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.

DocumentWho issues itWhat it doesDoes it set the effective date?
Proclamation, executive order, statute, or USTR or Commerce noticeThe President, Congress, USTR, CommerceCreates or changes the duty, usually by modifying the HTS in an annexYes. It states the entry date and time from which the change applies, and any in-transit or end date
Federal Register printingOffice of the Federal RegisterPublishes the instrumentNo. Printing can come before, on or after the effective date
CSMS messageCBPTells filers how to report the change in ACE: which Chapter 99 numbers, which order, which exemptionsNo. It repeats the instrument's dates
HTS revisionUSITCCompiles every change so far into a new edition of the scheduleNo. 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.

ChangeApplies to entries fromSigned or filedCSMS messageFederal Register printingHTS revision with the change became current
Section 122 surcharge, heading 9903.03.01, 10%12:01 a.m. EST, February 24, 2026Proclamation signed February 20, 2026# 67844987, February 23, 202691 FR 9339, February 25, 2026Revision 4, February 25, 2026
Section 301 forced-labor duties, headings 9903.05.20 to 9903.05.8412:01 a.m. ET, July 24, 2026Presidential memorandum July 23, 2026; USTR notice filed July 27# 69326983, July 23, 2026 (evening)91 FR 47318, July 28, 2026Revision 13, July 28, 2026
Section 301 China exclusion extension (178 exclusions)12:01 a.m. EST, November 30, 2025USTR notice filed November 28, 2025Not checked for this page90 FR 55232, December 1, 2025Not 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, 2026Entered July 24, 2026
6109.10.00 at 16.5%$3,300.00$3,300.00
9903.03.01 at 10%$2,000.00not 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.

  1. 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.
  2. 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.
  3. Filter by goods and origin. Match the 10-digit HTS numbers in column 33 and the country of origin against the instrument's lists.
  4. 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.
  5. 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

  1. USITC, HTS release list (revision names and release start and end dates) (hts.usitc.gov, checked )
  2. 19 U.S.C. 3005 Commission review of and proposed modifications to the Harmonized Tariff Schedule (law.cornell.edu, checked )
  3. 19 U.S.C. 3004 Enactment of the Harmonized Tariff Schedule (subsection (c), statutory status of modifications) (law.cornell.edu, checked )
  4. 19 CFR 141.69 Applicable rates of duty (ecfr.gov, checked )
  5. CBP CSMS # 67844987, Imposing Temporary Section 122 Duties (February 23, 2026) (content.govdelivery.com, checked )
  6. CBP CSMS # 69326983, GUIDANCE: Section 301 Forced Labor Import Duties (July 23, 2026) (content.govdelivery.com, checked )
  7. Proclamation, Imposing a Temporary Import Surcharge To Address Fundamental International Payments Problems, 91 FR 9339 (February 25, 2026) (federalregister.gov, checked )
  8. USTR, Notice of Actions in Section 301 Investigations (forced labor import prohibitions), 91 FR 47318 (July 28, 2026) (govinfo.gov, checked )
  9. USTR, Notice of Product Exclusion Extensions (Section 301, China), 90 FR 55232 (December 1, 2025) (federalregister.gov, checked )
  10. USTR, Notice of Product Exclusion Extensions (Section 301, China), 91 FR 72610 (November 10, 2026) (federalregister.gov, checked )
  11. 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 )
  12. 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 )

Questions people ask

No. The revision is the USITC's compilation of changes made by proclamations, executive orders, statutes and agency notices. The rate starts on the date and time the instrument gives. In 2026, Revision 4 became current on February 25, a day after the Section 122 surcharge started on February 24, and Revision 13 became current on July 28, four days after the Section 301 forced-labor duties started on July 24.

CSMS is CBP's Cargo Systems Messaging Service, which tells filers how to report a change in ACE: which Chapter 99 numbers, which order, which exemptions. It does not create the duty; the instrument does. CSMS # 67844987, sent February 23, 2026, gave the filing instructions for the Section 122 surcharge that started the next day.

Yes, when the instrument says so. The Section 301 forced-labor duties applied from July 24, 2026, four days before the USTR notice was printed at 91 FR 47318 on July 28. USTR's notice extending 178 Section 301 exclusions was printed at 90 FR 55232 on December 1, 2025 and covered goods entered from 12:01 a.m. on November 30, 2025, a day earlier, though it had been filed for public inspection on November 28. An entry filed in such a window on the old stack is corrected afterwards, by post-summary correction before liquidation or protest after it, or, for an underpayment, by prior disclosure where appropriate.

Watch three feeds: CSMS messages from CBP, the Federal Register for proclamations and USTR, Commerce and CBP notices, and the USITC release list for HTS revisions. Then test each change against your own entry lines by date, origin and HTS number. Most changes touch none of your lines; the few that do are worth reading in full.

The time of entry under 19 CFR 141.68, applied by 19 CFR 141.69, which says the rates are those in effect at the time of entry. Warehouse withdrawals take the withdrawal date and immediate transportation entries the date the transportation entry was accepted. Block 7 of Form 7501 is the entry date, and an in-transit clause in the instrument can add a loading-date test.

They are still subject to the law in force on their entry date. If a line was filed without a new duty, the shortfall is an underpayment to correct by post-summary correction before liquidation, or by prior disclosure where appropriate. If a line paid a duty that had ended or never applied, it is an overpayment to recover by post-summary correction or by protest within 180 days of liquidation.

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