Section 301 Duties Survive: What the Continuation Ruling Means for Your 2027 Sourcing Plan

Two weeks after we reported the reciprocal tariff cut on about USD 30 billion of goods, Washington has made the other half of the picture official: the older, broader tariff architecture against Chinese imports is staying. For importers the two stories have to be read together, because reading only one of them will lead to the wrong landed-cost model.

What USTR decided

On 7 October 2026 the Office of the United States Trade Representative published a notice (91 Federal Register 64212) confirming that the two foundational Section 301 actions did not terminate at their four-year anniversaries. The action effective 6 July 2018 passed its anniversary on 6 July 2026, and the action effective 23 August 2018 on 23 August 2026.

Under Section 307 of the Trade Act of 1974, both would have expired automatically on those dates unless representatives of benefiting domestic industries asked for continuation. They asked in volume: 68 producer requests and 18 association requests for the July action, 57 and 19 for the August action — 162 requests in total. The statutory test is minimal. One qualifying request would have been enough, and USTR has no discretion to end the actions once one is filed. This stage of the process is administrative, not an evaluation.

What the ruling does not say

The notice does not touch duty rates, and it does not evaluate whether the tariffs are working. USTR has now opened the second statutory four-year review, with a separate public-comment process. That review is where the arguments will actually be heard — including arguments for new product exclusions.

The part importers keep mixing up

Here is the point worth stating plainly. The reciprocal arrangement covers a published list of consumer goods. Section 301 covers a much larger universe: Lists 1 through 4A, roughly USD 370 billion of Chinese imports measured at the trade values prevailing when the lists were drawn, at additional rates of 7.5% to 25%. Current trade under those lines is lower than the original figures, both because the duties suppressed volumes and because supply chains have been moving away from China independently.

So the correct reading is not "tariffs are coming down". It is that a specific, negotiated list is being relieved while the floor under everything else stays exactly where it was. If your product was not named in the reciprocal list, your duty position in 2027 is unchanged.

Also on the Q4 calendar: postal rates

If you sell direct to consumers, add this to the model. The US Postal Service peak-season surcharge took effect on 4 October 2026 and runs through 17 January 2027, covering Priority Mail Express, Priority Mail, Ground Advantage and Parcel Select. For commercial shippers, Ground Advantage adds roughly USD 0.40 to USD 7.70 per piece depending on weight and zone, Priority Mail up to about USD 9.10, and Priority Mail Express up to about USD 18.20.

On a small appliance shipped by post, that surcharge can be a larger percentage change than the tariff line. Q4 pricing reviews that look only at duty will miss it.

What to do before you quote 2027

• Test each HTS line twice. One against the reciprocal list (rate relief possible) and once against the Section 301 tranches (unchanged). A line can be in neither, one, or both.
• Build a two-column landed-cost model — current duty and post-implementation duty — and keep both live until implementation details are published.
• Add the postal surcharge as its own line item for any DTC channel, with the 17 January 2027 expiry noted.
• Use the second review window. It is the formal venue for exclusion requests and for evidence on cost pass-through. Trade associations are the usual route for smaller importers.
• Do not conflate the refund tracks. CBP's IEEPA refund system moved into a third phase on 6 October, now covering some finally-liquidated entries — but it applies to the emergency-powers tariffs, only for importers that litigated and hold a court reliquidation order. It is not a general Section 301 refund.

Our exports ship EXW Dongguan, so duty and postage are settled on your side and both changes land directly in your cost model. If you want us to quote the current and post-implementation scenario side by side for a specific pest-control or PCBA order, send us the model and the destination market.