- Country: United States
- Explainer
- Topic: Duty stack
- Topic: IEEPA
- Topic: Section 301
- Topic: Section 232
- Topic: Section 122
- Topic: Section 338
Which US duties applied to my line on its 2026 entry date?
Published · Updated
This page describes the rules in force on . When they change, we publish a new page and link it from here.
Short answer
In 2026 the additional duties on a US entry line changed on five entry dates: IEEPA duties stopped for goods entered from 12:00 a.m. ET February 24, the 10 percent Section 122 surcharge ran from 12:01 a.m. February 24 through 12:01 a.m. July 24, Section 232 metal duty moved to the full customs value from April 6, the Section 301 forced-labor duty of 10 or 12.5 percent started on July 24, and a 50 percent Section 338 duty on listed Canadian goods started on August 22. The same $10,000 Chinese plastics line owed $3,280 before February 24, $2,280 in the Section 122 window and $2,530 from July 24; a listed Canadian line not claimed under USMCA went from $3,500 to $1,000 to $6,000. Price each line with the rules of its own entry date, not today's.
TariffSense checks every line of your filed entries against the measures in force on the entry date.
Which entry dates changed the US duty stack in 2026?
Every 2026 tariff instrument applies to goods "entered for consumption, or withdrawn from warehouse for consumption, on or after" a stated time. The entry date on the 7501 (block 7) therefore decides which programs apply to a line, not the ship date, the invoice date or the day the duty was paid. Five dates moved the stack this year, and two more changed which Canadian goods carry the newest duty.
| Entry date (eastern time) | What changed | Instrument |
|---|---|---|
| Through February 23, 2026 | IEEPA duties in force: reciprocal duty (10 percent on China under 9903.01.25), China fentanyl duty at 10 percent under 9903.01.24 since November 10, 2025, Canada at 35 percent under 9903.01.10 since August 1, 2025 for goods not entered free under USMCA | Executive Orders 14357, 14358 and 14325 |
| February 24, 2026, 12:00 a.m. | IEEPA duties no longer collected | CBP CSMS # 67834313 |
| February 24, 2026, 12:01 a.m. | Section 122 surcharge of 10 percent under 9903.03.01 on products of any country, with exemptions in 9903.03.02 to 9903.03.11 | Proclamation 11012, CSMS # 67844987 |
| April 6, 2026, 12:01 a.m. | Section 232 aluminum, steel and copper duty applies to the full customs value regardless of metal content; new headings 9903.82.02 onward | Proclamation 11021 |
| July 24, 2026, 12:01 a.m. | Section 122 surcharge ends; Section 301 forced-labor duty of 10 or 12.5 percent starts on products of 60 economies (9903.05.20 to 9903.05.84) | Proclamation 11012 clause (7); USTR notice, 91 FR 47318 |
| August 22, 2026, 12:01 a.m. | Section 338 duty of 50 percent on listed products of Canada (9903.03.12 to 9903.03.14) | Proclamations 11046 to 11048, start date set by Proclamation 11056 |
| September 15 and October 30, 2026 | Section 338 product lists changed; from September 15 the Section 232 relief heading 9903.03.15 covers only the dairy heading | Proclamations 11064, 11065 and 11076; CSMS # 69851916 |
The rates and heading text on this page were checked against Revision 23 of the 2026 Harmonized Tariff Schedule, the release current on November 11, 2026, and the instruments in the sources list. This page describes the rules in force on that day; later instruments can change the newest windows.
Why does the same product owe different duty in different windows?
Because the programs are separate legal actions with their own start and end times, and each one carries its own list of exemptions. Three of the 2026 programs replaced each other almost to the minute.
- IEEPA to Section 122. CBP stopped collecting IEEPA duties for goods entered on or after 12:00 a.m. ET February 24, 2026 (CSMS # 67834313), after the Supreme Court held on February 20, 2026 that IEEPA does not authorize tariffs. Proclamation 11012 started the 10 percent surcharge one minute later. Goods loaded on the final mode of transit before 12:01 a.m. February 24 and entered before 12:01 a.m. February 28 went under 9903.03.02 with no surcharge.
- Section 122 to Section 301. The surcharge ran "through 12:01 a.m. eastern daylight time on July 24, 2026" (Proclamation 11012, clause (7)), and the forced-labor duty applies to goods entered from 12:01 a.m. ET July 24, 2026. Goods loaded before July 24 and entered before 12:01 a.m. July 28 went under 9903.05.85 with no forced-labor duty.
- Section 338 on top. The Canadian duty is not a replacement. U.S. note 51(a) says goods under 9903.03.12 to 9903.03.14 remain subject to any other additional duty in the subchapter, so it sits on the same line as the forced-labor duty.
Two exemption patterns run through all of it. Section 232 articles were kept out of the surcharge ("shall not apply to the part of the import to which section 232 tariffs do apply," Proclamation 11012, paragraph 4) and out of the forced-labor duty (note 52(f), heading 9903.05.90). Canadian and Mexican goods entered free of duty under USMCA were kept out of the IEEPA duties, the surcharge (9903.03.07, 9903.03.08) and the forced-labor duty (9903.05.93, 9903.05.94), but not out of Section 338.
Worked line 1: a Chinese plastics article in three windows
The goods: an article of plastics, HTS 3926.90.99, product of China, general rate 5.3 percent, entered value $10,000. The subheading carries Section 301 duty under 9903.88.15 at 7.5 percent. It is not a Section 232 article, it is not on the note 52(b) exempt list, and it was not on the Annex II list of goods excepted from the surcharge.
| Entry date | Headings on the line | Duty |
|---|---|---|
| January 15, 2026 | 9903.88.15 (+7.5%) $750, 9903.01.24 (+10%) $1,000, 9903.01.25 (+10%) $1,000, 3926.90.99 (5.3%) $530 | $3,280 |
| May 15, 2026 | 9903.88.15 (+7.5%) $750, 9903.03.01 (+10%) $1,000, 3926.90.99 (5.3%) $530 | $2,280 |
| August 15, 2026 | 9903.88.15 (+7.5%) $750, 9903.05.31 (+12.5%) $1,250, 3926.90.99 (5.3%) $530 | $2,530 |
The arithmetic for August: $10,000 × 5.3% = $530; $10,000 × 7.5% = $750; $10,000 × 12.5% = $1,250; total $2,530, an effective 25.3 percent. Nothing compounds. Each rate is applied to the same entered value.
What goes wrong on real entries:
- A January entry that still shows 9903.01.24 at 20 percent. Executive Order 14357 cut the fentanyl duty to 10 percent for goods entered on or after 12:01 a.m. EST November 10, 2025. A line keyed at the old rate overpaid $1,000. All IEEPA duty is refundable after the Supreme Court decision, so this overpayment is part of the IEEPA claim; see IEEPA refunds: which entries qualify.
- A late-February entry that kept the IEEPA numbers. Any entry dated February 24 or later with 9903.01 or 9903.02 numbers on it was keyed with dead headings. The line should show 9903.03.01 instead.
- A late-July entry with both 9903.03.01 and 9903.05.31. The windows do not overlap, so one of them is wrong. An entry dated July 24 or later carries the forced-labor number only, unless the goods qualify for the in-transit heading.
- An August entry with no 9903.05.31. A system that never loaded the July headings underpays $1,250 a line. That is an underpayment to correct, not a refund to claim.
Worked line 2: a Canadian line, with and without a USMCA claim
The goods: lip make-up preparations, HTS 3304.10.00, product of Canada, general rate free, entered value $10,000. Subheading 3304.10.00 is listed in U.S. note 51(b)(3), so heading 9903.03.14 applies to it from August 22, 2026. The right stack depends on whether the line was entered free of duty under USMCA, which needs the goods to originate and the claim to be made.
| Entry date | Not entered under USMCA | Duty | Entered free under USMCA | Duty |
|---|---|---|---|---|
| January 15, 2026 | 9903.01.10 (+35%) | $3,500 | 9903.01.14 (no IEEPA duty) | $0 |
| May 15, 2026 | 9903.03.01 (+10%) | $1,000 | 9903.03.07 (no surcharge) | $0 |
| August 10, 2026 | 9903.05.29 (+10%) | $1,000 | 9903.05.93 (no forced-labor duty) | $0 |
| September 15, 2026 | 9903.05.29 (+10%) and 9903.03.14 (+50%) | $6,000 | 9903.05.93 and 9903.03.14 (+50%) | $5,000 |
The September row for a non-USMCA line: $10,000 × 10% = $1,000 forced-labor duty, plus $10,000 × 50% = $5,000 Section 338 duty, plus the free general rate, $6,000 in all. The USMCA claim saves the $1,000 but not the $5,000, because note 51(a) keeps goods eligible for special tariff treatment under general note 3(c)(i) subject to the Section 338 headings.
Two findings show up on Canadian entries from these windows. First, lines where a USMCA claim was available but not made: on a May entry the surcharge was paid for nothing, and on an August or later entry the forced-labor duty was. Second, lines with a USMCA claim and no Section 338 number from August 22 onward, an underpayment of half the entered value on every listed product. The full Canadian picture, list changes included, is in the Section 338 tariff on Canadian goods.
Where does Section 232 full value fit?
Section 232 changed the value, not the program, on April 6, 2026. Proclamation 11021 made the aluminum, steel and copper duty apply "to the full customs value of the imported product, regardless of metal content" for goods entered from 12:01 a.m. EDT April 6, 2026, mostly at 50 percent under 9903.82.02 or 25 percent under 9903.82.09. Before that date most derivative articles (those in chapters 73 and 76 and those added in 2025) paid Section 232 duty on their metal content only, on a split line.
For a Section 232 line the other 2026 programs mostly fall away. The surcharge did not apply to the part of an import subject to Section 232, and note 52(f) keeps the 9903.82 metal headings, the auto and auto-parts headings, wood products, trucks and buses, semiconductors and patented pharmaceuticals out of the forced-labor duty. So the money on a metal line from April 6 is the base rate plus Section 232 on the full value, and an audit question is whether the base and the exclusion heading are both right. A steel derivative priced on both sides of April 6 is worked in why your entry shows the wrong duty stack.
How do I price my own lines by entry date?
- Export the lines. Entry number, entry date, country of origin, special program indicator, the chapter 1 to 97 number, every Chapter 99 number, entered value and duty per line. A broker entry export or the 7501s themselves carry all of it.
- Sort every line into a window from the table at the top. Use the entry date, or the withdrawal date for goods withdrawn from a bonded warehouse.
- List the programs that window allows for the line's origin and HTS number, and the exemption headings that switch them off: 9903.03.02 to 9903.03.11 for the surcharge, 9903.05.85 to 9903.06.21 for the forced-labor duty, 9903.03.15 and 9903.03.16 for Section 338.
- Recompute the duty as rate × entered value for each program, added side by side. Use the duty calculator with the entry date to check a line.
- Compare with what was paid, line by line. Keep overpayments and underpayments on the same list, with the program each one belongs to.
- Route by program. IEEPA overpayments go to CBP's IEEPA refund process. Section 122 amounts follow which Section 122 entries paid the surcharge. Other differences go to a post-summary correction, a protest or a prior disclosure, depending on the entry's liquidation status. Your broker or trade counsel files them.
Doing this by hand works for a sample. A post-entry audit tool such as TariffSense reads 7501s and broker exports, rebuilds every line's stack with the measures in force on its own entry date, and flags each line where the paid stack differs, in both directions, with the program and the amount. For one code, origin and date at a time, the duty tools show every charge on the line for any entry date. Reading the Chapter 99 numbers themselves is covered in the 9903 lines on your entry summary.
What should I do next?
Pick the entries that sit near a boundary: the week of February 24, the week of July 24, and anything Canadian from August 22. Those are where a stale table produces the wrong numbers most often, and where one wrong rule repeats across every entry in the window. The post-entry audit guide covers the rest of each line. Confirm any correction or claim with a licensed customs broker or trade counsel before it is filed.
Sources
- USITC, Harmonized Tariff Schedule of the United States, Revision 23 (2026), Chapter 99 (U.S. notes 2(aa), 51 and 52) (hts.usitc.gov, checked )
- CBP CSMS # 67834313, Ending Collection of International Emergency Economic Powers Act Duties (February 22, 2026) (content.govdelivery.com, checked )
- Learning Resources, Inc. v. Trump, No. 24-1287 (U.S. Feb. 20, 2026) (supremecourt.gov, checked )
- Proclamation 11012, Imposing a Temporary Import Surcharge To Address Fundamental International Payments Problems, 91 FR 9339 (govinfo.gov, checked )
- CBP CSMS # 67844987, Imposing Temporary Section 122 Duties (February 23, 2026) (content.govdelivery.com, checked )
- Executive Order 14325, Amendment to Duties To Address the Flow of Illicit Drugs Across Our Northern Border, 90 FR 37957 (govinfo.gov, checked )
- Executive Order 14357, Modifying Duties Addressing the Synthetic Opioid Supply Chain in the People's Republic of China, 90 FR 50725 (govinfo.gov, checked )
- Executive Order 14358, Modifying Reciprocal Tariff Rates Consistent With the Economic and Trade Arrangement With the People's Republic of China, 90 FR 50729 (govinfo.gov, checked )
- Proclamation 11021, Strengthening Actions Taken To Adjust Imports of Aluminum, Steel, and Copper, 91 FR 18201 (govinfo.gov, checked )
- USTR, Notice of Actions in Section 301 Investigations (forced labor import prohibitions), 91 FR 47318 (govinfo.gov, checked )
- CBP CSMS # 69326983, Section 301 forced labor duties guidance (July 23, 2026) (content.govdelivery.com, checked )
- Proclamation 11056, Temporary Suspension of Additional Duties To Offset Canadian Discrimination (Section 338), 91 FR 54789 (govinfo.gov, checked )
- CBP CSMS # 69606660, Section 338 additional duties on certain goods of Canada (August 21, 2026) (content.govdelivery.com, checked )
- Updated : Re-checked every source; rates, caps and deadlines updated.
