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China Tariff Stacking in 2026: What Switches Each Layer Off

Photo: Bahnfrend, CC BY-SA 4.0

Percentages are how China tariff stacking usually gets described, while a broker pays dollars line by line, so this piece works through one entry. It is a calculation from the published headings and rates, with no importer behind it. The entry has two lines of Chinese goods entered on or after July 24, 2026, each with $50,000 of customs value. Line 1 is a small DC motor, 12 W and 30 mm across, not brushless, filed under 8501.10.4060. Line 2 is a mains-powered home drip coffee maker under 8516.71.0020. Section 232 does not reach either line, and fees such as merchandise processing stay out of the sums.

Where 37.5% on List 1 comes from

Three chapter 99 headings produce it, and each reads in the tariff schedule as the ordinary duty plus a rate. List 1 products take 25% under 9903.88.01. List 4A products take 7.5% under 9903.88.15. The newest layer, 9903.05.31, adds 12.5% to articles of China entered from 12:01 a.m. Eastern on July 24, 2026 (Federal Register notice 2026-15181, CBP CSMS 69326983).

Nothing in the new heading cancels the old ones. Note 52(a) to subchapter III has goods under the new headings carry any other additional duty in that subchapter too, except where its subdivisions (b) through (k) say otherwise. For a List 1 line the sum is 25% and 12.5%, which makes 37.5%. For a List 4A line it is 7.5% and 12.5%, which makes 20%. The most-favored-nation rate is charged as well: 4.4% on 8501.10.40, 3.7% on 8516.71.00 (HTS 8501.10.40 and 8516.71.00).

The entry, line by line

The motor’s subheading is on List 1 (note 20(b)). It would pay 25%. But item 26 of note 20(vvv)(i) describes it almost word for word, a DC motor under 18.65 W, other than brushless, under 38 mm in diameter, and that earns heading 9903.88.69 in place of 9903.88.01. The legacy duty drops out and the 12.5% stays. Duty on the motor: $2,200 at 4.4% plus $6,250 at 12.5%, so $8,450.

The coffee maker is on List 4A (note 20(s)) and has no exclusion. It pays $1,850 at 3.7%, $3,750 at 7.5% and $6,250 at 12.5%, which is $11,850. The entry owes $20,300 in all, 20.3% of what was declared.

A duty-bearing Section 232 heading would take the 12.5% off a line through 9903.05.90. A proper chapter 98 claim does the same, except under 9802.00.40, .50, .60 and .80, where the duty applies to the value of the repairs, alterations or processing, or to the assembled article less U.S. components. The entry above uses none of these.

One digit pair in the motor’s code

Now the broker files the same motor under 8501.10.4040, the brushless line. Item 26 no longer describes it, so 9903.88.69 cannot be claimed and 9903.88.01 applies. The motor’s duty becomes $2,200 plus $12,500 plus $6,250, or $20,950 instead of $8,450. The entry goes from $20,300 to $32,800, and the whole $12,500 difference is the 25% legacy duty on $50,000.

It can go the other way. A 14 W motor, 45 mm across, filed under 8501.10.4060 with a 9903.88.69 claim would be $12,500 short on a $50,000 line, because the exclusion needs both the listed ten-digit number and a product that fits the note’s description. Leaving 9903.05.31 off a line costs $6,250 here.

The order of numbers on the entry summary line carries no rate, but CBP’s CSMS fixes it: the chapter 98 number goes first, the chapter 99 numbers follow with Section 301 ahead of Section 232, and the chapter 1 to 97 number goes last because it carries the entered value.

What changes on November 10, and what has no date yet

The first piece of China tariff stacking with an end date is the exclusions under 9903.88.69 and 9903.88.70, which can be claimed on entries up to 11:59 p.m. Eastern on November 9, 2026, according to Federal Register notice 2025-21671, and Revision 21 of the HTS repeats that date. USTR’s press release says November 10, which is the first day without them. Unless USTR extends them, the motor falls to 9903.88.01 from then and the shipment to $32,800. The Federal Register has no USTR notice extending them. Notice 2026-20510 of October 7 says the legacy Section 301 actions remain in effect while the four-year review continues.

The truce is thinner on paper. Treasury Secretary Bessent said on September 23 that the truce would be extended to January 10, 2027 (CNBC). The Federal Register carries no executive order or notice for it. On September 27 the White House published the “30-for-30” lists, and the U.S. list includes 8516.71.00, the coffee maker. The terms of reference leave any tariff cut to each country’s domestic legal process, and Revision 21 has no chapter 99 heading to claim one under. Until a heading appears, the coffee maker pays 20% in Section 301 duty plus 3.7%.

For the cost side of each layer on a shipment, see Landed Cost 101, and compare the freight line itself on Navo freight rates.

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