Section 301 Exclusions Expiring November 2026: The Full List Importers Need

When do the current Section 301 exclusions expire?

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 in late November 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.

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 HS classification API returns accurate 10-digit HTSUS classification at 96% accuracy at the 6-digit level on production traffic, which is the foundation for cross-referencing your catalog against the exclusion list.

TL;DR: 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 HS classification API reaches 96% accuracy at the 6-digit level on production traffic and returns the full US tariff stack (MFN + Section 301 + Section 232 + Section 122 + Chapter 99), making catalog-to-exclusion matching tractable at scale. CBP collected $225.8 billion in duties, taxes, and fees in FY 2025, much of it from Section 301 enforcement on Chinese-origin imports.

Last updated: May 2026

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 November 10, 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 HS classification API supports the classification piece (accurate 10-digit HTSUS at 96% accuracy at the 6-digit level on production traffic) and the GingerControl compliance team can support the cross-reference and product description matching work.

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.

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.

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 HS classification API returns 10-digit HTSUS classification with the full US tariff stack (MFN + Section 301 + Section 232 + Section 122 + Chapter 99) in every response. The reasoning chain documents which Section 301 List applies and supports both exclusion analysis and audit defense.

Tracking the November 2026 Deadline

USTR has not yet announced whether the November 10, 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 tracks USTR exclusion announcements and delivers alerts matched to the specific HTSUS lines in the user's catalog. For Section 301 specifically, this means catching exclusion extensions, modifications, or expirations within hours of USTR publication.

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 10, 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 delivers alerts on USTR exclusion changes 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) and Section 122 reciprocal tariffs continue to apply independently based on their own rules. Products with Section 301 exclusions may still carry Section 232 and Section 122 entries depending on the HTSUS line and country-of-origin specifics.

How does GingerControl support Section 301 exclusion analysis?

The HS classification API returns accurate 10-digit HTSUS classification with the full Section 301 entries in the tariff stack. For exclusion analysis (cross-referencing your catalog against the USTR exclusion list and verifying product description match), the GingerControl compliance team can support the work in Mandarin, Cantonese, Spanish, or English depending on your team's preference.

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 10, 2026 expiration. Catalog matching, sourcing diversification analysis, USMCA qualification evaluation, and exclusion renewal preparation all take time to execute properly.

Try the GingerControl API at gingercontrol.com/products/openapi. The OpenAPI is faster, cheaper, and more accurate than the alternatives, and has already saved customers a combined $4M in duties through optimized HTS classification and full tariff stack visibility. You can test the live API speed and see real response times directly on the page.

GingerControl is not just a tool. Our team includes native Mandarin, Cantonese, Spanish, and English speakers who support Section 301 strategy across exclusion analysis, sourcing diversification, USMCA nearshoring, and substitution drawback planning. Talk to our team about preparing your catalog for the November 2026 deadline.

References

[REF 1] 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

[REF 2] 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

[REF 3] 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

[REF 4] 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

[REF 5] U.S. Customs and Border Protection, Trade Statistics Data cited: $225.8 billion in duties, taxes, and fees collected in FY 2025 Source: CBP Trade Statistics Published: 2025

[REF 6] White House, Trump-Xi November 1 2025 Trade Announcement Data cited: Bilateral trade announcement triggering exclusion extension Source: White House announcement November 1, 2025