Post-Section 122 Sunset Lane Comparison: China vs Vietnam vs India vs EU vs UK (August 2026)
Section 122 expired July 24 2026, Section 301 forced-labor kicked in the same instant. This is the side-by-side landed cost comparison across five major sourcing lanes to the United States, using 100,000 USD CIF as the reference shipment. Worked numbers for the four most common product categories per lane, and the reshoring math that changed on July 24.
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Open calculatorPost-Section 122 Sunset Lane Comparison: China vs Vietnam vs India vs EU vs UK (August 2026)
Section 122 expired 12:01 AM Eastern Time July 24 2026. Section 301 forced-labor tariffs kicked in at the same instant. The in-transit grace period closed 12:01 AM ET July 28 2026. Every entry filed from that moment forward is priced against the new post-sunset stack.
This article walks through what the new landed cost looks like across five major US import lanes: China, Vietnam, India, EU, and UK. Using a 100,000 USD CIF reference shipment and four common product categories per lane, it shows exactly who won and who lost the July 24 rate transition.
The rate framework recap
Every US import origin now falls into one of these buckets:
- USMCA (Canada, Mexico) qualifying: Exempt from Section 301 forced-labor. Section 122 gone. Post-sunset net: minus 10 percent versus June.
- Tier 1 (17 economies including UK, EU as a bloc): 10 percent forced-labor rate on top of MFN and other regime layers. Post-sunset net: roughly zero (replaced 10 percent Section 122 with 10 percent forced-labor).
- Tier 2 (38 economies including China, India, Vietnam, Bangladesh, Thailand): 12.5 percent forced-labor rate. Post-sunset net: plus 2.5 percent versus June (12.5 percent forced-labor replaced 10 percent Section 122).
- Tier 3 (5 economies, variable structure): rate case-by-case, generally 10 to 12.5 percent with adjustment authority.
Section 301 China lists (1 through 4A) still apply on top of the forced-labor layer for China-origin goods. Section 232 still applies on steel, aluminum, copper derivatives, autos, semiconductors, wood. AD/CVD orders are unaffected.
China lane, five product examples
Chapter 8471 laptops (List 4A exposure)
Pre-sunset stack: MFN 0% + 301 List 4A 7.5% + 122 10% = 17.5% = 17,500 USD.
Post-sunset stack: MFN 0% + 301 List 4A 7.5% + forced-labor 12.5% = 20% = 20,000 USD.
Net change: +2,500 USD.
Chapter 6203 mens cotton trousers
Pre-sunset: MFN 16.6% + 122 10% = 26.6% = 26,600 USD.
Post-sunset: MFN 16.6% + forced-labor 12.5% = 29.1% = 29,100 USD.
Net change: +2,500 USD.
Chapter 8501 electric motors
Pre-sunset: MFN 2.4% + 301 List 3 25% + 122 10% = 37.4% = 37,400 USD.
Post-sunset: MFN 2.4% + 301 List 3 25% + forced-labor 12.5% = 39.9% = 39,900 USD.
Net change: +2,500 USD.
Chapter 7208 hot-rolled steel coil (Section 232 covered)
Pre-sunset: MFN 0% + 232 50% (no S122 stack on 232) = 50% = 50,000 USD.
Post-sunset: MFN 0% + 232 50% (forced-labor exempt on 232 lines) = 50% = 50,000 USD.
Net change: zero. Section 232 coverage insulated this from the July 24 rate transition.
Vietnam lane
Chapter 6203 mens cotton trousers
Pre-sunset: MFN 16.6% + 122 10% = 26.6% = 26,600 USD.
Post-sunset: MFN 16.6% + forced-labor 12.5% = 29.1% = 29,100 USD.
Net change: +2,500 USD.
Chapter 9401 seats
Pre-sunset: MFN 0% + 122 10% = 10% = 10,000 USD.
Post-sunset: MFN 0% + forced-labor 12.5% = 12.5% = 12,500 USD.
Net change: +2,500 USD.
Chapter 6404 footwear
Pre-sunset: MFN 20% + 122 10% = 30% = 30,000 USD.
Post-sunset: MFN 20% + forced-labor 12.5% = 32.5% = 32,500 USD.
Net change: +2,500 USD.
Chapter 8517 phones
Pre-sunset: MFN 0% + 122 10% = 10% = 10,000 USD.
Post-sunset: MFN 0% + forced-labor 12.5% = 12.5% = 12,500 USD.
Net change: +2,500 USD.
Pattern for Tier 2 Vietnam: uniform +2,500 USD per 100k CIF across all non-232 lines.
India lane
Chapter 8479 industrial machinery
Pre-sunset: MFN 0% + 122 10% = 10% = 10,000 USD.
Post-sunset: MFN 0% + forced-labor 12.5% = 12.5% = 12,500 USD.
Net change: +2,500 USD.
Chapter 2933 pharmaceutical intermediates (annex-exempt HS)
Pre-sunset: MFN 6.5% + 122 10% = 16.5% = 16,500 USD.
Post-sunset: MFN 6.5% + forced-labor 0% (annex exempt) = 6.5% = 6,500 USD.
Net change: -10,000 USD. The annex exemption on 2933 subheading eliminates the forced-labor layer AND the Section 122 gone. Big win.
Chapter 6109 knit T-shirts
Pre-sunset: MFN 16.5% + 122 10% = 26.5% = 26,500 USD.
Post-sunset: MFN 16.5% + forced-labor 12.5% = 29% = 29,000 USD.
Net change: +2,500 USD.
EU lane (Tier 1)
Chapter 8703 passenger cars (Section 232 covered)
Pre-sunset: MFN 2.5% + 232 25% (passenger vehicles) = 27.5% = 27,500 USD (no S122 stack).
Post-sunset: MFN 2.5% + 232 25% (forced-labor exempt on 232 lines) = 27.5% = 27,500 USD.
Net change: zero.
Chapter 2204 wine
Pre-sunset: MFN 22.4 cents per liter (specific) + 122 10% = varies (call it ~11,000 USD on 100k CIF).
Post-sunset: MFN 22.4 cents per liter (specific) + forced-labor 10% (Tier 1) = ~10,500 USD.
Net change: -500 USD. Wine loses the specific-duty base but keeps the Tier 1 10 percent layer.
Chapter 8425 lifting machinery (Germany-origin common)
Pre-sunset: MFN 0% + 122 10% = 10% = 10,000 USD.
Post-sunset: MFN 0% + forced-labor 10% (Tier 1) = 10% = 10,000 USD.
Net change: zero.
UK lane (Tier 1)
Chapter 8479 machinery
Pre-sunset: MFN 0% + 122 10% = 10% = 10,000 USD.
Post-sunset: MFN 0% + forced-labor 10% (Tier 1) = 10% = 10,000 USD.
Net change: zero.
Chapter 6203 cotton apparel
Pre-sunset: MFN 16.6% + 122 10% = 26.6% = 26,600 USD.
Post-sunset: MFN 16.6% + forced-labor 10% (Tier 1) = 26.6% = 26,600 USD.
Net change: zero.
The reshoring gap post-sunset
The China-to-India substitution math is the single biggest strategic move for most importers. Take chapter 8471 laptops as the reference.
China (Tier 2 + List 4A): 20 percent post-sunset stack (7.5 percent 301 + 12.5 percent forced-labor).
India (Tier 2, no 301 China lists): 12.5 percent post-sunset stack.
Mexico USMCA-qualifying: 0 percent post-sunset stack.
The China-India gap is still 7.5 percentage points (the 301 List 4A layer). Not as wide as under the Section 122 regime (17.5 vs 10 percent, gap 7.5), but the arbitrage held. The Mexico USMCA-qualifying option got even more compelling: it went from 10 percent pre-sunset to 0 percent post-sunset, widening its gap versus China from 7.5 to 20 percentage points.
Practical next steps
- Re-run the landed cost model for every SKU on every lane with the new rate structure. Line-by-line, not aggregate.
- Re-evaluate reshoring roadmaps with the wider USMCA advantage baked in. Mexico assembly of China-sourced components under substantial-transformation qualification is now materially cheaper.
- Update customer-facing landed-cost commitments if any are contract-linked to the pre-sunset rate structure.
- Verify Section 232 anti-stacking application across all lanes on 232-covered lines. Broker error at rate transition is highest on 232 line items.
- Track the 471-subheading annex for exemption expansions through 2026 and 2027. Additions to the annex on top-value HS lines create refund windows retroactive to July 24 2026.
Citations
- Section 301 forced-labor Federal Register notice July 24 2026: https://ustr.gov/about/policy-offices/press-office/press-releases/2026/july/ustr-final-action-section-301-forced-labor
- CBP CSMS 69326983 (entry filing instructions): https://content.govdelivery.com/accounts/USDHSCBP/bulletins/csms/69326983
- HTSUS 2026 latest revision: https://hts.usitc.gov/current
- USMCA-qualifying rules of origin overview: https://www.cbp.gov/trade/priority-issues/trade-agreements/free-trade-agreements/usmca
- Section 232 anti-stacking guidance: https://www.cbp.gov/trade/programs-administration/entry-summary/section-232
Frequently asked questions
Did the China reshoring math actually change on July 24?
Yes. Section 122 replaced 10 percent across every non-USMCA origin including all reshoring targets (Vietnam, India, Mexico, Malaysia). Its expiration removed that layer uniformly. Section 301 forced labor replaced it at 12.5 percent on 38 Tier 2 countries including China, India, and Vietnam. Net: Tier 2 origins saw a 2.5 percent bump. Tier 1 origins (17 countries) saw a 0.0 percent net change. USMCA-qualifying Mexico and Canada saw a full 10 percent removal (biggest winners).
Which lane became the biggest winner?
Mexico and Canada under USMCA-qualifying flows. The Section 122 10 percent layer is gone with no forced-labor replacement (they are exempt at the entry level). A 100k USD USMCA-qualifying shipment lost the entire 10,000 USD Section 122 layer with nothing replacing it.
Which lane got hit hardest?
Vietnam and Bangladesh apparel. MFN rates on chapter 61/62 apparel are already 15 to 32 percent. Adding 12.5 percent forced-labor (Tier 2) on top of that lands landed cost 2.5 percentage points higher than the pre-sunset stack (12.5 minus 10 percent Section 122). On a 100k CIF apparel shipment, that is 2,500 USD net worse.
What about the UK?
UK is Tier 1 (10 percent forced-labor rate, based on Modern Slavery Act 2015 forced-labor import provisions and the UK-US trade dialogue). Net change on UK-origin: near zero (Section 122 10 percent replaced by forced-labor 10 percent).
What about the EU?
EU as a bloc is Tier 1 (10 percent forced-labor rate, based on the EU Forced Labor Regulation adopted 2024). Same near-zero net change dynamic as the UK. However, individual EU member state supply chains that source components from a Tier 2 upstream country can face different total-stack exposure depending on substantial transformation.
Is the arbitrage from China to India still worth it?
Partially. Pre-sunset, a Section 301 List 3 exposed China line (say chapter 8471 laptops) paid 25 percent 301 plus 10 percent 122 plus MFN 0 percent = 35 percent stack. Same product from India paid 0 percent 301 plus 10 percent 122 plus MFN 0 percent = 10 percent stack. Post-sunset, China pays 25 percent 301 plus 12.5 percent forced-labor = 37.5 percent stack. India pays 12.5 percent forced-labor = 12.5 percent stack. India arbitrage gap widened from 25 percentage points to 25 percentage points net. So still very much worth it.
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