Did past China entries pay Section 301 duty on an excluded product?

Which exclusions are still in force?

Most Section 301 exclusions for products of China expired in 2019 and 2020, as USTR's own notice puts it. What remains is two groups, each with its own Chapter 99 heading in HTSUS Revision 23:

The dates come from the heading text in Revision 23 and from USTR's notice of November 10, 2026 (91 FR 72610), which extended all 178 exclusions "through 11:59 p.m. eastern time on January 9, 2027". The extensions ran without a gap: through May 31, 2025 (89 FR 46948), August 31, 2025 (90 FR 23987), November 29, 2025 (90 FR 42500), November 9, 2026 (90 FR 55232), and now January 9, 2027. The 164 under 9903.88.69 start on June 15, 2024 because the May 2024 notice extended every then-current exclusion through June 14, 2024 as a transition, and only the 164 beyond it.

USTR's November notice also fixes the scope: each exclusion is governed by the ten-digit statistical reporting numbers and the product descriptions in the note. A product that sits in the right statistical number but does not match the description, or the reverse, is not excluded.

Why would an excluded line still have paid?

Five reasons account for most of it.

1. The broker's tariff database charges the list heading by code. The China list headings apply to every product of China in the listed 8-digit subheadings. The exclusion is a narrower 10-digit number plus a description, so it needs a product-level decision the database does not make.
2. The exclusion was never connected to the product. Many of the 164 date from 2018 and 2019 requests by other importers. An exclusion "is available for any product that meets the description", in USTR's words, whoever asked for it, so an importer can qualify without knowing.
3. Exclusions lapsed and came back. Between May 2024 and November 2026 USTR set six successive end dates, in steps from two weeks to just under a year. Filers who stopped claiming at an announced end date and did not restart after the next extension paid in the gaps between notices.
4. Statistical numbers changed on July 1, 2026. Four exclusions, note 20(vvv)(i)(4) to (6) for pump casings, covers and plastic pump parts and (iv)(4) for certain plastic articles, were written against statistical numbers that changed in the July 1, 2026 tariff schedule. USTR conformed them on September 2, 2026 (91 FR 56538), and CBP's systems accepted the new numbers only from noon on September 23, 2026 (CSMS # 69990649). CBP's own example: goods entered July 1 through September 22, 2026 that paid the Section 301 duty should file a post-summary correction on or after September 23, 2026.
5. The wrong layer was removed. An exclusion removes only the China Section 301 heading. A line that claimed 9903.88.69 and also dropped the forced-labor duty under 9903.05.31 for an entry from July 24, 2026 underpaid the second layer.

Worked line

AC permanent split capacitor motors not exceeding 16 W, statistical number 8501.10.4020 (general rate 4.4%), product of China, entered August 31, 2026, entered value $80,000. Subheading 8501.10.40 is on List 1 in U.S. note 20(b), so heading 9903.88.01 adds 25 percent. Note 20(vvv)(i)(25) excludes "Electric motors, AC, permanent split capacitor type, not exceeding 16 W (described in statistical reporting number 8501.10.4020)" under 9903.88.69. The motors match. The product and entry are illustrative; fees are left out.

The overpayment is $20,000. The forced-labor duty stays: subheading 8501.10.40 is not on any of the U.S. note 52 exemption lists, and the exclusion does not reach that duty. The entry reaches 300 days on June 27, 2027, so as long as it has not liquidated before then, a post-summary correction can fix it, filed at least 15 days before the scheduled liquidation date.

At the same volume every month, the motors alone add $240,000 a year in duty that the exclusion took away.

How do you find these lines in your own entries?

1. Pull every line with country of origin China entered from January 1, 2024, with the 10-digit statistical number, the description from the commercial invoice and every Chapter 99 number reported.
2. Keep the lines that carry a China list heading: 9903.88.01, 9903.88.02, 9903.88.03, 9903.88.04 or 9903.88.15.
3. Match the statistical number against note 20(vvv)(i) to (iv) and 20(www). For the four conformed exclusions, use the number in force on the entry date: the old numbers through June 30, 2026, the new ones from July 1, 2026.
4. Match the description. Read each candidate against the exclusion's words: wattage, dimensions, value per unit, material, end use. Keep the specification sheet that proves it.
5. Check the date window: from June 15, 2024 for 9903.88.69, from January 1, 2024 for 9903.88.70, and in both cases through January 9, 2027 as extended so far.
6. Check that the exclusion matches the list the line paid. Subdivision (vvv)(i) excludes from 9903.88.01, (ii) from 9903.88.02, (iii) from 9903.88.03 or 9903.88.04, (iv) from 9903.88.15, and (www) from 9903.88.02.
7. Recompute the line without the list duty, keeping every other layer.

A post-entry audit runs the statistical-number match on every China line and puts the candidates in front of a reviewer with the exclusion text, so the description test is a human decision with the evidence beside it. The duty calculator shows the full stack for one code and date, with the exclusion applied.

What is the route back for each entry?

CBP's guidance on exclusions is direct: importers may file a post-summary correction if within the PSC filing timeframe, and may protest the liquidation if beyond it but within the protest timeframe (CSMS # 69990649).

As of November 11, 2026, any entry made before January 15, 2026 is past 300 days, so for most of the 2024 and 2025 entries in the window the question is whether they liquidated in the last 180 days, that is on or after May 15, 2026. Entries that liquidated before that are final. Entries made from January 15, 2026 onward can still be corrected before liquidation if the 15-day rule allows. Check each entry's liquidation date in ACE before deciding; how to check entry liquidation status shows where.

What else should the review cover?

• The forced-labor layer. For China lines from July 24, 2026, confirm 9903.05.31 at 12.5 percent is present unless an exemption in U.S. note 52 applies; see what the Section 301 forced-labor duty adds to an entry line.
• Claims that do not fit. A line claiming 9903.88.69 whose product does not match the description underpaid the list duty. Correct it before liquidation, or read prior disclosure after you find an underpayment if a 19 U.S.C. 1592 violation may be involved.
• The January 9, 2027 date. Mark the end date for every product that relies on an exclusion, and watch the Federal Register for another extension. Goods entered after the last covered day pay the list heading again unless USTR acts.

The full set of refund routes is on recover overpaid import duty, the deadlines on how long you have to fix a past entry, and where Section 301 sits in a full review on post-entry customs audit of Form 7501. File corrections and protests through a licensed customs broker.