Section 301 China Exclusions Expire November 10, 2026: The Eight-Week Snap-Back Playbook for Importers

Section 301 China Exclusions Expire November 10, 2026: The Eight-Week Snap-Back Playbook for Importers

There is a quieter tariff clock running underneath the Section 338 and pharma headlines, and it hits a lot more importers. All 178 remaining product exclusions from the China Section 301 tariffs expire at 11:59 p.m. ET on November 9, 2026. Any China-origin entry filed on or after November 10 that today claims heading 9903.88.69 pays the underlying list rate again — 25% on Lists 1, 2 and 3, 7.5% on List 4A — unless USTR acts first.

Eight weeks out, USTR has not acted. In each of the last two cycles the agency opened a public comment docket roughly ten weeks before the deadline (the September 16, 2025 notice preceded the December 1, 2025 extension). As of September 16, 2026 we could not find a comparable comment request in the Federal Register. That is not proof the exclusions will lapse — the last extension was announced only after a presidential summit and landed eight weeks before the prior expiry — but it means the leading indicator that usually shapes the next cycle has not appeared yet, and planning has to start from the snap-back, not the extension.

This article covers what actually expires, who is exposed, what the November 10 date means for goods sitting in a bonded warehouse (it is not what most people assume), and a four-scenario decision table for Q4 buys. It complements our standing Section 301 explainer and the tariff-stacking guide.

What expires on November 10 — and what does not

The 178 exclusions are the survivors of the 2018–2020 exclusion rounds and the 2024 four-year review: 164 product-specific exclusions and 14 exclusions for solar-manufacturing equipment. USTR extended all 178 on December 1, 2025 (FR Doc 2025-21671) through 11:59 p.m. ET November 9, 2026, framing the extension as part of the trade-and-economic arrangement announced after the Trump–Xi meeting on November 1, 2025. On September 2, 2026 USTR amended four of the exclusions to track July 1 HTSUS statistical-suffix changes; that housekeeping notice did not touch the expiry date.

Mechanically, every one of the 178 is claimed the same way: the broker reports the 10-digit classification plus 9903.88.69 as the Chapter 99 secondary code, and the underlying list code (9903.88.01, .02, .03, .04 or .15) drops off the line. The product description in the annex — not the HTS code — is what makes the claim valid, which is why CBP verification letters on 9903.88.69 claims almost always ask for the spec sheet rather than the classification ruling.

What does not change on November 10:

• The Section 301 rates themselves. Lists 1–4A stay in force at 25% / 7.5%; the strategic-sector increases from the 2024 four-year review (100% EVs, 50% semiconductors and solar cells, 25% batteries, cranes, certain steel and aluminum) are unaffected because they were never eligible for the exclusion umbrella in the first place.
• The Section 301 forced-labor action that went live July 24. That is a separate investigation with its own Chapter 99 headings. An exclusion under 9903.88.69 never removed it, and its expiry does not add to it.
• Section 232 metals duties, AD/CVD, MPF and HMF. The exclusion only ever suppressed the Section 301 layer.

Who is actually exposed

The honest answer is "fewer importers than the 2019 exclusion era, but more concentrated." The 178 lean heavily toward industrial inputs and capital equipment: pumps, motors and compressors; specialty chemicals and intermediates; wear parts for recycling and metals processing; certain medical consumables; and the 14 solar-manufacturing tooling lines. If you import consumer goods on List 4A you are mostly already paying 7.5% and this deadline changes little. If you import a covered industrial line on List 3 you have been paying MFN only, and on November 10 your effective rate jumps by 25 points.

The fastest way to find out whether you are exposed is not the annex — it is your own entry data. Ask your broker to pull every entry line filed under 9903.88.69 since November 30, 2025, sorted by entered value. That list is your exposure, line by line, and the total entered value times 25% (or 7.5% for List 4A lines) is the annual cost of the snap-back. Most importers with a real exposure find it is concentrated in two or three suppliers.

The bonded-warehouse question: this deadline runs backwards

Most of the tariff deadlines we have covered this year — the Section 122 sunset, the Section 338 list changes, the USMCA interim-arrangement scenarios — reward *holding* goods in bond and withdrawing later. That is because duty is assessed at the rate in effect on the date of withdrawal for consumption, and in those cases the rate was expected to fall.

November 10 is the mirror image. The exclusion is valid for entries — including withdrawals from warehouse for consumption — made through 11:59 p.m. ET November 9. A covered SKU sitting in a bonded warehouse on November 10 loses the exclusion at withdrawal, exactly as a container on the water does. So the first-order bonded play here is not "hold." It is withdraw covered inventory before the deadline and let goods you would otherwise have kept in bond into the commerce of the United States while 9903.88.69 still works. If you are storing covered product in bond today, put a withdrawal on the calendar for the first week of November, with the ACE filing lead time built in. Our withdrawals guide walks through partial withdrawals if you only want to release part of a lot.

There is a second-order play that runs the other way, and it is the one worth talking to a bonded operator about now. The last extension was published December 1, 2025, *after* the prior November 29 expiry, with an effective date of November 30 — in other words, USTR let the prior window close and then reopened it with a gap of a single day. If the same pattern repeats, a covered container that arrives in mid-November has three choices: enter it for consumption and pay the snap-back rate with no refund mechanism if an extension follows; hold it at the terminal and eat demurrage while waiting for a notice that may not come; or move it into a bonded warehouse under a Type 21 entry, pay nothing at entry, and withdraw at whatever rate is in effect on the day you choose. If an extension arrives, you withdraw under 9903.88.69. If it does not, you have lost only storage, and you still have the option to re-export from bond without ever paying the 301 duty. That is the correct use of bonded storage on this deadline: not to beat the expiry, but to avoid being forced into a 25% entry during the weeks when USTR is most likely to act.

Run the arithmetic before you commit. The Duty Deferral Calculator compares the carrying cost of bond against the duty at stake; for a $400,000 List 3 container, the $100,000 of Section 301 duty in question dwarfs a few weeks of bonded storage, and the break-even is measured in months, not weeks.

Four scenarios for Q4 buys

Here is the decision table we would model for any covered SKU with a purchase order open right now. Assume a $250,000 line, List 3, 3% MFN.

The point of the table is that Scenarios B and C are the same container on the same date, and the only variable is whether it was entered for consumption or into bond. On a 25-point swing, the entry type is the decision.

An eight-week checklist

1. Pull the 9903.88.69 report from your broker this week: every line since November 30, 2025, with entered value, list code and supplier. That is your exposure.
2. Re-verify each claim against the current annex (FR Doc 2025-21671, Annexes A and B, as amended September 2, 2026). USTR has narrowed descriptions in past cycles and CBP can act on unliquidated entries.
3. Model the snap-back per line. For multi-line invoices, importers commonly run classification and duty per line in software such as Zonos, which lets you save a scenario per entry date rather than rebuilding the sheet each 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 full affiliate disclosure.) Cross-check the stacked result with the Tariff Stacking Calculator if the line also carries Section 232 content.
4. Calendar withdrawals for any covered inventory currently in bond, targeting the first week of November with lead time.
5. Decide the bond-or-enter rule for November arrivals now, while there is no pressure: our suggestion is bond anything covered that lands November 10 or later, with a standing withdrawal trigger of "extension notice published" and a hard review date of December 15.
6. Watch the Federal Register for a USTR comment request. If one appears, plan for an extension or a narrowing. If nothing has appeared by mid-October, plan for the snap-back as the base case.
7. Talk to suppliers about ship dates. Pulling a November shipment into October is the cheapest fix available and it only works if you ask in September.

The Bottom Line

The 178 China Section 301 exclusions expire at 11:59 p.m. ET on November 9, 2026, and on current evidence USTR has not started the process that preceded the last two extensions. Exposure is concentrated in industrial and capital-equipment lines on Lists 1–3, where the snap-back is a 25-point jump in effective rate. Unlike most of this year's deadlines, bonded storage does not beat this one — the exclusion is lost on withdrawal after November 9 just as it is on entry — so the first move is to withdraw covered inventory before the deadline. The second move is to bond covered arrivals that land after it, so that a late or retroactive extension can still be claimed and a snap-back rate is never paid on goods that could have waited or been re-exported.

If your China-origin cargo moves through the Port of Charleston, C&C Warehouse is a CBP-bonded and General Order facility minutes from the terminals that receives containers in-bond, files against Type 21 warehouse entries, and handles the partial withdrawals, re-export from bond and transloading this deadline calls for. Use the form below with the HTS lines and the arrival window, and we will tell you what the bonded option costs against the duty at stake.

FAQ

When do the Section 301 China exclusions expire? At 11:59 p.m. ET on November 9, 2026. Entries and warehouse withdrawals for consumption made on or after November 10, 2026 cannot claim heading 9903.88.69 unless USTR publishes a further extension.

How many exclusions are affected? 178 — 164 product-specific exclusions and 14 for solar-manufacturing equipment — all extended by USTR on December 1, 2025 in FR Doc 2025-21671.

What rate applies after the exclusion expires? The underlying Section 301 list rate returns: 25% for Lists 1, 2 and 3 and 7.5% for List 4A, on top of the MFN rate and any Section 232 or AD/CVD duties.

Does holding goods in a bonded warehouse preserve the exclusion past November 10? No. Duty is assessed at the rate in effect on the date of withdrawal for consumption, so goods withdrawn on or after November 10 lose the exclusion. Covered inventory in bond should be withdrawn before the deadline; bonding is useful for arrivals after the deadline that you want to hold pending a possible extension or re-export.

Has USTR opened a comment period on extending the exclusions again? As of September 16, 2026 we could not find a Federal Register comment request comparable to the September 2025 notice. That is the leading indicator to watch; its absence by mid-October would make the snap-back the base case.

Is there a bonded warehouse near the Port of Charleston that can hold China-origin cargo through the November deadline? Yes. C&C Warehouse is a CBP-bonded and General Order facility minutes from the port that receives in-bond containers, files Type 21 warehouse entries and handles partial withdrawals and re-export from bond.

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