Section 301 Exclusions Expiring November 2026: The Full List Importers Need
Chen Cui Co-Founder of GingerControl What changed: Exclusions run through11:59p.m.EDT November9,2026; November10 is post-expiration.
The 178 Section 301 product exclusions that were extended after the November 1, 2025 Trump-Xi trade announcement expire at 11:59 p.m. eastern daylight time on November 9, 2026. The extension covers exclusions under HTSUS 9903.88.69 and 9903.88.70 with their corresponding U.S. notes. USTR notice was published in the Federal Register on December 1, 2025 and became effective November 30, 2025. After the expiration date, products covered by these exclusions are subject to the underlying Section 301 tariff (typically 25%) unless USTR takes further action.
In this post
- How do I know which Section 301 exclusions affect my catalog?
- What the November 2026 Expiration Actually Means
- How to Match Your Catalog Against the Exclusion List
- What Affected Importers Should Do Before November 2026
- Why Accurate 10-Digit Classification Matters for Exclusion Analysis
- Tracking the November 2026 Deadline
- Frequently Asked Questions
- Start Your Section 301 Exclusion Analysis Now
- References
How do I know which Section 301 exclusions affect my catalog?
You match the 10-digit HTSUS lines in your import history against the exclusions listed in the USTR Federal Register notice. Exclusions are granted at the specific 10-digit HTSUS line and product description level. A grant for "smart speakers with display and voice assistant" on HTSUS 8517.62.0090 only applies to products that match the specific description, not to all imports under that HTSUS line. GingerControl's Classification + Tariff Calculation API returns a 10-digit HTS code (99.86% at the 10-digit level on GingerControl's own internal test of 1,000+ products), which is the foundation for cross-referencing your catalog against the exclusion list.
USTR extended 178 Section 301 product exclusions through November 9, 2026 following the November 1, 2025 Trump-Xi trade announcement. The exclusions sit under HTSUS 9903.88.69 and 9903.88.70 (heading-level pointers) with attached U.S. notes that identify the specific 10-digit HTSUS lines and product descriptions covered. The extension was effective November 30, 2025. For Chinese-origin importers, the expiration means the underlying Section 301 tariff (typically 25%) returns on covered products unless USTR takes further action. The right preparation work now: identify which exclusions cover your catalog by matching your 10-digit HTSUS lines and product descriptions against the USTR list, model the duty cost increase per affected SKU, and evaluate alternatives (sourcing diversification, tariff engineering, USMCA-qualifying nearshoring, substitution drawback on exported portion). GingerControl's Classification + Tariff Calculation API returns a 10-digit HTS code with its U.S. duty layers (General, Special, Section 301, Section 232 and other Chapter 99 lines), making catalog-to-exclusion matching tractable at scale. CBP collected $216.7 billion in duties, taxes, and fees in FY 2025, including $35.6 billion in Section 301 duties assessed on products of China.
For Chinese-origin flows, compare Section 301 strategies for Chinese-origin imports using the product, sourcing, exclusion and recovery facts.
What the November 2026 Expiration Actually Means
USTR's Section 301 exclusion process has historically favored short-term renewals over permanent exemptions. The exclusions extended through 11:59 p.m. EDT on November 9, 2026 cover 178 product descriptions that previously qualified for Section 301 exemption. Once they expire, covered products revert to the underlying Section 301 tariff rate.
The mechanics:
- HTSUS 9903.88.69 is the heading-level identifier that says a product is covered by a specific exclusion grant
- HTSUS 9903.88.70 is the related heading for additional exclusion coverage
- U.S. notes attached to each of these headings list the specific 10-digit HTSUS lines and product descriptions that qualify
- Importers file using HTSUS 9903.88.69 or 9903.88.70 plus the underlying Chapter 1-97 HTS classification
When the exclusions expire, importers can no longer file under 9903.88.69 or 9903.88.70 for the covered products. The Section 301 tariff (typically 25% under List 1, 2, or 3) applies to the entry instead.
For a $5M annual import value under covered exclusions, the duty cost increase at 25% is $1.25M annually starting November 10, 2026. The financial impact is material enough that catalog matching and alternative strategy work should begin well before the expiration date.
How to Match Your Catalog Against the Exclusion List
The matching work has three steps:
Step 1: Identify your 10-digit HTSUS lines. Pull your import history for the past 12 months and extract the unique 10-digit HTSUS lines with Section 301 exposure. Cross-reference against your current catalog to confirm which lines are still active.
Step 2: Cross-reference against the USTR exclusion list. The USTR notice in the Federal Register lists the specific 10-digit HTSUS lines and product descriptions covered by the extended exclusions. For each line in your import history that has Section 301 exposure, check whether an active exclusion covers it.
Step 3: Verify product description match. Exclusions require the product description to match the exclusion description, not just the 10-digit HTSUS line. The exclusion language is the test. Products that share the HTSUS line but do not match the specific product description do not qualify for the exclusion.
For mid-market and enterprise importers with 1,000+ active SKUs, this matching work is significant. GingerControl's Classification + Tariff Calculation API supports the classification piece (a 10-digit HTS code; 99.86% at the 10-digit level on our own internal test of 1,000+ products) and GingerControl's trade advisory service, quoted for its scope, can review the matching as a second pair of eyes.
What Affected Importers Should Do Before November 2026
Six recommended steps before the expiration date:
1. Run a complete catalog matching exercise. Identify which SKUs are currently covered by extended exclusions. Model the duty cost increase per SKU if the exclusion expires without further extension.
2. Evaluate sourcing diversification. For high-impact SKUs, evaluate alternative sourcing from non-Chinese origins. Vietnam, Thailand, Mexico, India, and other countries are common alternatives. The substantial transformation analysis required for genuine country-of-origin shift is fact-specific; see our Vietnam and Thailand as China substitute origins analysis for the test.
3. Evaluate USMCA-qualifying Mexico nearshoring. For products where Mexico manufacturing can meet USMCA rules of origin (tariff shift, regional value content, product-specific rules), USMCA preferential treatment eliminates both MFN and Section 301. See our China-to-Mexico nearshoring USMCA qualification guide.
4. File new exclusion requests where applicable. USTR periodically opens new exclusion request windows. Products with strong economic and substitute-availability arguments may qualify for new exclusion grants.
5. Model the substitution drawback opportunity. For importers who re-export some portion of covered products, substitution drawback recovers 99% of Section 301 duties paid on the exported portion.
For eligible exported goods, evaluate Section 301 China tariff drawback recovery rather than treating the China-list duty as a sunk cost.
6. Build monitoring infrastructure. Tariff and exclusion changes happen frequently. Compliance Radar delivers personalized alerts matched to the HTSUS codes in your catalog so you catch exclusion expirations, modifications, and new grants in time to act.
The Compliance Radar alerts matched to your HTS codes workflow ties each policy notice to the product codes in the monitored catalog.
Why Accurate 10-Digit Classification Matters for Exclusion Analysis
Exclusion grants operate at the 10-digit HTSUS line and product description level. A classification error at the 10-digit level can:
- Miss an exclusion that should apply (paying Section 301 unnecessarily)
- Claim an exclusion that does not apply (creating audit exposure and penalty risk)
- Misidentify the underlying Chapter 1-97 line, which cascades to incorrect duty calculation
GingerControl's Classification + Tariff Calculation API returns a 10-digit HTS code with its U.S. duty layers (General, Special, Section 301, Section 232 and other Chapter 99 lines) in every response, so the Section 301 lines that apply are visible per item for exclusion analysis.
Tracking the November 2026 Deadline
USTR has not yet announced whether the November 9, 2026 expiration will be extended further. Historical patterns suggest USTR may extend select exclusions while letting others expire, but the specific outcome depends on bilateral negotiations, USTR priorities, and political timing.
For importers, the operational approach is to plan for expiration as the default while monitoring USTR announcements for potential extensions:
- Default plan: Section 301 tariff returns on covered products November 10, 2026. Model duty cost increase and evaluate alternatives.
- Upside scenario: USTR extends some or all exclusions further. Continue current import pattern with no immediate duty change.
- Mixed scenario: USTR extends some exclusions and lets others expire. Catalog-by-catalog impact varies.
Compliance Radar checks new Federal Register notices, which carry USTR's exclusion actions, against the specific HTSUS lines in the user's catalog. For Section 301 specifically, this means catching exclusion extensions, modifications, or expirations once the Federal Register notice is published.
Frequently Asked Questions
Which Section 301 exclusions are extended through November 2026?
178 product exclusions previously scheduled to expire November 29, 2025 were extended through 11:59 p.m. EDT on November 9, 2026. The exclusions cover HTSUS 9903.88.69 and 9903.88.70 with corresponding U.S. notes that identify the specific 10-digit HTSUS lines and product descriptions. The USTR notice was published in the Federal Register on December 1, 2025.
What was the reason for the November 2025 exclusion extension?
The extension followed the November 1, 2025 trade and economic announcement by the White House regarding the Trump-Xi negotiation. The exclusion extension was part of the broader bilateral framework that emerged from those discussions.
How do I know if my products are covered by an extended exclusion?
Cross-reference your 10-digit HTSUS lines and product descriptions against the USTR exclusion list. A product is covered only if both the HTSUS line and the product description match the exclusion language. Importers with large catalogs may need automated cross-referencing; the GingerControl HS classification API plus compliance team support can handle this work at scale.
What happens to my imports after November 10, 2026 if the exclusion expires?
The underlying Section 301 tariff (typically 25% for List 1, 2, or 3 products) applies to your imports starting on the expiration date. You cannot continue filing under HTSUS 9903.88.69 or 9903.88.70 for the covered products. The duty cost increase is the Section 301 rate applied to your import value on affected SKUs.
Will USTR extend the exclusions again?
USTR has not announced further extensions beyond November 9, 2026. Historically USTR has periodically extended exclusions, sometimes selectively. Importers should plan for expiration as the default while monitoring USTR announcements for potential further extensions. Compliance Radar emails alerts on exclusion changes published in the Federal Register, matched to your catalog.
Can I file a new exclusion request for products that lose coverage?
USTR periodically opens new exclusion request windows. Products with strong economic and substitute-availability arguments may qualify for new exclusion grants. The exclusion request process is administered by USTR; check USTR's Section 301 exclusion process page for current request windows and procedures.
Does the Section 301 exclusion extension affect Section 232 or Section 122 tariffs?
No. Section 301 exclusions only affect Section 301 tariffs. Section 232 metals tariffs (50% globally on steel/aluminum/copper with the U.K. at 25%, with the April 2 2026 tiered structure) apply independently based on their own rules, and Section 122 ended on July 24, 2026 (it covered entries from February 24 to July 23, 2026). Products with Section 301 exclusions may still carry Section 232 entries depending on the HTSUS line and country-of-origin specifics.
How does GingerControl support Section 301 exclusion analysis?
The Classification + Tariff Calculation API returns a 10-digit HTS code with its Section 301 lines among the duty layers. For exclusion analysis (cross-referencing your catalog against the USTR exclusion list and verifying product description match), GingerControl's trade advisory service, quoted for its scope, can review the work as a second pair of eyes.
Start Your Section 301 Exclusion Analysis Now
If your catalog includes Chinese-origin imports covered by the extended Section 301 exclusions, the time to evaluate alternatives is now, not after the November 9, 2026 expiration. Catalog matching, sourcing diversification analysis, USMCA qualification evaluation, and exclusion renewal preparation all take time to execute properly.
The Classification + Tariff Calculation API is for enterprise systems and starts with a call: a product description and its origin go in, and a 10-digit HTS code with its U.S. duty layers comes back as JSON, 120 items per call by default. There is no public tester or test key; your key comes after the call.
GingerControl is not just a tool: its trade advisory service, quoted for its scope, reviews exclusion matching and your Section 301 tariff exposure as a second pair of eyes, and its duty drawback service builds the claim file when exported goods qualify. Talk to our team about preparing your catalog for the November 2026 deadline.
References
- Office of the U.S. Trade Representative, Extending Exclusions to November 2026 Final FRN
Data cited: 178 exclusions extended through 11:59 p.m. EDT November 9, 2026; HTSUS 9903.88.69 and 9903.88.70 coverage
Source: USTR Section 301 Exclusion Extension Notice
Published: November 2025 - Federal Register, Notice of Product Exclusion Extensions
Data cited: USTR Section 301 exclusion extension notice publication December 1, 2025
Source: Federal Register Notice 2025-21671
Published: December 1, 2025 - Office of the U.S. Trade Representative, China Section 301 Tariff Actions and Exclusion Process
Data cited: Section 301 exclusion request process and historical extension patterns
Source: USTR Section 301 Exclusion Process - U.S. Customs and Border Protection, Section 301 China Trade Remedies
Data cited: Section 301 List 1-4A coverage and HTSUS 9903.88 series
Source: CBP Section 301 - U.S. Customs and Border Protection, Trade Statistics
Data cited: $216.7 billion in duties, taxes, and fees collected in FY 2025, including $35.6 billion in Section 301 duties on products of China
Source: CBP Trade Statistics
Published: 2025 - White House, Trump-Xi November 1 2025 Trade Announcement
Data cited: Bilateral trade announcement triggering exclusion extension
Source: White House announcement November 1, 2025
Shortlisting AI for trade compliance?
Hand this to GingerOS.
Pick a 30-minute slot on the next page with Chen Cui, our CEO. Bring one notice or one SKU list (an ERP export, a spreadsheet or an email will do) and see what GingerOS does with it.
Reviewed by Michael Weick, LCB / CCS
