What does the Section 301 forced-labor duty add to an entry line?

Which rate does a line pay?

Three facts decide the forced-labor layer on an entry line: the country of origin, the entry date and whether the article falls under one of the exemptions in U.S. note 52 to subchapter III of chapter 99. The duty applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on July 24, 2026 (91 FR 47318, DATES). Goods loaded onto the vessel and in transit before that moment were exempt if entered before 12:01 a.m. on July 28, 2026, under heading 9903.05.85.

The 60 economies fall into three groups. The table shows the heading and rate as printed in HTSUS Revision 23 (checked November 11, 2026); the economies named are examples, not the full list.

The floor headings come in pairs, and only one of each pair fits a given line. For a specific or compound general rate, note 52(k) converts it to an ad valorem equivalent by dividing the duty by the customs value; its own example is 50 cents a kilogram on a $10 kilogram, or 5 percent.

The rate is set by the economy, not by the product. USTR's notice gives 10 percent to economies that impose a forced-labor import prohibition, have committed to one in an Agreement on Reciprocal Trade or run a partial regime, and 12.5 percent to every other economy. Nothing about the product's own supply chain changes the rate, which is what separates this duty from a UFLPA detention.

How does it sit with the rest of the stack?

U.S. note 52(a) answers most stacking questions in three sentences:

1. The forced-labor duty is charged in addition to the general rate in chapters 1 to 97.
2. It is charged in addition to any other additional duty in subchapters III and IV of chapter 99, unless note 52 says otherwise. That includes the China Section 301 lists in U.S. note 20.
3. Goods that qualify for a free trade agreement rate under general note 3(c)(i) still pay it, except where note 52 exempts them. The agreement exemptions are narrow: USMCA goods of Canada and Mexico entered free (9903.05.93 and 9903.05.94) and CAFTA-DR textile and apparel goods entered free (9903.05.95).

Chapter 98 entries are exempt, except 9802.00.40, 9802.00.50 and 9802.00.60, where the duty falls on the value of the repair or processing, and 9802.00.80, where it falls on the assembled value less the U.S. components. Antidumping and countervailing duties continue on top.

What note 52 switches off is just as important. Under subdivision (f) and heading 9903.05.90, the duty does not apply to articles under the Section 232 headings for aluminum, steel and copper (9903.82.02 and 9903.82.04 to 9903.82.26), passenger vehicles and light trucks and their parts, medium- and heavy-duty vehicles and parts, the listed wood products, semiconductor articles of 9903.79.01 and, for goods entered from July 31, 2026, patented pharmaceutical articles of 9903.04.60 to 9903.04.66 (91 FR 47318, Annex I, Part B).

CBP's filing instructions put the Section 301 Chapter 99 number first among the trade-remedy numbers on the line, before Section 232, with the entered value reported on the chapter 1 to 97 number (CSMS # 69326983). The order controls the keying, not the arithmetic: each additional rate is a percentage of the entered value, never a duty on a duty.

Four worked lines

All four lines are entered on September 15, 2026, each for $60,000 except the last. The products and countries are illustrative. The headings and rates are read from HTSUS Revision 23; each code was checked against note 52 in Revision 13, the first printing, and Revision 23. The merchandise processing fee is left out to keep the arithmetic short.

Line 1: an add-on economy

LED luminaires, HTS 9405.42.84 (general rate 3.9%), product of Vietnam.

Line 2: a floor economy

The same luminaires, product of Germany. The general rate of 3.9 percent is below the EU floor of 10 percent, so heading 9903.05.39 applies and the combined rate is 10 percent.

If the German product carried a general rate of 10 percent or more, say a backpack of man-made fibres under 4202.92.31 at 17.6 percent, the line would report 9903.05.38 and pay nothing extra. A broker who adds 10 percent on top of 3.9 percent here overcharges $2,340; one who reports 9903.05.39 on the backpack invents a duty that does not exist.

Line 3: China, with List 3

The same luminaires, product of China. Subheading 9405.42.84 is on the List 3 schedule in U.S. note 20(f), so heading 9903.88.03 adds 25 percent, and the forced-labor duty stacks on it.

Line 4: a Section 232 article

Stainless steel cookware, HTS 7323.93.00 (general rate 2%), product of Vietnam, entered value $40,000. Subheading 7323.93.00 is in U.S. note 16(c)(vii), so heading 9903.82.09 charges 25 percent on the full customs value, and heading 9903.05.90 takes the line out of the forced-labor duty.

The common error on this line is reporting 9903.05.84 instead of 9903.05.90. That adds $5,000 the importer did not owe. How the Section 232 base and tier are worked out is on Section 232 on full value since April 6, 2026.

Where do forced-labor lines go wrong?

Most errors since July 24, 2026 fall into one of these patterns. Each is visible from the entry summary and the product master, without asking the broker.

The exemption lists are long: subdivision (b) alone lists more than 800 tariff numbers, from coffee and spices to computers, smartphones and semiconductors. How to test past lines against them and claim the duty back is on the forced-labor exemptions page.

What about drawback and foreign trade zones?

The duties under headings 9903.05.20 to 9903.05.84 are drawback eligible. CBP deployed an ACE validation on August 12, 2026 that disallowed drawback on them, and corrected it in production by August 18, 2026 (CSMS # 69567203). The message does not say how claims rejected in between are handled; any claim rejected on that ground in that week is worth resubmitting through the filer. On duty drawback on past entries the program-by-program table shows which other Chapter 99 duties come back.

Goods subject to the duty and admitted into a foreign trade zone may only be admitted in privileged foreign status, unless eligible for domestic status (CSMS # 69326983). The rate is then fixed at admission, which matters for goods admitted before July 24, 2026 and withdrawn later.

How do you check your own lines?

1. Pull every line entered from July 24, 2026 with the country of origin, the chapter 1 to 97 number, every Chapter 99 number and the entered value.
2. Read the country heading for each origin and confirm the rate: 10 or 12.5 percent, or the floor pair.
3. For floor economies, compare the general rate with the floor. Below it, the combined rate is the floor; at or above it, the "no change" heading applies.
4. Test each code against the note 52 exemptions: the lists in (b) and (c), the conditions in (d) civil aircraft and (e) pharmaceutical use, the Section 232 headings in (f), the agreement exemptions in (g) to (i), and the economy lists in (j).
5. Recompute the duty as rate times entered value and compare with the amount on the 7501.
6. Sort the differences into overpayments to recover and underpayments to correct, by entry status.

The duty calculator returns the forced-labor layer next to the rest of the stack for a code, a country and an entry date. A post-entry audit runs the same checks on every line of a 7501 export and flags each pattern in the table above, in both directions. For where this fits in a full review, see post-entry customs audit of Form 7501, and for how the forced-labor layer sits with Section 232 and the IEEPA period on older entries, why your entry shows the wrong duty stack.