- Country: United States
- Explainer
- Topic: Effective dates
- Topic: Duty stack
- Topic: Post-entry audit
- Topic: Deadlines
How do tariff schedule changes reach your entries, and how do you tell which entries a change touched?
Published
Short answer
A change to US duty reaches every entry whose entry date falls inside the window the legal instrument sets, whatever day the USITC publishes the HTS revision or CBP sends its CSMS message. The Section 301 forced-labor duties applied to goods entered from 12:01 a.m. eastern time on July 24, 2026; CBP's filing message (CSMS # 69326983) went out the evening before, but the USTR notice was printed at 91 FR 47318 on July 28, 2026 and HTS Revision 13, the first revision with the new headings, became current the same day, so Revision 12 was still the current schedule for July 24 to 27. To find the entries a change touched, filter your entry lines by entry date window, origin and the HTS numbers or headings the instrument lists, then sort them by liquidation status.
TariffSense checks every line of your filed entries against the measures in force on the entry date.
Which document actually changes the duty on an entry?
Four documents carry a US tariff change, and only one of them is the law. The other three report it, explain it or program it, and each can arrive on a different day.
| Document | Who issues it | What it does | Does it set the effective date? |
|---|---|---|---|
| Proclamation, executive order, statute, or USTR or Commerce notice | The President, Congress, USTR, Commerce | Creates or changes the duty, usually by modifying the HTS in an annex | Yes. It states the entry date and time from which the change applies, and any in-transit or end date |
| Federal Register printing | Office of the Federal Register | Publishes the instrument | No. Printing can come before, on or after the effective date |
| CSMS message | CBP | Tells filers how to report the change in ACE: which Chapter 99 numbers, which order, which exemptions | No. It repeats the instrument's dates |
| HTS revision | USITC | Compiles every change so far into a new edition of the schedule | No. It records changes already made |
19 U.S.C. 3004(c)(1) treats the HTS as enacted, each statutory amendment and each presidential modification made under legal authority as "statutory provisions of law for all purposes". The USITC's role is described in 19 U.S.C. 3005(a): it "shall keep the Harmonized Tariff Schedule under continuous review" and recommend modifications to the President. In practice the USITC also publishes each revision, and its release list shows how often that happens: the 2026 Basic edition took effect December 31, 2025, and Revision 23 became current on November 10, 2026, which is 24 editions in just over ten months.
Why does the HTS revision lag behind the change?
Because the revision is compiled after the instrument is signed. Three recent changes show the gap, each dated from the instrument, the CSMS message and the USITC release list.
| Change | Applies to entries from | Signed or filed | CSMS message | Federal Register printing | HTS revision with the change became current |
|---|---|---|---|---|---|
| Section 122 surcharge, heading 9903.03.01, 10% | 12:01 a.m. EST, February 24, 2026 | Proclamation signed February 20, 2026 | # 67844987, February 23, 2026 | 91 FR 9339, February 25, 2026 | Revision 4, February 25, 2026 |
| Section 301 forced-labor duties, headings 9903.05.20 to 9903.05.84 | 12:01 a.m. ET, July 24, 2026 | Presidential memorandum July 23, 2026; USTR notice filed July 27 | # 69326983, July 23, 2026 (evening) | 91 FR 47318, July 28, 2026 | Revision 13, July 28, 2026 |
| Section 301 China exclusion extension (178 exclusions) | 12:01 a.m. EST, November 30, 2025 | USTR notice filed November 28, 2025 | Not checked for this page | 90 FR 55232, December 1, 2025 | Not checked for this page |
For July 24 to 27, 2026, the current edition of the schedule was Revision 12, which still carried heading 9903.03.01 and had no heading 9903.05.84. The law that applied to entries on those days rested on a presidential memorandum of July 23 and a USTR notice not printed until July 28; the only official filing text on those days was CBP's CSMS message, sent at 5:50 p.m. EDT on July 23, about six hours before the duties started. Anyone pricing entries from the published schedule on those days had the wrong stack, through no fault of the schedule.
The direction can also run the other way. An instrument can be printed weeks before it takes effect, and the next revision then carries the new heading with a future date in its text. Reading the date in the heading or note, not the revision date, is what keeps a lookup right.
How does one boundary change a real line?
Take a cotton knit T-shirt of Vietnam, subheading 6109.10.00 (General rate 16.5%), entered value $20,000, entered on two consecutive days.
Entered July 23, 2026. Heading 9903.03.01 applied to products of any country entered from 12:01 a.m. EST on February 24, 2026 through 12:01 a.m. EDT on July 24, 2026 (CSMS # 67844987), at "+ 10%" in Revision 12. Subheading 6109.10.00 is not on the U.S. note 2(aa) exemption lists, and the CAFTA-DR textile heading 9903.03.09 does not cover Vietnam.
Entered July 24, 2026. Revision 23 records that headings 9903.03.01 to 9903.03.11 "expired at the close of July 23, 2026". Heading 9903.05.84 covers products of Vietnam entered from 12:01 a.m. ET on July 24, 2026 at "+ 12.5%" (91 FR 47318), unless an exception heading such as the in-transit heading 9903.05.85 applies.
| Entered July 23, 2026 | Entered July 24, 2026 | |
|---|---|---|
| 6109.10.00 at 16.5% | $3,300.00 | $3,300.00 |
| 9903.03.01 at 10% | $2,000.00 | not applicable |
| 9903.05.84 at 12.5% | not applicable | $2,500.00 |
| Total duty | $5,300.00 | $5,800.00 |
A shipment that arrived at midnight could fall either side, which is why the time of entry matters as much as the day. 19 CFR 141.68 sets that time by entry type, and the in-transit page covers the loading-date clauses that sometimes soften a boundary. The general method for a single line is in how to find the duty on an HTS code, and the duty calculator prices a code for any entry date.
How do you tell which of your entries a change reached?
Every change has three filters in it: a date window, a set of goods and a set of origins. Your entry lines carry all three, so the test is mechanical.
- Read the instrument, not the summary. Note the start date and time, any end date, any in-transit clause, the Chapter 99 headings it creates or changes, the product list (by HTS number or description) and the countries.
- Filter by entry date. Use the time of entry (block 7 of Form 7501), or the withdrawal date for warehouse withdrawals. Lines inside the window are candidates.
- Filter by goods and origin. Match the 10-digit HTS numbers in column 33 and the country of origin against the instrument's lists.
- Compare what was reported with what should have been. Each candidate line should carry the new heading, or an exception heading that explains why not. Lines outside the window should not.
- Sort the differences by status. Unliquidated entries can be corrected by post-summary correction; liquidated ones by protest within 180 days of liquidation; underpayments that are material belong in a conversation about prior disclosure. How long you have to fix a past entry has the clocks side by side.
The lines most likely to be wrong are the ones filed in the first days after a change, before the revision and ACE programming caught up, like July 24 to 27, 2026, and the ones filed on the day a benefit started before its notice was printed, like November 30, 2025.
How do you track changes without reading every notice?
Subscribe to the three feeds and test each item against your own data.
- CSMS for filing instructions. Each message names the headings and dates.
- Federal Register for the instruments themselves: proclamations, executive orders, and USTR, Commerce and CBP notices. Its public inspection desk often shows a document a day or more before printing.
- USITC release list for each new revision, with its start date. A new revision is a prompt to look for headings that changed, not a sign that something took effect that day.
Then run each change through the filters above. Most changes touch none of your lines. The ones that do are found at line level, and the post-entry audit guide explains how to work through them. TariffSense keeps the measures by effective date and re-checks each entry line against the measures in force on its own entry date, so a change printed late or applied retroactively shows up as a per-line finding on the entries it reached. The audit page explains how to run that on your entry history, and the duty tools show the stack for a single code on either side of a change date. Confirm any correction or protest with a licensed customs broker.
Sources
- USITC, HTS release list (revision names and release start and end dates) (hts.usitc.gov, checked )
- 19 U.S.C. 3005 Commission review of and proposed modifications to the Harmonized Tariff Schedule (law.cornell.edu, checked )
- 19 U.S.C. 3004 Enactment of the Harmonized Tariff Schedule (subsection (c), statutory status of modifications) (law.cornell.edu, checked )
- 19 CFR 141.69 Applicable rates of duty (ecfr.gov, checked )
- CBP CSMS # 67844987, Imposing Temporary Section 122 Duties (February 23, 2026) (content.govdelivery.com, checked )
- CBP CSMS # 69326983, GUIDANCE: Section 301 Forced Labor Import Duties (July 23, 2026) (content.govdelivery.com, checked )
- Proclamation, Imposing a Temporary Import Surcharge To Address Fundamental International Payments Problems, 91 FR 9339 (February 25, 2026) (federalregister.gov, checked )
- USTR, Notice of Actions in Section 301 Investigations (forced labor import prohibitions), 91 FR 47318 (July 28, 2026) (govinfo.gov, checked )
- USTR, Notice of Product Exclusion Extensions (Section 301, China), 90 FR 55232 (December 1, 2025) (federalregister.gov, checked )
- USTR, Notice of Product Exclusion Extensions (Section 301, China), 91 FR 72610 (November 10, 2026) (federalregister.gov, checked )
- USITC, Harmonized Tariff Schedule of the United States, Revision 12 (2026), Chapter 99 (heading 9903.03.01, U.S. note 2(aa)) (hts.usitc.gov, checked )
- USITC, Harmonized Tariff Schedule of the United States, Revision 23 (2026), Chapter 99 (headings 9903.05.84 and 9903.03.01) (hts.usitc.gov, checked )
