What Chinese goods actually cost to import in 2026: the duty stack after IEEPA

What changed

Two layers came off. The reciprocal tariff and the 20% fentanyl related duty on Chinese goods both rested on IEEPA, and CBP stopped collecting them on 24 February 2026 after the Supreme Court held the statute does not authorise tariffs. Any headline quoting a Chinese reciprocal percentage is describing a regime that ended in February 2026.

Everything built on other statutes stayed. The Section 301 tariffs from the 2018 investigation are intact: 25% on Lists 1, 2 and 3, and 7.5% on List 4A. The strategic sector increases from the four year review are intact too, and they carry the harshest numbers in the schedule, with electric vehicles at 100%, semiconductors and solar cells at 50%, and batteries and critical minerals at 25%.

One layer was added. The Section 301 forced labour action that took effect on 24 July 2026 places China in the 12.5% tier, applied broadly across chapters 1 to 97.

Section 232 sits on top wherever the goods qualify. Since 6 April 2026 the metals tariffs apply to the entire customs value of covered steel, aluminium and copper articles and their derivatives rather than to declared metal content, which pulled a great deal of ordinary consumer hardware into a 50% or 25% assessment.

Exclusions still exist. 178 Section 301 product exclusions remain valid until 10 November 2026, and they attach to subheadings rather than to categories, so the only way to know whether yours survives is to check the exact code.

As an aggregate, the Penn Wharton Budget Model put the effective US tariff rate on Chinese imports at 23.2% in mid 2026. That is a trade weighted average across everything the US buys from China. No individual shipment is assessed at 23.2%, and using it as a planning number will mislead you in both directions.

Who it affects

• Consumer electronics and accessory sellers, most of whom sit on List 3 or List 4A and now carry the forced labour layer as well.
• Importers who priced 2026 assuming the fentanyl duty would persist. Their landed costs fell in February and a surprising number never repriced.
• Anyone importing goods with a substantial steel, aluminium or copper body, where the April valuation change did more damage than any rate change.
• Sellers holding a Section 301 exclusion that expires on 10 November 2026, who have a fourth quarter buying decision to make before then.

A worked cost example

A seller imports 2,000 Bluetooth speakers from Shenzhen at $11.40 each. This is what the stack looks like now, set against what the same order cost before 24 February 2026. The MFN rate is illustrative, so confirm your own subheading.

That order is $1,700 cheaper to land than it was in January, which is not the direction most sellers assume 2026 went. The forced labour layer added $2,850 in July, but the removal of the fentanyl duty took $4,560 off in February, and the net is a saving. Whether it holds depends on litigation nobody in this supply chain controls.

What importers should do

1. 1 Reprice from the current stack rather than from a 2025 quote. A lot of sellers are still carrying a 20% duty in their cost model that CBP stopped charging in February.
2. 2 Check whether your subheading is one of the 178 Section 301 exclusions expiring on 10 November 2026, and plan the fourth quarter buy around it.
3. 3 Look at whether any part of your product body brings it into Section 232 scope. Since April the assessment runs on full customs value, not on metal content.
4. 4 If you paid fentanyl or reciprocal duties in 2025, that is a refund claim and it deserves its own workstream rather than a note in a spreadsheet.
5. 5 Discount any tracker still publishing a China reciprocal rate. It is describing something that no longer exists.

Questions importers keep asking

Primary sources

• Penn Wharton Budget Model, effective tariff rates →
• USITC Harmonized Tariff Schedule →

Related changes

What to re-check, and when

This page is about the China duty stack, and no published instrument names a closing date for the measure itself, so this site records no scheduled end for it: it runs until the authority behind it revokes or amends it, which is a finding about the measure rather than a gap in the record, while any temporary provision sitting alongside it carries its own date in the passage above that describes it, and what is dated below is the reading rather than the measure.

The claims on this page about the China duty stack were last read on 28 August 2026, against the sources it names, and what to check first is the sentence under this one.

Re-check this stack whenever a new Section 301 or Section 232 investigation is announced, and again ahead of 10 November 2026 when the 178 remaining China exclusions lapse.