Tariffs
Section 301, de minimis, and forced-labor tariff actions affecting China-origin cargo.
Overview
Tariffs are the most volatile, highest-impact policy variable in cross-border logistics in 2026 — and the single fastest-growing line item in landed cost for China-to-US e-commerce sellers. From the original Section 301 tariffs (7.5%-25%, 2018-present) to the new fentanyl (20%) and reciprocal (10%) tariffs frozen at a combined 30%, to forced-labor Section 301 actions adding another 12.5% and a separate 60-country tariff front, to the elimination of de minimis for sub-$800 parcels — every one of these programs flows directly into FBA landed cost and pricing models. The deeper operational challenge is that different tariff tracks move on independent timelines: the June 11 US-China deal froze the 30% combined rate for 60 days but did not pause the separate forced-labor Section 301 proposal, which continues through USTR's comment and hearing process on its own track. The 60-day freeze decision window arrives roughly mid-August 2026. This hub maps every active tariff program against cross-border e-commerce inventory, lays out the 2026 timeline in chronological order, and gives the operational steps that actually reduce exposure — because in 2026, every cent of duty changes the P&L. Every tariff action that lands on China-origin goods flows directly into FBA landed cost, because the vast majority of Amazon's third-party seller inventory still originates in China. With the combined fentanyl/reciprocal tariff frozen at 30%, a separate forced-labor Section 301 proposal adding 12.5% on select categories, and the de minimis exemption now gone, the per-unit duty line on an FBA seller's P&L is meaningfully different from what it was just 12 months ago — and the truce clock resets in mid-August 2026. This hub tracks every active tariff program that touches cross-border e-commerce inventory, maps the timeline of 2026 policy actions in order, and lays out the operational steps that actually reduce exposure.
Timeline
| Milestone | Window | Why it matters |
|---|---|---|
| Section 301 China tariffs first imposed | 2018 onward, multiple rounds | The original foundation — tariffs on a wide range of China-origin goods at 7.5%-25% depending on HTS code and list, still active and layered on top of every other program below |
| De minimis exemption eliminated | 2025 | Section 321 de minimis — the rule that let sub-$800 parcels enter duty-free — was eliminated, meaning small-parcel direct-ship models now pay full duties like any other entry |
| IEEPA tariffs ruled unconstitutional | Feb 20, 2026 | Supreme Court ruling halted IEEPA-based tariff collection; IEEPA duties stopped being collected on goods entered after Feb 24 |
| Section 122 tariff replaces IEEPA revenue | Feb 24, 2026 onward | Initial 10% on all countries, raised to 15% — applies broadly as a replacement for the struck-down IEEPA duties, not China-specific |
| CAATSA supply chain certification EO | Jun 3, 2026 | New executive order requiring supply chain certification against forced labor — adds a documentation layer on top of existing tariff compliance |
| HTSUS tariff-line modifications | Effective Jun 8, 2026 | Select HTS lines saw duty rate changes (e.g. 9903.88.67: 10%→15%); importers need to recheck classification, not assume rates are static |
| US-China 30% deal & 60-day pause | Jun 11, 2026 (freeze through ~mid-Aug) | Combined 20% fentanyl + 10% reciprocal tariff held at 30%; further increases paused, not cancelled — decision point ~mid-August 2026 |
| 60-country forced-labor tariffs | Announced Jun 15, 2026 | USTR tariffs on 60 countries deemed insufficient on forced-labor imports — broad scope, not China-specific |
| Section 301 forced-labor 12.5% China proposal | Proposed Jun 20, 2026 | New 12.5% on Chinese goods from forced-labor Section 301 investigation — separate track from the 30% freeze, moving through USTR comment/hearing process |
| Section 232 metals rate cut | Announced Jun 26, 2026 | Steel/aluminum/copper tariffs cut from 25% to 15% for agricultural, industrial equipment, HVAC categories; trade-deal partner countries get additional relief |
| Brazil 25% tariff proposed | Announced Jun 26, 2026 | New front — 25% on most Brazilian goods over digital trade and deforestation practices; narrows a key diversification option for some importers |
| US-China Board of Trade comment period | Open now, ongoing | New bilateral body seeking public comment on tariff reductions for non-sensitive sectors — longer-term track, separate from the 60-day freeze |
Active US tariff programs affecting cross-border e-commerce (as of late June 2026)
| Program | Current Rate | Scope | Status | Decision Point |
|---|---|---|---|---|
| Section 301 (China) | 7.5%-25% (list-dependent) | China-origin goods on specific HTS lists | Active, exclusions expire periodically | Ongoing — check quarterly |
| Fentanyl tariff | 20% | China-origin goods (broad) | Active, frozen per Jun 11 deal | ~Mid-Aug 2026 (60-day freeze expires) |
| Reciprocal tariff | 10% | China-origin goods (broad) | Active, frozen per Jun 11 deal | ~Mid-Aug 2026 (60-day freeze expires) |
| Section 122 (IEEPA replacement) | 15% | All countries | Active since Feb 24, 2026 | No stated expiration |
| Section 301 forced-labor (China) | 12.5% (proposed) | China-origin goods, forced-labor-linked | Proposed, USTR comment/hearing process | TBD — track USTR docket |
| 60-country forced-labor tariffs | Varies by country | 60 countries, forced-labor-linked | Announced Jun 15, rate schedule pending | TBD — watch for per-country schedule |
| Section 232 (steel/aluminum/copper) | 15% (was 25%) | Agricultural, industrial, HVAC equipment categories | Active, reduced Jun 26 | Ongoing — confirm HTS qualifies |
| Brazil proposal | 25% (proposed) | Most Brazilian goods, with exceptions TBD | Proposed Jun 26 | TBD — wait for exception list |
| De minimis (Section 321) | Eliminated | Sub-$800 parcels (all origins) | Ended 2025 | N/A — gone |
* Compiled from USTR announcements, trade compliance reporting, and CBP updates. Rates shown are additional duties on top of the base HTS rate unless noted otherwise.
2026 tariff timeline at a glance (chronological)
| Date | Action | Operational Impact |
|---|---|---|
| Feb 20 | SCOTUS rules IEEPA tariffs unconstitutional | IEEPA collection stops; importers with pending IEEPA-paid entries begin refund process |
| Feb 24 | Section 122 tariff imposed (10%, later 15%) | New blanket duty layer on all entries, all countries — recalibrate landed cost models |
| Jun 3 | CAATSA supply chain certification EO | New documentation requirement — supply chain forced-labor certification added to entry process |
| Jun 8 | HTSUS tariff-line modifications effective | Select HTS lines see rate changes — recheck classification, don't assume static rates |
| Jun 11 | US-China 30% deal, 60-day pause | Rate frozen, not cut — decision point ~mid-August; frontloading window opens |
| Jun 15 | 60-country forced-labor tariffs announced | New tariff front — request per-country schedule from trade counsel if you source from affected countries |
| Jun 20 | China forced-labor Section 301 12.5% proposed | Separate from 30% freeze — submit comments, prepare supply chain documentation |
| Jun 26 | Section 232 metals cut to 15% | Recalculate landed cost for qualifying equipment categories; trade-deal partners get additional relief |
| Jun 26 | Brazil 25% tariff proposed | If Brazil is in your diversification plan, watch for exception list before shifting sourcing |
| ~Mid-Aug | 60-day freeze decision window | Plan for possible rate change — frontloading typically intensifies near tariff deadlines |
* Key dates for importers tracking overlapping tariff action windows. All dates 2026 unless noted.
Latest News
- Jun 26, 2026Tariffs
Section 232 Metals Tariffs Cut to 15% for Select Categories and Trade-Deal Partners
Steel, aluminum, and copper tariffs reduced from 25% to 15% for agricultural, industrial, and HVAC equipment categories, with additional relief for US trade-deal partner countries.
- Jun 26, 2026New Tariff Front
USTR Proposes 25% Tariff on Most Brazilian Goods
A 25% tariff on most Brazilian goods over digital trade and deforestation practices marks a new tariff front beyond China — narrowing a key diversification option for some importers.
- Jun 24, 2026Trade Deal
US-China Deal Freezes Combined Tariff at 30% for 60 Days; Board of Trade Opens for Comment
The 20% fentanyl + 10% reciprocal tariff held at 30%, with a 60-day pause on further increases. A new US-China Board of Trade is seeking public comment on non-sensitive sector tariff reductions.
- Jun 23, 2026IEEPA
IEEPA Refund Update: Collection Stopped Feb 24, Section 122 Now at 15%
First wave of IEEPA refunds reached Treasury May 5, but a new Section 122 tariff at 15% on all countries replaces the lost revenue stream. Section 232 and 301 duties remain unchanged.
- Jun 23, 2026Compliance
HTSUS Modifications Effective June 8; DOJ Prioritizes Trade Fraud Enforcement
Select HTS lines saw duty rate changes effective June 8. Combined with DOJ designating customs fraud a white-collar enforcement priority, accurate classification now carries higher stakes.
- Jun 20, 2026Section 301
USTR Proposes 12.5% China Tariff from Forced-Labor Section 301 Investigation
New 12.5% proposal on Chinese goods from a forced-labor Section 301 investigation, on a separate track from the 30% freeze — China's overall effective rate has declined to 24%, masking this category-specific increase.
- Jun 17, 2026Survey
72% of Trade Professionals Cite Tariff Volatility as Top 2026 Risk
FreightWaves survey shows tariff risk concern nearly doubled from 41% to 72% year-over-year, as companies accelerate supplier diversification and regional supply chain realignment.
- Jun 15, 2026Forced Labor
USTR Announces Tariffs on 60 Countries Over Forced Labor; Section 301 Opens on Brazil and 16 Others
New forced-labor-linked tariffs on 60 countries, plus separate Section 301 investigations opened on Brazil and 16 other trading partners — expanding the tariff landscape beyond China.
Featured Guides
Section 301 (China)
The longest-running active tariff program — 7.5%-25% on specific HTS codes, with exclusions that expire. Re-check your HTS mapping quarterly; an expired exclusion applied unknowingly creates retroactive duty liability on audit.
Section 122 (all-country)
The IEEPA replacement — currently 15% on all countries. Broad-based but lower-rate; the operational impact is less about which products are covered and more about the blanket cost layer it adds to every entry.
Forced-labor tariffs (multi-country + China-specific)
Two tracks: the 60-country action and the separate China 12.5% Section 301 proposal. Harder to mitigate through country diversification because they target supply chain practices rather than origin — documentation of labor sourcing is the primary defense.
De minimis elimination
The end of duty-free sub-$800 parcels changes the economics of small-parcel direct-ship models (SHEIN, Temu small-batch testing, DTC brands). Every parcel now incurs full duty — model it per SKU, not just freight cost.
Section 232 (metals)
Steel, aluminum, copper — now 15% for select equipment categories, down from 25%. The relief is scoped to specific categories (agricultural, industrial, HVAC equipment), not all metals broadly — confirm your HTS code qualifies.
HTS classification risk
DOJ has designated trade/customs fraud a white-collar enforcement priority. HTSUS modifications effective June 8 changed rates on specific lines. Accurate classification is now both a cost issue and an enforcement exposure — vague descriptions like 'daily necessities' are specifically flagged.
Prep Checklist
- ✓Run a full tariff exposure audit across every HTS code in your product catalog against the current rate schedule — Section 301, Section 122, forced-labor actions, and any country-specific proposals that apply to your origins
- ✓For products relying on Section 301 exclusions, confirm each exclusion's expiration date and renewal status directly — an expired exclusion applied unknowingly means retroactive duty assessed on audit, not just going forward
- ✓Re-check HTS classification accuracy across your catalog — the June 8 HTSUS modifications changed rates on specific lines, and DOJ enforcement priority means misclassification carries higher penalty risk than before
- ✓If you import steel, aluminum, or copper products in the agricultural/industrial/HVAC equipment categories, recalculate landed cost using the new 15% Section 232 rate instead of the prior 25%
- ✓Model the mid-August 2026 decision point into your booking calendar — the 30% combined rate freeze expires roughly then, and frontloading behavior typically intensifies as a tariff deadline approaches
- ✓Track the US-China Board of Trade comment period for tariff reduction opportunities in your product categories — this is a separate, longer-term track from the 60-day freeze
- ✓If you currently source from Brazil as a China-diversification move, watch for the final scope and exception list on the proposed 25% tariff — don't shift sourcing until exceptions are confirmed
- ✓Review your continuous customs bond sufficiency — total duty liability has likely increased materially with stacked tariffs, and an insufficient bond flagged by CBP triggers a surety review at the worst possible time
- ✓Keep your 'three documents' (B/L, commercial invoice, packing list) mirror-consistent — stacked tariffs mean CBP is scrutinizing declared value more closely, and inconsistencies between documents are an easy flag
Related Wiki
Section 301 Tariffs: What Importers Need to Know
How Section 301 tariffs are applied on top of standard duty rates, exclusion processes, bond implications, and country-of-origin rules.
Customs Bonds Explained: Single Entry vs. Continuous Bonds
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What is Detention in Shipping? Fee Structure & Container Return Guidelines
Detention (per diem) fees explained: how daily rates accumulate outside port gates, and how to ensure timely empty container returns.
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FAQ
It depends on the specific tariff programs that apply to your HTS code. For goods subject to the fentanyl (20%) and reciprocal (10%) tariffs, the combined rate is 30% on top of the base HTS duty — frozen per the June 11 deal but not reduced, with a decision point roughly mid-August 2026. Section 301 China tariffs (7.5%-25%, list-dependent) are separate and still active. Goods may also face the Section 122 15% all-country tariff. In short: there is no single 'China tariff rate' — you need to check which programs apply to each HTS code.