through July 24.

First Sale for Export – primary mitigation

For brands using middlemen, First Sale drops dutiable value 15-30%. Combined with high apparel rates, dollar impact is substantial.

Supplier shifts and CAFTA-DR

Vietnam, Bangladesh, India avoid Section 301. CAFTA-DR-qualifying production (DR, Guatemala, El Salvador, Honduras, Nicaragua, Costa Rica) avoids Section 122 plus provides preferential base rates.

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.