Q4 2026 Import Deadline Calendar: Nine Dates From the September 24 Trump–Xi Summit to the December 4 Polysilicon Tariff — and Which Ones Run Backwards for Bonded Inventory

# Q4 2026 Import Deadline Calendar: Nine Dates From the September 24 Trump–Xi Summit to the December 4 Polysilicon Tariff — and Which Ones Run Backwards for Bonded Inventory

The September calendar is almost worked through: Canada's counter-tariffs went live on the 8th, the copper smelt-and-cast hard reject hit ACE on the 14th, the Court of International Trade heard the AD/CVD refund motion on the 15th, and the Section 338 list was rewritten the same day. What is left of September is the heaviest single week of the year for entry timing, and October through early December is not much lighter.

This is the fourth-quarter calendar as it stands on Monday, September 21. Nine dates, in order, each with the population it hits, the entry-line consequence, and — because five of the nine move the rate on a specific day — which way the deadline "runs" for goods sitting in a customs bonded warehouse or FTZ. On a rate increase, bonded inventory should be withdrawn before the date. On a rate cut or a refund, it should stay in bond past it. The distinction is worth real money in Q4, and it is the reason the bonded-warehouse angle recurs in almost every entry below.

Dates are Eastern time. Where an effective time is 12:01 a.m., the last safe entry is the business day before.

The calendar at a glance

Two dates are pending and could land anywhere in this window: the Section 301 excess-capacity determination on China (expected to recommend 7.5%, held until after the summit), and the president's signature on the Sanctioning Russia and Iran Act, which authorizes contingent 100% secondary tariffs. Both are covered in their own sections.

September 23–25: the Trump–Xi summit and the tariffs on hold

Xi Jinping's state visit runs September 23–25 with the bilateral meeting on the 24th. The reason it matters at the entry line is what is *not* happening around it: Bloomberg and Inside U.S. Trade both reported last week that the administration is holding new tariff announcements — including the Section 301 excess-capacity determination on China, which is expected to recommend 7.5% — until after the meeting. The summit playbook walks through the stack math: the China layer today is 12.5% forced-labor 301 plus the original 301 lists, which means a typical List 3 good sits at 40.5% and would move to 48% with the excess-capacity layer, before the November 9 exclusion lapse adds more for the 178 excluded lines.

The bonded direction here is the unusual one: do not front-run. The last two rounds of Section 301 changes used a four-day gap between Federal Register publication and effective date. If the outcome of the summit is a rate cut or an extension of the truce, goods withdrawn this week paid a rate they did not need to. If it is the 7.5% layer, the four-day precedent leaves enough time to run withdrawals after the notice publishes. The withdrawals guide covers how to have those entries pre-built so they can be filed the day the notice posts.

The Russia sanctions bill is the other overhang. The House passed it September 16, the Senate in August, and the White House has said the president will sign within days. It does not change a rate on signature — it creates an authority the president can pull, with broad waivers — but it is the reason to keep a scenario in the model that adds 100% to Chinese, Indian and Turkish lines.

September 29, 12:01 a.m.: the pharma tariff reaches everyone

The Section 232 pharmaceutical proclamation has been live for the companies named in Annex III since July 31. At 12:01 a.m. on September 29, the same ladder — 0% for generics, 15% for EU, Japan, Korea and Switzerland origin under the framework deals, 100% default for patented articles — applies to every other importer of covered patented drugs, active ingredients and key starting materials. The three-weeks-left checklist is now a one-week checklist and the items on it have not changed: confirm Annex I coverage by HTS and product, confirm Annex II/III status with the manufacturer if you distribute rather than make, and file consumption entries on everything covered that is on the ground.

Bonded direction: enter before. The rate that applies to a warehouse withdrawal is the rate in effect on the day of withdrawal, so covered inventory in bond or in an FTZ on September 29 pays the 100% layer when it comes out. Monday September 28 is the last full business day. In-transit language does not appear in this proclamation; cargo on the water is not protected.

September 29: Section 338 goes from a 50% duty to an import ban

The same morning, a separate set of Canadian goods stops being importable at all: packaged beer, wine and spirits, whey products, molasses, non-alcoholic beer and motorcycles over 800 cc. The Section 338 playbook has the HTS-level lists. USMCA origin does not help, and the ban sits on top of the 50% Section 338 duty and the Section 232 layers that stack on Canadian goods since September 15.

The transitional rule is the important one. Goods imported before September 29 but not yet entered for consumption — or in a bonded warehouse and not yet withdrawn — remain subject to the 50% duty rather than the prohibition *if they are entered or withdrawn before the 29th*. Bonded direction: enter before, and this is the one deadline on the calendar where the bonded-warehouse hedge stops working entirely. A bonded warehouse defers duty; it does not cure inadmissibility. Covered Canadian inventory that is still in bond on September 29 has two exits left, and consumption is not one of them: export it directly on a withdrawal for exportation (CBP Form 7512, immediate exportation), or move it under a T&E to a port of exit. Neither pays duty, and both need to be booked this week, not next.

October 1: the sugar TRQ year and the fiscal year

October 1 is quieter than it looks. The FY2027 raw cane sugar tariff-rate quota opens with the WTO minimum of 1,117,195 metric tons raw value, and refined-sugar and specialty allocations follow. It is a quota date, not a rate date, so the bonded direction is neutral: sugar-containing product importers who use bonded storage to time entries against quota fill should have the quota-status report open, not the tariff schedule.

The new federal fiscal year is also when CBP's annual bond sufficiency reviews tend to generate the most insufficiency letters, because the prior year's duty totals are complete. With the 301 forced-labor layer, Section 338 and the pharma tariff all adding to 2026 duty liability, continuous bonds written against 2025 numbers are the ones most likely to be flagged. Run the customs bond calculator on trailing-twelve-month duties, taxes and fees before CBP does.

October 6: CAPE Phase 3 and the finally liquidated IEEPA refunds

CBP's September 15 court declaration confirmed that Phase 3 of the CAPE refund program deploys in ACE on October 6. It is the first path to refunds on *finally liquidated* IEEPA entries — the population that Phases 1 and 2 could not touch — and it is narrower than the headline: day-one eligibility is limited to plaintiffs covered by a CIT reliquidation order who submitted a valid importer-of-record number by July 30. Everyone else waits for instructions, and DOJ's appeal still hangs over the whole population. The eligibility checklist has the three-population table and the pre-October 6 to-do list, including the $1.3 billion currently frozen for missing ACH details.

Bonded direction: neutral. This is money coming back, not duty going out. The practical link to Q4 inventory is cash flow: importers expecting a Phase 3 refund in October have a reason to *keep* duty-paid inventory lean and let bonded inventory sit until the refund lands, rather than paying December's duty in September.

October 22: CPSC eFiling reaches mail shipments

Mandatory CPSC certificate eFiling through ACE has applied to covered consumer products since July 8. On October 22 the requirement reaches shipments arriving through the postal channel, and the FTZ-withdrawal phase is scheduled for January 8, 2027. This is a data deadline rather than a rate deadline — the exposure is a held shipment, not a duty bill — so the bonded direction is neutral. The relevant note for bonded operators is the January 8 date: goods entering a zone now that will be withdrawn after that date will need certificate data at withdrawal, and the certificate should travel with the receiving paperwork.

November 9, 11:59 p.m.: the last 178 China exclusions expire

All remaining China Section 301 product exclusions under heading 9903.88.69 expire at 11:59 p.m. Eastern on November 9. As of this writing USTR has not opened the comment docket that preceded the last two extensions, which is the strongest signal yet that this one lapses. The eight-week snap-back playbook has the exposure test and the four-scenario decision table for Q4 buys.

Bonded direction: enter before. An excluded line that is in bond on November 10 pays the full List rate on withdrawal — 25% for a List 3 good, on top of the 12.5% forced-labor layer — where the same line withdrawn on November 9 pays only the forced-labor layer. This is the deadline that most directly rewards a weekly-withdrawal cadence: pull the excluded SKUs out through October and the first week of November as they sell, leave the non-excluded SKUs in bond, and do not pay November's duty on everything to protect the third of the inventory that is actually exposed.

December 1: CBP's heightened-disclosure ANPRM comments close

CBP's advance notice of proposed rulemaking on heightened import disclosures — foreign export documentation, manufacturer and supplier identification, valuation support — closes for comments on December 1. The ANPRM summary covers what CBP is asking for. This is a rulemaking date, not an entry date, but it is the single best window this year for importers to put on the record what a foreign-export-document requirement would cost in practice. Bonded direction: neutral.

December 4: polysilicon minimum import prices plus 15%

Proclamation 11052 takes effect December 4: minimum import prices of $21/kg on polysilicon, $100/kg on wafers, $0.22/W on cells and $0.38/W on modules, plus a 15% Section 232 tariff on ingots, wafers, cells and modules, stacked on Section 301 and AD/CVD. The polysilicon playbook has the stacking math on a real invoice and the MIP certification, whose penalty for a materially inaccurate statement is an import bar for the importer *and its affiliates*.

Bonded direction: enter before, with a caveat that does not appear on any other date on this list. The proclamation carries an anti-stockpiling clause, and a pattern of unusually large consumption entries in November against a rate change on December 4 is exactly what it is written to catch. Bonded inventory withdrawn at the normal cadence through the fall is defensible; a single 400% November is not. Importers with covered goods on order should be modeling the December 4 rate as the base case now and treating November withdrawals as the last step of a normal season, not a front-run.

The two dates without a date

Section 301 excess capacity. Sixteen economies, 21 sectors, hearings closed May 8, the July 24 target passed with nothing published, and the statutory window runs into March 2027. The China piece is expected first and is expected to recommend 7.5%, consistent with the 20% cumulative cap agreed at Busan and reaffirmed in Beijing in May. Bonded direction once it posts: enter before, using the four-day gap.

USMCA. The review has split into a U.S.–Mexico track that is grinding forward and a U.S.–Canada track that has collapsed into Section 338. USTR is now describing "interim arrangements" by year-end rather than a deal. The two-tracks playbook has the three scenarios. Nothing changes at the entry line until a proclamation posts, and the rate-on-withdrawal rule makes bonded storage the cleanest hedge on both tracks.

The Q4 modeling discipline

Every date above changes a rate, a quota, a refund or a data requirement on a specific day, and most of them stack. The only way to keep the model honest is to run each lane as a scenario per entry date: today's rate; today plus the layers already on the calendar (7.5% for China, the November 10 exclusion lapse, December 4 for solar); and each of those plus the contingent layers (100% under the Russia sanctions act). For multi-line invoices, importers commonly do this in classification software such as Zonos, which saves a scenario per entry date rather than rebuilding the sheet every time a notice posts. (Disclosure: this is an affiliate link — FreightFigures may earn a commission if you sign up, at no additional cost to you. See our affiliate disclosure.) For a single line, the tariff stacking calculator does the same arithmetic without the setup, and the duty deferral calculator will tell you what a bonded week is worth against each of the "enter before" dates.

This week's checklist (September 21–25)

1. Pharma, by Monday the 28th: consumption entries on every covered patented article, API and KSM on the ground; withdrawals from bond and FTZ for the same. Confirm Annex II/III status in writing if you are a distributor.
2. Canadian alcohol, whey, big motorcycles, by Monday the 28th: enter for consumption at 50%, or book the export withdrawal. Nothing on the ban list should still be in bond on the 29th.
3. China lanes: do *not* withdraw ahead of the summit. Pre-build the withdrawal entries for the excess-capacity scenario so they can be filed inside the four-day gap if the notice posts.
4. Excluded China lines: start the weekly withdrawal cadence now — seven weeks to November 9.
5. Bond sufficiency: run trailing-twelve-month duties before October 1, with the 301 forced-labor and Section 338 layers included.
6. CAPE Phase 3: confirm your IOR number status and ACH enrollment before October 6 if you are in the plaintiff population.
7. Solar: model December 4 as the base case; keep November withdrawals at the seasonal norm.

Where the bonded capacity is

Five of the nine dates reward bonded inventory that can be withdrawn on a specific day, and two of them — pharma and the Canadian ban — need capacity that can turn withdrawals and export paperwork inside a week. That is not a Q1 planning conversation; it is a this-week conversation. If the freight comes through the Southeast, the Port of Charleston importer's guide covers the local mechanics, the entry type 21 walkthrough covers getting goods into bond, and the withdrawals guide covers getting them out on the right day.

The Bottom Line

Q4 2026 has nine hard dates and two floating ones, and the direction each one runs for bonded inventory is not the same. September 29 (pharma), November 9 (exclusions) and December 4 (polysilicon) reward withdrawing before. The September 29 Canadian ban rewards withdrawing before and then closes the door entirely. The Trump–Xi summit and the excess-capacity determination reward waiting, then moving inside a four-day window. October 6 is money coming back. Build the calendar into the withdrawal schedule now, because the next six weeks decide whether December's duty is paid on what sold or on everything.

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