If you import parts or assemblies, Section 301 tariffs can change your landed cost quickly. These duties stack on top of normal tariffs and sometimes on top of Section 232 metals tariffs. This guide explains what Section 301 tariffs are, who pays them, how they interact with Section 232, and how Redstone can help you check your specific part.<\/p>\n
Get a Quote from Redstone Manufacturing<\/a><\/p>\n To understand who pays and how tariffs stack, you first need a basic picture of how a Section 301 action starts. The process follows a defined sequence. An interested party files a petition with the Office of the United States Trade Representative (USTR), or USTR opens a case on its own. USTR then investigates whether the foreign country\u2019s acts, policies, or practices are unfair and burden U.S. commerce. If USTR makes an affirmative determination, it announces enforcement measures, typically additional duties on a list of products from the named country. USTR must publish notice of an investigation in the Federal Register and provide opportunity for public comment and hearing.<\/a><\/p>\n Two examples show how this plays out over time. The first is the China investigation. The first Section 301 action against China took effect July 6, 2018, adding a 25% duty on Chinese products with an approximate annual trade value of 34 billion dollars.1<\/sup> A second action followed August 23, 2018, covering an additional 16 billion dollars in goods at 25%.1<\/sup><\/a> Those lists, along with later rounds, remain in force in 2026.<\/p>\n The second example is the July 2026 forced-labor action. On July 23, 2026, President Trump directed USTR to impose Section 301 tariffs on goods from 60 economies tied to forced-labor enforcement failures, with tariffs taking effect July 24, 2026, at rates of 10% or 12.5% depending on whether the economy had adopted a forced-labor import prohibition.1<\/sup><\/a> China, which did not adopt such a prohibition, falls in the 12.5% tier, which stacks on top of the existing China Section 301 list tariffs that remain in place.1<\/sup><\/a><\/p>\n The China tariff program is also under active review. USTR released a notice on May 5, 2026, announcing the initiation of the second statutory four-year review of the 2018 Section 301 actions against China.<\/a> Under the Trade Act of 1974, Section 301 actions terminate on their four-year anniversary unless domestic industries request continuation and USTR conducts a review.<\/p>\n Once a Section 301 duty applies, the importer of record becomes legally responsible for it. The importer of record owes the duty to U.S. Customs and Border Protection (CBP) at the time of entry.<\/a> The importer of record is the party legally responsible for the customs entry, including HTS classification, filing, and payment.<\/a> That legal liability does not shift to a customs broker, freight forwarder, or supplier, even when a broker files the entry on the importer\u2019s behalf.<\/a><\/p>\n Legal liability and economic burden do not always sit in the same place. The importer of record pays CBP, but commercial pricing can move the cost elsewhere in the supply chain through the landed cost, and procurement may negotiate based on an assumed duty rate.<\/a> A seller quoting on Delivered Duty Paid (DDP) terms absorbs the duty into the unit price and acts as importer of record.<\/a> Under Free On Board (FOB) terms, the buyer is responsible for import clearance and paying the duty and typically takes on the importer-of-record role, although customs law still controls who holds that status.<\/a> The tariff bill lands in one place legally. The contract determines where it lands economically.<\/p>\n For most U.S. equipment makers buying parts overseas, this distinction affects day-to-day decisions. If the supplier quotes FOB, the buyer becomes the importer of record and owns every customs obligation. If the supplier quotes DDP, the supplier carries that responsibility, but the buyer still needs to know what rate the supplier assumed and who covers any difference if rates change between quote and shipment.<\/p>\n Section 301 and Section 232 often apply at the same time. They do. To understand why, you need to treat the two statutes as separate layers with different triggers.<\/p>\n Section 301 is country-based. It applies because of where a part was made. The China duties, imposed after the 2018 investigation into technology transfer and intellectual property practices, are the ones most buyers have seen. The July 2026 forced-labor action extended Section 301 to 60 economies, but the China lists remain the most significant for industrial parts.<\/p>\n Section 232 is material-based. Section 232 is authorized under the Trade Expansion Act of 1962 and administered by the Department of Commerce and the President. It targets specific product categories on national security grounds, primarily steel, aluminum, copper, automobiles, and semiconductors, regardless of origin country.<\/a> Its derivative product lists are what pull ordinary custom parts into scope. A simple steel bracket is not a strategic asset by itself, yet it still counts as steel for Section 232 purposes.<\/p>\n The two layers stack in most situations. A single imported steel component from China could be subject to ordinary customs duty, Section 301 additional duties, Section 232 steel tariffs, and antidumping and countervailing duties at the same time.<\/a> A steel bracket made in China catches a Section 232 duty because it is steel and a Section 301 duty because it is Chinese. Both sit on top of the ordinary duty rate for its HTS code.<\/p>\n One recent change in Section 232 calculations has surprised many buyers. As of April 6, 2026, Section 232 tariffs on steel, aluminum, and copper apply to the full customs value of the covered article and its derivatives. This replaced the prior system that measured Section 232 tariffs on derivatives by the precise metal content of the imports.<\/a> A part that was previously assessed only on its metal content is now assessed on its full entered value. That shift matters for machined or fabricated parts where labor and processing represent a large share of the cost.<\/p>\n The United States-Mexico-Canada Agreement (USMCA) adds another layer of complexity. Preferential treatment under USMCA depends on North American content thresholds, not only on final assembly location. A part assembled in Mexico from predominantly Chinese inputs does not automatically qualify for USMCA treatment. Even when a part qualifies, it may still face Section 232 duties depending on the specific proclamation language.<\/a><\/p>\n For a deeper look at how a landed number is built from these layers, see our Section 301 Tariff Calculator. For material-side detail on Section 232, see our Section 232 steel and aluminum guide<\/a>.<\/p>\n See How Your Part Stacks Up<\/a><\/p>\n Section 232 metals tariffs follow a different logic from Section 301 and focus on where the metal itself was produced. Duty on steel and aluminum follows where the metal was produced, not where the part was made.<\/a> This rule sits inside the Section 232 framework and often surprises buyers.<\/p>\n The operative standard is \u201cmelted and poured\u201d for steel and \u201csmelted and cast\u201d for aluminum.<\/a> Products made abroad with qualifying U.S.-origin metal inputs may receive a reduced 10% Section 232 rate instead of the higher default rate.1<\/sup><\/a> A June 1, 2026 proclamation lowered the threshold for products to qualify as made entirely from U.S.-origin aluminum, steel, or copper from 95% to 85% by weight.<\/a><\/p>\n This rule enables a legitimate structure that many manufacturers can use. A buyer purchases U.S.-origin steel or aluminum, ships it to an overseas facility for casting or fabrication, and then brings the finished part back. Because the metal was melted and poured in the United States, the Section 232 duty exposure is reduced even though the part was manufactured abroad. The rule tracks the metal, not the machining or assembly location.<\/p>\n This structure follows the published proclamations and relies on accurate documentation. The proclamations explicitly establish the reduced rate for parts made from qualifying U.S.-origin metal. Documentation of the metal\u2019s origin is required, and CBP can impose penalties for misrepresentation. The structure only works when the metal genuinely qualifies.<\/p>\n Section 301 exclusions provide another way to reduce duty exposure for specific products. An exclusion is a product-specific exemption from a Section 301 tariff, granted by USTR for a defined period. Exclusions do not apply automatically. They must be requested through USTR\u2019s formal process and are granted or denied on a product-by-product basis, not a company-by-company basis.<\/p>\n Section 301 does not specify a tariff exclusion process in the statute itself. The exclusion process has been established administratively by USTR for each Section 301 action.<\/a> A request must identify the specific 10-digit HTS code, describe the product in technical terms, and show why the tariff causes disproportionate harm.<\/a> Requests based mainly on intended end use are rejected, so detailed technical specifications matter.<\/a><\/p>\n Granted exclusions are retroactive to the date the applicable tariff took effect, but most exclusions carry expiration dates and must be renewed.<\/a> As of 2026, Section 301 exclusions carried over under the November 2025 U.S.-China arrangement lapse on November 10, 2026.<\/a> An exclusion that applies today may not apply to a shipment that arrives in early 2027. Buyers whose parts currently enter under an exclusion should model both scenarios before committing to orders that will land after that date.<\/p>\n Checking Section 301 exposure for a specific part starts with the correct HTS code. The Harmonized Tariff Schedule of the United States (HTSUS) is a 10-digit classification system that assigns every imported product a code based on its material composition and end use.<\/a> That code determines the base duty rate, whether Section 301 applies and at which rate, and whether Section 232 metals duties are in scope. The Section 301 lists are organized by HTS code and country of origin, so a part\u2019s classification becomes the key that opens or closes its tariff exposure.<\/p>\n Classification rarely feels intuitive. A single digit difference at the 8- to 10-digit HTS level can change whether a product is in scope for Section 301 additional duties.<\/a> Copying a supplier\u2019s export code does not provide a safe shortcut. Chinese exporters classify for Chinese export purposes, and those codes frequently do not match the U.S. schedule.<\/a> The liability for any error falls on the importer of record.<\/a><\/p>\n The practical move for a buyer without customs experience is to send the drawing or part number for review. Unless someone has real machining experience, they generally cannot tell whether a part requires 5-axis machining. The same idea applies to tariff classification. Some parts that appear straightforward carry unexpected Section 301 or Section 232 exposure based on their material or end use. Some parts that look exposed qualify for exclusions or reduced rates based on metal origin. Sending the drawing lets a specialist review the part and explain whether Section 301 applies, how the layers stack, and what the landed cost looks like.<\/p>\n Redstone simplifies this entire picture by taking on the importer-of-record role. Redstone acts as importer of record on modified DDP terms. Tariffs, duties, customs, and freight roll into one landed unit price. The customer does not have to file anything, talk to a customs broker, or handle customs questions. HTS classification is handled based on end use. Duties are included at rates in effect as of the quote date and adjusted at shipment if they change.<\/p>\n Because Redstone acts as importer of record, you get a U.S. company standing behind every order. Repair, replacement, or refund responsibility sits with a U.S. company under a U.S. contract. Parts are manufactured at ISO 9001 certified facilities. If tariffs or conditions change, Redstone can move your program between its facilities in China, India, Taiwan, Vietnam, and Mexico without you requalifying a supplier. One American point of contact owns the program from quote through delivery.<\/p>\n The metal-origin rule, the stacking mechanics, and the exclusion landscape all factor into Redstone\u2019s work before a quote goes out. The customer sees one number.<\/p>\n See Your Landed Cost In One Number<\/a><\/p>\n Yes. The original China Section 301 lists from 2018 remain in force<\/a>, and a second four-year review initiated in May 2026 is ongoing. The July 2026 action added a new Section 301 layer on goods from 60 economies. For current rates and coverage, see the Key Takeaways section and linked sources. Section 301 tariffs remain in effect unless the statutory four-year termination rule applies without a continuation request and review, or USTR modifies or ends them.<\/a><\/p>\n Yes, in most cases. As explained earlier, Section 301 is triggered by country of origin and Section 232 by material category, mainly steel, aluminum, and copper. A steel part from China can therefore face both duties on top of the ordinary HTS duty rate, unless a specific action such as the July 2026 forced-labor measure carves out an exception.<\/p>\n The importer of record pays the duty to U.S. Customs and Border Protection at the time of entry. The importer of record is the party legally responsible for the customs entry, and that liability does not transfer to a customs broker or freight forwarder. The economic cost can move through the supply chain via pricing, but the legal obligation stays with whoever holds the importer-of-record role under customs law and the contract.<\/p>\n A Section 301 exclusion is a product-specific, time-limited exemption from a Section 301 tariff, granted by USTR after a formal request process. Exclusions are not automatic and must be requested using the specific 10-digit HTS code and detailed technical product specifications. Most exclusions carry expiration dates and must be renewed. As of 2026, exclusions carried over from the November 2025 U.S.-China arrangement are set to lapse on November 10, 2026.<\/p>\n The first step is determining the correct 10-digit HTS classification for the part, which depends on its material composition and end use. The Section 301 lists are organized by HTS code and country of origin, so the classification determines whether and at what rate Section 301 applies. Because classification requires customs expertise and a single digit difference can change the outcome, the most reliable approach for a buyer without customs experience is to submit a drawing or part number for review by someone who handles this work regularly.<\/p>\n You now have a clearer view of how Section 301 tariffs work, how they stack with Section 232, and how the metal-origin rule can change your duty exposure. The next step is to see how these rules affect your specific parts. Send a drawing or part number and Redstone will review whether Section 301 applies, how the tariff layers stack, and what the landed cost looks like. No customs knowledge required on your end.<\/p>\n Send a Drawing, Get a Straight Answer<\/a><\/p>\n 1<\/sup> Tariff rates change often. Always check the US Customs and Border protection website for the latest information.<\/p>\n<\/div>\n Learn how Section 301 tariffs work, who pays, and how they stack with Section 232. Redstone Manufacturing helps you source smarter. Get a quote today.<\/p>\n","protected":false},"author":118,"featured_media":194,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"inline_featured_image":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-195","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-uncategorized"],"_links":{"self":[{"href":"https:\/\/redstonemanufacturing.com\/resources\/articles\/wp-json\/wp\/v2\/posts\/195","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/redstonemanufacturing.com\/resources\/articles\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/redstonemanufacturing.com\/resources\/articles\/wp-json\/wp\/v2\/types\/post"}],"replies":[{"embeddable":true,"href":"https:\/\/redstonemanufacturing.com\/resources\/articles\/wp-json\/wp\/v2\/comments?post=195"}],"version-history":[{"count":0,"href":"https:\/\/redstonemanufacturing.com\/resources\/articles\/wp-json\/wp\/v2\/posts\/195\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/redstonemanufacturing.com\/resources\/articles\/wp-json\/wp\/v2\/media\/194"}],"wp:attachment":[{"href":"https:\/\/redstonemanufacturing.com\/resources\/articles\/wp-json\/wp\/v2\/media?parent=195"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/redstonemanufacturing.com\/resources\/articles\/wp-json\/wp\/v2\/categories?post=195"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/redstonemanufacturing.com\/resources\/articles\/wp-json\/wp\/v2\/tags?post=195"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}How Section 301 Works In Practice<\/h2>\n
Who Actually Pays The Section 301 Tariff<\/h2>\n
How Section 301 And Section 232 Stack<\/h2>\n
The Metal-Origin Rule For Steel And Aluminum<\/h2>\n
Section 301 Tariff Exclusions Explained<\/h2>\n
How To Check Whether Your Product Is Subject To Section 301 Tariffs<\/h2>\n
Where Redstone Manufacturing Fits In<\/h2>\n
Frequently Asked Questions<\/h2>\n
Are Section 301 Tariffs Still Active In 2026?<\/h3>\n
Do Section 301 Tariffs Stack With Section 232?<\/h3>\n
Who Actually Pays The Section 301 Tariff?<\/h3>\n
What Are Section 301 Tariff Exclusions?<\/h3>\n
How Can I Check If My Product Is Subject To Section 301 Tariffs?<\/h3>\n
Send A Drawing, Get A Straight Answer<\/h2>\n
\nRead Next<\/h2>\n
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