What to know about each:
- China. The Section 301 duties on Chinese goods continue, with exclusion updates as recent as September 22, 2026.
Forced labor. These duties took effect July 24, 2026; goods already subject to Section 232 are exempt.
ACE blocked drawback on them from August 12 to 18, 2026, until CBP corrected it.
- Brazil. A 25% duty imposed by a July 15, 2026 memorandum, on goods entered from July 22, 2026.
You can recover Section 301 duty through unused merchandise drawback, by direct identification or by substitution within the same 8-digit HTS subheading, and through manufacturing drawback with a ruling.
One part isn't settled. A substitution claim is capped at the lesser of the import duty and the duty the exported article would bear if imported.
When a Chapter 99 duty depends on the country of origin, as these do, how CBP applies that cap isn't settled.
Your broker decides line by line.
- CBP CSMS #69567203, Aug 18, 2026[1]
- CBP CSMS #69535943, Aug 2026[2]
- CBP CSMS #69302472, Jul 21, 2026[3]
- CBP CSMS #69990649, Sept 22, 2026[4]
- 19 U.S.C. 1313(b), (j)(2)[5]
- Are Section 301 duties eligible for drawback?
- Can you recover Section 301 tariffs through duty drawback?
- Can I recover Section 301 tariffs through unused merchandise drawback?
Written by the NexQloud Drawback team from the primary sources linked on this page.
Not legal advice. NexQloud Drawback is not a government agency.
NexQloud Drawback is software used by licensed customs brokers.
