CBP Issues Guidance on Section 301 China Conforming Amendment
Published Sept. 22, 2025
Key Points
- On September 22, 2026, CBP issued entry-filing guidance for four Section 301 China product exclusions.
- The guidance concerns changes to 10-digit statistical reporting categories in the HTSUS effective July 1, 2026.
- The changes apply to U.S. notes 20(vvv)(i)(4), 20(vvv)(i)(5), 20(vvv)(i)(6), and 20(vvv)(iv)(4) under HTSUS 9903.88.69.
- ACE functionality for acceptance of the conforming amendment will be effective at noon on September 23, 2026.
- Importers may file a Post Summary Correction (PSC) to request a refund of certain Section 301 duties paid on previous imports, if within the applicable PSC filing timeframe.
The
U.S. Customs and Border Protection (CBP) issued CSMS #69990649 on September 22, 2026, providing entry-filing guidance for imports subject to four Section 301 China product exclusions. The guidance concerns changes to 10-digit statistical reporting categories in the Harmonized Tariff Schedule of the United States (HTSUS) effective July 1, 2026, and provides instructions for submitting entries under the amended exclusions. CBP also provides information on the Automated Commercial Environment (ACE) functionality and procedures for requesting refunds of certain Section 301 duties already paid. The Office of the U.S. Trade Representative (USTR) published the Federal Register notice on September 2, 2026.
Section 301 China Entry Guidance
CBP provided instructions for importers, brokers, and filers submitting entries for imports subject to four exclusions from the Section 301 China measures, effective July 1, 2026.
- U.S. note 20(vvv)(i)(4) under HTSUS 9903.88.69 was modified to describe statistical reporting numbers 8413.91.9039, 8413.91.9046, 8413.91.9059, and 8413.91.9099 effective July 1, 2026.
- U.S. note 20(vvv)(i)(5) under HTSUS 9903.88.69 was modified to describe statistical reporting numbers 8413.91.9039, 8413.91.9046, 8413.91.9059, and 8413.91.9099 effective July 1, 2026.
- U.S. note 20(vvv)(i)(6) under HTSUS 9903.88.69 was modified to describe statistical reporting numbers 8413.91.9039, 8413.91.9046, 8413.91.9059, and 8413.91.9099 effective July 1, 2026.
- U.S. note 20(vvv)(iv)(4) under HTSUS 9903.88.69 was modified to describe statistical reporting numbers 3926.90.9915 and 3926.90.9920 effective July 1, 2026.
Notes: Prior to July 1, 2026, goods covered by notes 20(vvv)(i)(4), (5), and (6) were classified under HTSUS 8413.91.9065, 8413.91.9085, or 8413.91.9096. Prior to July 1, 2026, goods covered by note 20(vvv)(iv)(4) were classified under HTSUS 3926.90.9910.
ACE Functionality Effective September 23
ACE functionality for acceptance of the conforming amendment will be effective at noon on September 23, 2026.
Importers should not submit the corresponding Chapter 99 HTSUS number for the Section 301 China duties when HTSUS 9903.88.69 is submitted.
Questions about ACE entry rejections involving product exclusions should be directed to the importer’s CBP Client Representative.
Refunds for Section 301 Duties Already Paid
To request a refund of Section 301 duties paid on previous imports of products granted duty exclusions by USTR, importers may file a Post Summary Correction (PSC) if the entry is within the PSC filing timeframe.
If the entry is beyond the PSC filing timeframe, importers may protest the liquidation if the entry is within the protest filing timeframe.
CBP gives the example of Chinese goods entered from July 1 through September 22, 2026 that are subject to the conforming amendments under HTSUS 9903.88.69 and on which Section 301 China duties were paid. Importers should file a PSC on or after September 23, 2026, to obtain a refund of duties paid.
Questions about Section 301 entry-filing requirements should be sent to CBP’s Office of Trade, Trade Remedy branch, at traderemedy@cbp.dhs.gov.
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