Section 301 Forced-Labor Chapter 99 Heading Map for 60 Countries: HTS 9903.05.37 through 9903.06.14 Assignments, Tier A vs Tier B Rate Structure, and Broker Filing Reference for Post-Jul 24 2026 Entries

The Section 301 forced-labor tariff took effect at 12:01 AM EDT July 24 2026, replacing Section 122 with a country-specific tier structure covering 60 countries. Rates are 10 percent (Tier A) or 12.5 percent (Tier B) on covered chapters. Annex A provides carve-outs by country and chapter. Chapter 99 heading assignments run from 9903.05.37 through 9903.06.14 in the HTSUS.

For brokers filing entry summaries on covered origins post-Jul 24, the practical filing task is (a) verify country tier assignment against USTR list, (b) check Annex A for exemption at the specific HS chapter, (c) assign the correct Chapter 99 heading on CBP Form 7501 line 30, and (d) calculate the stacked duty correctly when the merchandise is also subject to Section 232, existing Section 301 lists, or other Chapter 99 headings.

Chapter 99 Heading Range Structure

HTS 9903.05.37 through 9903.05.97: Tier A country assignments (10 percent additional duty). Each Tier A country typically has one primary heading with sub-headings for Annex A carve-outs.

HTS 9903.06.00 through 9903.06.14: Tier B country assignments (12.5 percent additional duty). Each Tier B country typically has one primary heading with sub-headings for Annex A carve-outs.

The specific country-to-heading mapping is published in CBP CSMS 69327891 and cross-referenced in the HTSUS Chapter 99 revisions dated July 24 2026. Brokers should not memorize the mapping; rely on the CSMS lookup and the ACE Entry Summary automated heading-suggestion function.

Tier A Country List

Approximately 44 countries at Tier A with 10 percent additional duty:

Bangladesh, Bolivia, Brazil, Cambodia, Colombia, Democratic Republic of Congo, Dominican Republic, Ecuador, Egypt, Ethiopia, Ghana, Guatemala, Haiti, Honduras, India, Indonesia, Kenya, Laos, Madagascar, Malaysia, Mexico (excluding USMCA-preferential entries), Morocco, Mozambique, Myanmar, Nepal, Nicaragua, Nigeria, Pakistan, Peru, Philippines, Rwanda, Senegal, Sri Lanka, Sudan, Tanzania, Thailand, Tunisia, Uganda, Uzbekistan, Venezuela, Vietnam, Yemen, Zambia, Zimbabwe.

Notable at Tier A:

• Mexico entries lose the S301 forced-labor add-on when USMCA-preferential origin is claimed and documented. Non-USMCA Mexican entries carry the 10 percent add-on.
• India is the highest-volume Tier A country by US import share. Textile, apparel, and pharma Annex A patterns are heavily India-specific.
• Brazil is separately subject to a 25 percent Section 301 tariff imposed following the yearlong digital-trade/environmental investigation, stacked on top of the 10 percent forced-labor add-on.

Tier B Country List

Approximately 16 countries at Tier B with 12.5 percent additional duty:

Afghanistan, Belarus, Central African Republic, China, Cuba, Eritrea, Iran, Libya, Mali, Nicaragua (specific categories), North Korea, South Sudan, Syria, Turkmenistan, Venezuela (specific categories), Zimbabwe (specific categories).

Notable at Tier B:

• China is at Tier B for the forced-labor tariff, stacked on top of existing Section 301 List 1 through List 4A rates. A List 3 Chinese good faces 25 percent (List 3) plus 12.5 percent (forced-labor) equals 37.5 percent Section 301 stack.
• Cuba and North Korea entries are largely blocked by existing sanctions; the tariff is nominal.
• Iran, Syria, Libya are similarly sanction-blocked for most trade categories.

Annex A Carve-Outs

Annex A exempts specific HS chapters or subheadings by country. The exemption zeros out the Section 301 forced-labor add-on for the exempt category, leaving only the base MFN duty.

Most common carve-outs by chapter:

Chapter 30 (pharmaceuticals): Broad carve-out across most Tier A and Tier B countries for finished pharmaceuticals, generics, biosimilars, and biologics. Reflects US supply-chain dependency on specific finished-dose manufacturing origins.

Chapter 90 (medical and optical instruments): Specific subheadings for medical devices, diagnostic equipment, prosthetics, and optical inputs. Approximately 40 percent of Chapter 90 subheadings carve out for at least some Tier A countries.

Chapter 84 and 85 (mechanical and electrical inputs): Selected subheadings supporting US-manufacturing inputs. Semiconductors, specific machinery components, and electrical control systems from Tier A countries frequently carve out.

Chapter 10, 11, 12 (grains, milling products, oil seeds): Humanitarian and agricultural-input carve-outs for Tier A countries.

Chapter 15 (animal and vegetable oils): Humanitarian carve-outs for palm oil, coconut oil, and specific edible oils from Tier A countries.

Chapters with NO or very few carve-outs across most covered countries:

Chapter 50 through 63 (textiles): Very few carve-outs. Textile is the primary category driving forced-labor concerns.

Chapter 61 and 62 (apparel): No carve-outs. All apparel from all 60 covered countries carries the full tier add-on.

Chapter 64 (footwear): No carve-outs. All footwear from all 60 covered countries carries the full tier add-on.

Chapter 42 (leather goods): Very few carve-outs.

Chapter 71 (jewelry, precious metals): Few carve-outs, primarily for humanitarian gold imports.

The Chinese-Origin Stack

For Chinese-origin merchandise, the Section 301 stack post-Jul 24 layers multiple Chapter 99 headings:

Base: MFN rate per HTS heading (Chapter 29 chemicals, Chapter 84 machinery, Chapter 85 electronics, etc).

Section 301 List 1: 9903.88.01 at 25 percent. Applies to Chinese-origin goods in specific 4-digit HS ranges (industrial machinery, chemicals, some vehicles).

Section 301 List 2: 9903.88.02 at 25 percent. Applies to specific 4-digit HS ranges (semiconductors, electric motors, specific chemicals).

Section 301 List 3: 9903.88.03 at 25 percent. Broadest coverage, thousands of HS lines including textiles, apparel-inputs, specific consumer goods.

Section 301 List 4A: 9903.88.15 at 7.5 percent. Consumer electronics, footwear, apparel, food processing equipment. (List 4B was suspended and never went into effect.)

Section 301 forced-labor (post-Jul 24): 9903.06.xx at 12.5 percent for Chinese-origin.

A Chinese-origin apparel item classifiable under HTS 6109.10 (cotton knit t-shirts) faces: 16.5 percent MFN (Chapter 61) + 25 percent List 3 + 12.5 percent forced-labor = 54 percent total ad valorem on CIF.

Compare to Vietnamese-origin same HTS 6109.10: 16.5 percent MFN + 10 percent forced-labor (Tier A) = 26.5 percent total ad valorem.

Origin arbitrage between China and Tier A alternatives is worth 27.5 percentage points at the apparel category. Substantial transformation analysis under 19 CFR 102.21 determines whether third-country assembly qualifies for the third-country origin or triggers 19 CFR 134 substantial-transformation review.

Broker Filing Sequence

For each post-Jul 24 entry:

1. Declare country of origin on CBP Form 7501 line 10 based on 19 CFR 134 substantial transformation analysis (not simply the shipping origin).
2. Look up the tier assignment (Tier A or Tier B) from the USTR country list.
3. Check Annex A for the specific HS chapter and country combination. If exempt, no forced-labor Chapter 99 heading is applied.
4. If not exempt, assign the specific 9903.05.xx or 9903.06.xx heading per CSMS 69327891 lookup.
5. File the Chapter 99 heading on Form 7501 line 30 as a separate line item from any other Chapter 99 assignments (Section 232, existing 301 lists).
6. Calculate the stacked duty: MFN base plus each Chapter 99 heading additive, applied to CIF.
7. Assess MPF (0.3464 percent capped at 634.62) and HMF (0.125 percent, no cap) as normal.
8. File entry summary within 10 business days of release.

Line-Item Transparency Under 19 CFR 141.61

CBP Form 7501 line 30 requires itemized Chapter 99 heading disclosure. Brokers using blended-duty math (single combined rate applied without Chapter 99 breakdown) violate 19 CFR 141.61 line-item requirements.

The itemization matters operationally for:

• PSC preservation: If any single Chapter 99 heading is later determined to be misassigned, CAPE Phase 2 PSC can correct just that heading without disturbing the others.
• Reconciliation: Post-entry reconciliation entries can reference specific Chapter 99 line items for USMCA claims, first-sale valuation, or origin corrections.
• Drawback: 19 USC 1313(j) drawback claims require Chapter 99 heading-level provenance for the underlying entry.
• 19 USC 1592 IOR liability: The importer of record is liable for each declared line item. Blended-duty declarations do not shield the IOR from per-heading enforcement.

Importers should request itemized ACE Entry Summary printouts or ABI extracts from their brokers to verify Chapter 99 line-item transparency on every entry.

PSC Correction Pathway

Tier-misassignment corrections file through CAPE Phase 2 under 19 CFR 141.111 within 314 days of entry summary. The correction package includes:

• Amended CBP Form 7501 with corrected Chapter 99 heading.
• Documentation of the correct tier assignment (USTR country list, CBP CSMS 69327891).
• Annex A carve-out citation if applicable.
• Substantial transformation analysis under 19 CFR 134 if country of origin is at issue.
• Recalculated duty at the corrected rate.

Refund lands to IOR ACH account within 30 to 60 days of CBP acceptance pre-Aug 19 baseline. Post-Aug 19 forecast is 60 to 120 days due to Section 338 volume stacking.

Practical Cost-of-Compliance

For importers running consistent Tier A country volumes:

• India, Vietnam, Bangladesh, Cambodia apparel and textile importers: Full 10 percent add-on with no meaningful Annex A relief. Landed cost impact is 10 percentage points on CIF.
• India, China pharma importers: Chapter 30 carve-outs provide broad relief. Landed cost impact is minimal for covered subheadings.
• Mexico non-USMCA importers: 10 percent add-on unless USMCA-preferential origin is documented. Origin documentation cost is now higher than pre-Jul 24.
• Brazil importers: 10 percent forced-labor plus 25 percent Section 301 Brazil-specific equals 35 percent total add-on. Landed cost impact is severe.

For US importers running diverse origins, the practical cost-of-compliance move is category-by-category origin diversification analysis. The Chapter 99 heading map is the entry point.

What Not to Do

Do not assume the pre-Jul 24 Section 122 exposure math still applies. Section 122 was a flat 10 percent on all countries. Section 301 forced-labor is country-specific with Annex A carve-outs and stacks differently.

Do not skip Annex A verification. Assuming full tier rate when a carve-out exists overstates landed cost and creates working capital drag through unnecessary duty prepayment.

Do not use blended-duty math on Form 7501. Line-item transparency under 19 CFR 141.61 is a compliance requirement, not a preference.

Do not delay PSC filing on suspected tier misassignments. The 314-day window from entry summary is the outer limit, not the target.

The Chapter 99 heading map is the operational reference for post-Jul 24 broker filings. The forced-labor tariff is here, the CBP CSMS is published, the tier assignments are stable. What remains is careful per-entry classification work.