Excess-Capacity Section 301 Tariffs Pushed Past the September 24 Trump–Xi Summit: What China-Origin Importers Should Do This Week

Excess-Capacity Section 301 Tariffs Pushed Past the September 24 Trump–Xi Summit: What China-Origin Importers Should Do This Week

The next tariff on Chinese goods has a number attached to it but no date. On September 17, Bloomberg and Inside U.S. Trade reported that the administration is expected to delay announcing the Section 301 "structural excess capacity" tariffs until after President Trump meets President Xi in Washington on September 24. The plan before the delay was a USTR report published ahead of the summit recommending a 7.5% additional duty on Chinese products. The reason for the delay was not given, USTR and the White House did not comment, and it is not confirmed that 7.5% survives the summit unchanged.

That leaves importers of China-origin goods in the position they were in for most of July: a rate that is widely reported, an effective date that is not, and a stack of existing layers that already makes the arithmetic painful. This article covers what is actually pending, how it lands on top of what China-origin entries already pay, what a post-summit announcement would probably look like on the calendar, and what to do with cargo on the water and in the warehouse this week. It complements the Section 301 explainer, the forced-labor tariff day-one guide and the November 10 exclusions snap-back playbook.

What is pending, and why 7.5% is the number

USTR opened two self-initiated Section 301 investigations in March 2026 to replace the country-specific IEEPA tariffs the Supreme Court struck down in February. The first, on forced-labor import enforcement, covered about 60 economies and concluded in July with additional duties of 10% or 12.5% depending on whether the exporting country maintains its own forced-labor import ban; China sits in the 12.5% tier. Those duties have been collected since July 24.

The second, on structural excess manufacturing capacity, covers 16 jurisdictions: China, the European Union, Japan, South Korea, India, Vietnam, Taiwan, Indonesia, Thailand, Malaysia and others. Public hearings ran in May. That is the case whose determination was expected before the summit and is now expected after it.

The 7.5% figure is not arbitrary. At the Busan meeting in October 2025 — reaffirmed when the two presidents met in Beijing in May 2026 — Washington and Beijing settled on a ceiling of roughly 20% in new second-term U.S. duties on Chinese goods. The forced-labor layer already uses 12.5 points of that room; 7.5% fills the rest exactly. Beijing has said publicly that a 7.5% excess-capacity duty would be consistent with the truce. So the base case is that the delay is about sequencing and leverage, not about the rate. The risk cases are that the summit produces a broader deal that trades the 7.5% away or defers it, or that it goes badly and the number moves up. Nobody outside the room knows which, and you should plan for the base case while pricing the others.

One point that gets lost in the China coverage: the excess-capacity report covers all 16 economies, and the rates for the other 15 have not been reported at all. If you source from Vietnam, Thailand, Malaysia, India, Korea, Japan, Taiwan or the EU, the same announcement can carry a new line for you, and there is no truce cap protecting you.

The China stack today, and after 7.5%

The excess-capacity duty would be additional — a new Chapter 99 line on top of every layer already on the entry. For a typical China-origin product, the current layers are:

Two worked lines make the exposure concrete. Both use a $100,000 entered value and a 3% general rate, no Section 232, no AD/CVD.

The right-hand column is the one to stare at. An importer whose China-origin line has been protected by an exclusion for six years is looking at a duty bill that roughly triples between now and mid-November if both events land as expected — and the second of those events, the exclusion expiry, is already on the calendar.

How the announcement would probably land on the calendar

Section 301 actions in this cycle have followed a pattern, and it is short. The forced-labor determination was finalized around July 20 and took effect for goods entered for consumption on July 24 — four days. The Brazil 25% action gave about a week, with an in-transit exemption that closed on July 29. The USTR notice sets the effective date; CBP follows with a CSMS message and a new Chapter 99 heading; the duty attaches to goods entered for consumption, or withdrawn from warehouse for consumption, on or after that date.

So if the report comes out in the last week of September, an early- to mid-October effective date is the planning assumption, and a two-week lead time is generous by recent standards. In-transit exemptions have been offered in this cycle, but they have been narrow and short — do not build a plan that depends on one.

That has a direct consequence for anything on the water today. A container that sailed from Shanghai this week arrives at a U.S. East Coast port in roughly five to six weeks, which puts it at the pier in late October — inside any plausible effective window. West Coast arrivals from this week's sailings land in the first half of October, which may or may not clear the date. Cargo that is already at a U.S. port, or in a bonded warehouse, is the cargo you can still do something about.

The bonded-warehouse math runs one direction

Readers of this site know the rule: duty is assessed at the rate in effect on the date of withdrawal for consumption, not the date the goods entered the warehouse. A bonded warehouse does not freeze today's rate. For a tariff that is only expected to go up, that means:

• Anything you will sell in the next 60–90 days: enter it for consumption now. Pay today's 40.5% (or 15.5%) rather than October's 48%. This is the opposite of the instinct to hold and wait for clarity; clarity, in this case, is expected to cost 7.5 points.
• Anything in bond today with a near-term sale: withdraw it before the effective date, whenever that turns out to be. A partial withdrawal covering the next quarter's demand is often the right size — see how partial withdrawals work.
• Bond what you are not sure you will sell in the United States. Goods that may re-export — to Canada, Mexico, Latin America — never owe the duty if they leave in bond. That optionality is worth more at 48% than it was at 40.5%.
• Bond slow movers for the cash-flow deferral, not the rate. A China-origin SKU with twelve months of stock on hand does not benefit from paying 40.5% today versus 48% in a year as much as it benefits from paying nothing until each pallet actually sells. Duty deferral on a 40%-plus stack is a financing decision, and the duty deferral calculator will tell you what the carrying-cost break-even looks like for your inventory turn.

The other thing a 48% stack does is push marginal cargo toward abandonment. When a consignee's landed cost no longer clears the sale price, containers get refused, and refused containers become General Order cargo after fifteen days — with storage charges accruing and the goods eventually sold at auction. If you are the consignee, that is the outcome to model against; if you are the carrier or NVOCC, it is the reason to line up a GO warehouse before October.

Where it fits with the other clocks

The excess-capacity duty is one of four dates a China-origin importer is now managing in the same quarter, and they interact:

• September 24 — Trump–Xi summit, Washington. The excess-capacity report and any change to the 7.5% number are expected after this.
• September 29 — Section 232 pharmaceutical tariffs for non-Annex III products; Chinese APIs and finished pharma are squarely in scope.
• Early-to-mid October (expected) — excess-capacity effective date, if the July pattern holds.
• November 10 — the 178 remaining China exclusions expire unless USTR extends them; as of this week there is still no comment docket.

The interaction that matters: an exclusion-claiming importer who withdraws everything before the excess-capacity date to save 7.5 points and then leaves the rest of the year's inventory in bond past November 9 will pay 48% on the balance instead of 23%. If you hold both risks, the withdrawal decision has to be sized against the *later* date, not the earlier one.

This week's checklist

1. Pull every China-origin line entered in the last twelve months and tag it with its current stack: list code or exclusion, forced-labor tier, any Section 232 or AD/CVD line. Your broker's ACE entry summary report does this in one export.
2. Model three scenarios per SKU, not one: today's rate, plus 7.5%, plus 7.5% with the exclusion gone. 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 affiliate disclosure.) For a quick single-line check, the tariff stacking calculator and landed cost calculator are free.
3. Check your continuous bond. A 7.5-point jump on China-origin volume raises your annual duties, taxes and fees, and CBP's 10% rule means a bond that was adequate in June may be insufficient by November. Under-bonded importers get insufficiency letters, and an insufficient bond stops entries. Run the customs bond calculator against the post-October stack.
4. Sort inventory by disposition: sell in 90 days → enter or withdraw now; may re-export → bond; slow mover → bond for deferral. Write the disposition on the PO so the broker does not have to guess at the pier.
5. Do not over-correct into a stockpile. The solar proclamation last month included an explicit anti-stockpiling clause; the excess-capacity action may or may not, but a visible surge in China-origin entries between now and the effective date is exactly the pattern USTR has said it will watch. Pull forward what you would have bought anyway; do not manufacture demand.
6. Watch the non-China rates. If any of your alternate-sourcing countries are among the other 15 economies in the investigation, the same announcement can change the comparison you just ran.
7. Confirm your Form 5106 data is clean before you file a wave of consumption entries. As of today, September 18, CBP is voiding importer numbers with inaccurate 5106 records, and a voided IOR number in the middle of a pre-tariff withdrawal program is the worst possible timing.

Where Charleston fits

A large share of the China-origin volume that used to route through the West Coast now comes through the Suez to the East Coast, and the Port of Charleston is one of the primary gateways for it. That means two things for the next six weeks. First, containers arriving from mid-October onward are the ones most likely to be caught by an effective date, so Charleston consignees are the ones who most need a withdraw-before, bond-after plan in place before the notice publishes. Second, when a 48% stack pushes marginal cargo toward refusal, the carriers' General Order volume at the port goes up.

C&C Warehouse is a CBP-bonded and General Order facility minutes from the Port of Charleston. It receives in-bond containers off the Wando Welch and North Charleston terminals, files Type 21 warehouse entries, handles partial withdrawals so you can pull next month's stock before the rate changes and leave the rest in bond, and takes GO cargo from carriers and NVOCCs. If you have China-origin containers landing at Charleston between now and Thanksgiving, the form below reaches the operations desk directly; tell us the current entry status, the arrival window and whether the goods claim an exclusion, and we will tell you which side of the line each container belongs on. For background on the port, start with the Port of Charleston importer's guide.

FAQ

Have the Section 301 excess-capacity tariffs been announced? No. As of September 18, 2026, the administration is reported to be delaying the announcement until after the September 24 Trump–Xi summit. The rate previously expected for Chinese goods is 7.5%, but neither the rate nor an effective date has been published.

Does the 7.5% replace the 12.5% forced-labor tariff? No. It would be an additional line. Together the two would total 20% in new second-term duties on Chinese goods, which is the ceiling both governments have described as consistent with the October 2025 truce.

Does holding China-origin goods in a bonded warehouse protect them from the new tariff? No. Duty is assessed at the rate in effect on the withdrawal date. Goods you will sell soon should be entered or withdrawn for consumption before the effective date; bonding is for goods that may re-export or that you want to defer duty on for cash-flow reasons.

Will there be an in-transit exemption? Unknown. Some actions in this cycle have had short in-transit windows; the forced-labor action gave four days' notice. Plan as though there is none.

Which countries besides China are covered by the excess-capacity investigation? Sixteen jurisdictions in total, including the European Union, Japan, South Korea, India, Vietnam, Taiwan, Indonesia, Thailand and Malaysia. Their rates have not been reported.

Is there a bonded warehouse near the Port of Charleston that can hold China-origin cargo through the announcement? 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, handles partial withdrawals and accepts General Order cargo.

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