Everything electronics procurement teams need to know about Section 301 tariffs: which HTS codes are affected, current rates (List 1–4), exclusion codes, and how to calculate your duty exposure on China-origin components.
Section 301 tariffs are additional import duties imposed by the US on goods from China under the Trade Act of 1974. They were first implemented in 2018 following a USTR investigation finding that China's trade practices — including forced technology transfer and IP theft — are unreasonable and discriminatory. Section 301 tariffs are separate from and additive to normal MFN duty rates and the Section 122 global surcharge. For semiconductors and ICs (HTS chapters 8541–8542), the Section 301 rate under List 3 was raised to 50% effective January 1, 2025 — bringing the total effective rate to 60% for semiconductors from China.
The vast majority of electronic components from China are covered under Section 301 List 3 or List 4A (7.5% rate). List 3 covers essentially all of HTS Chapter 85 (electrical machinery), including microcontrollers, integrated circuits, printed circuit boards, electronic modules, and most passive components. List 4A covers some consumer electronics finished goods at 7.5%. Semiconductors and ICs (HTS 8541–8542) fall under List 3 at the 50% rate (effective January 1, 2025); other electronic components generally remain at 25%. The only China-origin electronics exempt from Section 301 are those with a valid, active exclusion code (see below).
USTR has periodically granted temporary product-specific exclusions from Section 301 tariffs. Exclusions are applied via special HTS subheadings (typically 9903.88.xx codes) that, when applicable to your import, reduce or eliminate the Section 301 surcharge. Exclusions are: (1) product-specific — you must verify that your exact product matches the exclusion description, (2) time-limited — they expire on specified dates and may or may not be renewed, and (3) self-certified — you as the importer determine eligibility and claim the exclusion on your entry. The TariffTracker calculator shows potential exclusion codes for your specific HTS code when you run a calculation.
Semiconductors and ICs (HTS 8541–8542) from China face 50% Section 301 under List 3 (raised from 25%, effective January 1, 2025). Other electronic components generally remain at 25% Section 301. Key codes at the 50% rate: 8542.31 (processors and microcontrollers), 8542.32 (memories), 8542.33 (amplifiers), 8542.39 (other ICs), 8541.29 (transistors and MOSFETs), 8541.10 (diodes). Codes remaining at 25%: 8532.24 (ceramic capacitors/MLCCs), 8533.21 (chip resistors), 8504.50 (inductors), 8534 (PCBs), 8544 (cable assemblies). The Section 301 rate stacks directly on top of MFN base rate and is paid at the time of US Customs entry.
Total duty = (MFN base rate + Section 301 rate + Section 122 rate) × customs value. For a typical semiconductor from China: (0% MFN + 50% Section 301 + 10% Section 122) × $10,000 customs value = $6,000 in duty. Additionally, MPF (Merchandise Processing Fee) of 0.3464% (min $32.71, max $614.35 per entry) applies. HMF (Harbor Maintenance Fee) of 0.125% applies for ocean shipments. The TariffTracker calculator computes all of these fees automatically.
Procurement teams have four main strategies: (1) Supply chain diversification — source equivalent components from Taiwan, Malaysia, Thailand, or Philippines where Section 301 does not apply. (2) Claim available exclusions — check USTR's exclusion list and TariffTracker for applicable 9903.88.xx codes. (3) First sale valuation — if goods are purchased through an intermediary, duty may be calculated on the factory price (first sale) rather than the importer's price, reducing the taxable base. (4) Foreign Trade Zones — assembly in a US FTZ can defer or reduce duty obligations, particularly useful for manufacturing operations.
| HTS Code | Description | MFN Rate | Examples |
|---|---|---|---|
| 8542.31 | Processors, microcontrollers (ICs) | Free | 50% Sec 301 + 10% Sec 122 = 60% total |
| 8542.32 | Memory ICs (DRAM, NAND, NOR) | Free | 50% + 10% = 60% total |
| 8541.29 | Power transistors, MOSFETs (≥1W) | Free | 50% + 10% = 60% total |
| 8532.24 | MLCCs (ceramic capacitors) | Free | 25% + 10% = 35% total |
| 8533.21 | Chip resistors (surface mount) | Free | 25% + 10% = 35% total |
| 8534.00 | Printed circuit boards (bare PCBs) | Free | 25% + 10% = 35% total |
No. CBP applies duties based on country of origin (where substantial transformation occurred), not country of shipment. Re-routing China-origin goods through Vietnam, Taiwan, or Mexico without genuine manufacturing in that country is country-of-origin fraud — a federal customs violation.
When USTR grants an exclusion, it typically applies retroactively to the effective date specified in the exclusion notice. In some cases this allows importers to file for refunds on previously paid Section 301 duties within the exclusion period. Filing a protest with CBP is required.
Section 232 tariffs are imposed on national security grounds and cover steel and aluminum products. Section 301 tariffs cover a much broader range of goods from China based on trade practice findings. Electronics are primarily affected by Section 301 (and now Section 122), not Section 232.
Section 301 applies at the time of formal entry into US commerce. Goods in a bonded warehouse or FTZ are not yet entered into US commerce. You pay Section 301 when goods are released from the warehouse/FTZ into the US market, based on the rate in effect at the time of that release.
Enter any part number or HTS code to get the full duty stack, MPF, HMF, and landed cost instantly.
Open Calculator →