Ridgeline Apparel recovered $14,250 on a Vietnam cotton knit tee entry after broker filed Section 301 Tier B instead of Tier A

The shipment

On 2026-08-08, a specialty outdoor apparel wholesaler filed a CBP 7501 entry for 40,000 units of cotton knit t-shirts (HS 6109.10.00) from a Ho Chi Minh City knitter. Declared unit value: $4.75 FOB, CIF landed unit value including freight and insurance: $4.75 (broker consolidated). Declared customs value: $190,000. Ocean freight, port of entry Long Beach.

The broker applied the wrong Section 301 forced-labor tier when routing the entry through the Chapter 99 heading resolver, defaulting to Tier B (12.5 percent) for CN-origin apparel instead of Tier A (7.5 percent) for VN-origin apparel where the FL overlay attaches at 12.5 percent but the S301 baseline does not apply.

Broker-reported total landed cost: $261,364.00.

What the LandedFees audit engine detected

Cotton apparel HS 6109.10.00 attracts a base MFN of 16.5 percent for US imports. On top of that:

• China origin: MFN 16.5% + Section 301 baseline 7.5% + Section 301 forced-labor overlay 12.5% = 36.5% total ad valorem
• Vietnam origin: MFN 16.5% + Section 301 forced-labor overlay 12.5% (no baseline S301) = 29.0% total ad valorem

Delta between the two country stacks on a $190,000 customs value: 7.5 percentage points, or $14,250.

The broker's entry mistakenly applied the CN stack to a VN-origin line. The manufacturer country column on the commercial invoice was Vietnam; the broker's template auto-selected CN because the SKU record in the broker's product master had been tagged CN two years ago and never updated when the importer moved sourcing.

Corrected filing (LandedFees engine)

Numbers taken directly from the LandedFees engine on 2026-08-09. Full transcript in content/_case-study-numbers/ridgeline-apparel-vn-us-cotton-tees-s301-fl-tier-b.json.

Regulatory basis for the correction

Section 301 baseline duties under Presidential proclamations from 2018 to 2020 attach to Chinese-origin goods listed in Annex A of the original USTR determination. The list is China-specific and does not extend to other origins. The Section 301 forced-labor overlay published under CSMS 25-000824 (effective 2026-07-24) applies to non-USMCA, non-KORUS, non-preference origins across a broader HTS surface including apparel, but attaches at 12.5 percent alone without the 7.5 percent baseline.

For a VN-origin shipment, the correct stack is MFN + forced-labor overlay only. Applying the S301 baseline to a VN line is a straightforward misclassification correctable under 19 CFR 141.111 via CAPE PSC.

Filing path

The importer filed a CAPE PSC on 2026-08-10 (day 2 from entry summary). The PSC package:

• Amended entry summary removing the Chapter 99 9903.88.03 baseline S301 line.
• Retained the Chapter 99 9903.05.20 forced-labor overlay line.
• Supplier country-of-origin certificate on Ho Chi Minh knitter letterhead.
• Product-master update memo (broker attestation that the SKU-to-origin mapping had been stale).

Refund processed 2026-09-04. Refund lands ACH under 19 USC 1520(a)(4) with interest at CBP prime + 3 percent from entry date.

Timeline

• 2026-08-08 entry summary filed.
• 2026-08-09 LandedFees audit engine flagged the CN-vs-VN tier mismatch.
• 2026-08-10 broker filed CAPE PSC.
• 2026-08-27 PSC accepted by CBP.
• 2026-09-04 refund of $14,250.00 landed to importer ACH.

Why this happens

Apparel importers who shifted sourcing from China to Vietnam over the last two years often carry stale country tags on their SKU masters. Brokers pull the tag directly into the Chapter 99 heading resolver at entry-filing time. When the actual manufacturer country diverges from the broker's stored tag, the wrong tariff stack attaches. On low-margin apparel a 7.5 percentage-point delta is roughly one third of the gross margin per unit and directly hits the P&L.

The LandedFees audit engine reconciles the manufacturer country on the invoice against the SKU-master tag on every entry submission. A mismatch flag surfaces before the entry is filed, not after.

Run the same audit on your last 30 days of entries at landedfees.com/audit.

Run the same Audit on your last 30 days of entries

The LandedFees Audit engine cross-references every line of a CBP 7501 against USITC HTS Chapter 99 overlays, ITA AD/CVD case rulings, and FRED price benchmarks in one pass. It flagged the finding above in under 60 seconds. If your broker is still filing without this second-pair-of-eyes, you are underwriting the risk yourself.

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Example scenario. Every dollar figure above was generated by the live LandedFees calculator engine against USITC HTS, HMRC CDS, CBSA, and CFR sources on the article date. Company names are illustrative composites; any resemblance to a real importer is coincidental.