CBP Updates Section 301 China Exclusion Filing Guidance
To Our Valued Partners,
U.S. Customs and Border Protection has issued new filing guidance for four existing Section 301 China product exclusions following changes to certain 10-digit HTS statistical reporting numbers.
The exclusions themselves are not new. USTR made the changes so the same qualifying products can continue to receive the existing exclusions after the HTS statistical reporting numbers changed effective July 1, 2026.
These exclusions remain in effect through November 9, 2026.
What Changed
The update affects four existing product exclusions under HTSUS 9903.88.69.
For three of the exclusions, qualifying goods that were previously classified under:
• 8413.91.9065
• 8413.91.9085
• 8413.91.9096
are now described under the following statistical reporting numbers effective July 1, 2026:
• 8413.91.9039
• 8413.91.9046
• 8413.91.9059
• 8413.91.9099
These exclusions fall within HTS heading 8413.91, which covers certain parts of pumps. The exact product description in the applicable exclusion still determines whether a product qualifies.
The fourth exclusion previously referenced 3926.90.9910. Effective July 1, 2026, qualifying goods under that exclusion are now described under:
• 3926.90.9915
• 3926.90.9920
The change does not expand the exclusions to every product classified under these HTS numbers. The product must still meet the specific requirements of the applicable Section 301 exclusion.
Why This Matters
Although the HTS changes became effective July 1, 2026, USTR issued the conforming amendment on September 2 and CBP issued the filing instructions on September 22. CBP is now providing a process for qualifying importers to correct affected entries and request refunds of Section 301 duties paid during that period.
CBP’s ACE system began accepting these conforming amendments at 12:00 p.m. Eastern Time on September 23, 2026.
CBP also instructs importers and filers not to submit the corresponding Chapter 99 number for the Section 301 China duty when HTSUS 9903.88.69 is submitted.
There may also be an opportunity to recover Section 301 duties that were already paid.
CBP specifically explains that if qualifying Chinese goods were entered from July 1 through September 22, 2026, were covered by one of these exclusions, and Section 301 duties were paid, the importer may file a Post Summary Correction on or after September 23, 2026 to request a refund, as long as the entry is still within the PSC filing timeframe.
If the PSC timeframe has passed, a protest may still be available if the entry remains within the protest filing timeframe.
What You Should Do
If your company imports goods from China that may fall within one of these four exclusions, now is a good time to review your entries from July 1 through September 22, 2026.
We recommend confirming:
• Whether your product qualifies for one of the four affected exclusions
• Whether the correct updated HTS statistical reporting number applies
• Whether Section 301 duties were paid on a qualifying entry
• Whether a Post Summary Correction or protest may be available to recover those duties
RESOURCES
CBP CSMS #69990649
USTR Federal Register Notice, September 2, 2026
USTR Section 301 China Exclusion Information
USTR Federal Register Notice, December 1, 2025
As always, our team is here to help you stay ahead of customs changes and keep your shipments moving.
If you are not currently using Southern Star Navigation for customs brokerage, we are still happy to talk through your international freight and customs needs and help determine how our team may be able to support you.
Contact our team at 833-782-7628 with questions or to review what may need attention.
