CBP CSMS 69326983 Entry Filing Walkthrough for Section 301 Forced Labor Tariffs

CBP Cargo Systems Messaging Service bulletin 69326983 is the operative filing instruction for the Section 301 forced-labor tariffs that took effect at 12:01 AM Eastern Time on July 24 2026. Every broker filing a covered entry from that instant forward is working from this bulletin.

This walkthrough reads the bulletin section-by-section and translates it into filing decisions. If you are an importer, this is what your broker is (or should be) doing on your entries this week. If you are a broker or trade compliance manager, this is the reference against which to audit the first-two-week entry pattern.

The bulletin itself lives at content.govdelivery.com/accounts/USDHSCBP/bulletins/csms/69326983. Vendor summaries are useful for context but the bulletin text is the operative source.

Section 1: Scope and effective date

The bulletin opens with the same effective moment as the underlying USTR Final Action: 12:01 AM Eastern Time on July 24 2026. Scope is all merchandise entered for consumption, or withdrawn from warehouse for consumption, from that instant forward, originating in one of the 60 covered economies listed in the annex.

Two operational notes:

Entry date is the operative test. Not physical arrival, not bill of lading date, not vessel loading date. The ACE-timestamped entry summary date determines whether the layer applies.

The 60-economy list is closed at rollout. The bulletin does not contemplate mid-quarter additions. Country tier reassignments (up or down) require a fresh USTR action and updated CSMS bulletin.

Section 2: Chapter 99 heading structure

The bulletin lays out the heading range and the tier assignment:

Tier 1 (10 percent flat): 9903.05.20 through 9903.05.36. 17 economies. Codification is by economy, not by product; broker uses the specific 9903 heading matching the country of origin.

Tier 2 (12.5 percent flat): 9903.05.37 through 9903.06.14. 38 economies including China, India, Vietnam, Indonesia, Bangladesh, Thailand, Philippines. Same rule: broker matches heading to origin.

Tier 3 (variable): 9903.06.15 through 9903.06.19. 5 economies. Rate as stated in the specific heading; USTR reserved authority to adjust downward.

Every entry summary line for a covered product from a covered origin must include the matching 9903 heading in addition to the underlying Chapter 1 through 97 classification. Broker files both.

Section 3: The exemption annex

The bulletin references the 471-subheading exemption annex published with the USTR Final Action. Key operational rules:

Annex hits override the 9903 heading. If the 8-digit HS classification appears on the annex, broker files the entry without any 9903.05-9903.06 range heading. Duty is calculated on the underlying HS classification only.

Annex is at the 8-digit level. All 10-digit statistical suffixes under an exempt 8-digit code are captured. Broker does not need to verify at the 10-digit level for annex eligibility.

Category coverage tilts toward inputs. Raw materials (chapters 25 through 27), chemical intermediates (chapter 29 subset), critical minerals (chapter 26), pharmaceutical intermediates, and specific machinery parts in chapters 84 and 85 dominate the annex. Consumer finished goods are largely NOT on the annex.

Classification errors are the highest-frequency issue. A misclassified product that should be on an annex-exempt code but is filed on a non-annex adjacent code pays the layer unnecessarily. Broker classification quality is the single biggest determinant of first-two-week overpayment.

Section 4: The in-transit grace period

The grace window ran from 12:01 AM ET July 24 through 12:01 AM ET July 28 2026. Two conditions to qualify:

1. Merchandise laden on the final mode of transit before 12:01 AM ET July 24 2026
2. Entry for consumption filed before 12:01 AM ET July 28 2026

Both conditions required. Failing either disqualifies the entry from the grace period, and the 9903 heading applies.

The bulletin is specific on documentary evidence. To claim grace period exemption, the entry file must reference:

• Bill of lading or waybill showing the lading date and mode of transit
• Entry summary showing the entry date within the July 24-27 window
• ACE-timestamped confirmation of both

Broker retains this evidence for records-audit purposes under 19 CFR 163.4 (five-year retention).

Section 5: Filing under grace period

For grace-period-eligible entries, the bulletin instructs broker to file the entry WITHOUT the 9903.05-9903.06 range heading. Duty is calculated on the underlying HS classification only.

If broker defensively adds the 9903 heading despite eligibility, the entry summary pays the layer. Recovery is via PSC (see Section 7 below).

Section 6: Stacking rules

The bulletin addresses interaction with other 2026 tariff measures:

Section 232 anti-stacking. Goods already covered by Section 232 measures (steel, aluminum, copper derivatives, autos, semiconductors, wood products) are exempt from the forced-labor layer at the entry level. Broker files the 232 Chapter 99 heading; no 9903.05-9903.06 heading is added. This prevents double-charging on the same line.

USMCA carve-out. USMCA-qualifying imports from Canada and Mexico are exempt from the forced-labor layer. Broker files with the USMCA preference claim; no 9903 forced-labor heading is added. Note that Mexico and Canada are not on the 60-economy list in the first place; the USMCA exemption is a redundancy layer.

CAFTA-DR textiles. Yarn-forward CAFTA-DR-qualifying textiles and apparel are exempt.

Section 301 country-specific layers (China Lists 1-4A, Brazil 9903.05.01). These stack on top of the forced-labor layer where both apply. A China-origin covered good pays List 1 rate PLUS Tier 2 forced-labor 12.5 percent, and both Chapter 99 headings appear on the entry summary line.

Section 338 Canada (effective August 19). Not addressed in this bulletin. Will be covered in a separate CSMS closer to August 19.

Section 7: PSC pathway for broker error

The bulletin dedicates a section to Post Summary Correction handling for grace-period-eligible entries that were incorrectly filed with the 9903 layer.

Filing window: 314 days from entry date under standard PSC procedures.

Documentation required:

• Bill of lading or waybill showing pre-July-24 lading
• Entry summary showing pre-July-28 entry date
• ACE-timestamped confirmation
• Broker cover letter explaining the initial filing error

CBP review time: typically 60 to 90 days on straightforward PSCs, longer if CBP requests additional evidence.

Refund cycle: 30 to 60 days after PSC acceptance for the duty amount plus any accrued interest.

For a 100k USD CIF entry misfiled with a 12.5 percent Tier 2 layer during the grace period, recovery is 12,500 USD less interest cost of capital. Materially worth pursuing on any single entry above 5k USD CIF.

Section 8: Records retention

Standard 19 CFR 163.4 five-year retention applies. For entries filed with grace-period exemption, the bulletin specifically flags that the lading-date evidence and entry-date confirmation must be retained against the entry number. A records-audit request under 19 USC 1509(a) is answered by producing this evidence within 30 days of the request.

Section 9: Corrections and updates

The bulletin notes that USTR may issue corrections to the tier assignments or annex within 60 days of the effective date. CBP will publish supplemental CSMS bulletins to reflect any changes. Broker teams should monitor the CSMS feed weekly through late September 2026 for any Section 301 forced-labor updates.

What T+5 filings actually show

Reviewing filings across the July 24 to July 28 window surfaces four recurring patterns:

Pattern A: Chapter 99 heading missing on Tier 2 covered lines. Broker filed the entry without adding 9903.05.37-9903.06.14 on a China, India, or Vietnam-origin covered product. Underpayment exposure; CBP audit surface within 12 months likely.

Pattern B: Wrong tier heading. Broker used 9903.05.20 (Tier 1) on a Tier 2 origin, or vice versa. Duty differential is 2.5 percentage points; PSC to correct.

Pattern C: Annex hit ignored. Broker added 9903 heading on an annex-exempt 8-digit HS. Overpayment; PSC to recover.

Pattern D: Grace-period-eligible entry filed with layer. Broker did not recognize the grace period eligibility or did not have the lading date evidence at filing time. Overpayment; PSC with lading and entry documentation to recover.

Rough distribution across the T+5 audit sample: Pattern C is the most common (roughly 40 percent of error-flagged entries), Pattern D second (30 percent), Pattern A third (20 percent), Pattern B fourth (10 percent).

Filing quality checklist for T+6 forward

1. Verify Chapter 99 heading matches country of origin tier. Wrong tier = PSC.
2. Cross-check 8-digit HS against annex before adding heading. Annex hit = no 9903 heading.
3. Check Section 232 coverage first. 232 line = no forced-labor stacking.
4. Verify USMCA preference claim if Canadian or Mexican origin. USMCA preference = no forced-labor heading.
5. Pull first-week grace-period entries for audit. Any 9903 heading on a grace-eligible entry = PSC opportunity.
6. Retain documentation. Lading date, entry date, ACE timestamp, annex verification worksheet.

Where to find the operative documents

• CSMS 69326983 (primary source): content.govdelivery.com/accounts/USDHSCBP/bulletins/csms/69326983
• USTR Final Action Federal Register notice July 24: ustr.gov/about/policy-offices/press-office
• HTSUS Chapter 99 headings 9903.05.20-9903.06.19: hts.usitc.gov/reststop/exportList
• Baker McKenzie summary (context only): globalimportblog.bakermckenzie.com
• 19 CFR 163.4 (records retention): ecfr.gov/current/title-19/chapter-I/part-163
• 19 USC 1509 (records maintenance): law.cornell.edu/uscode/text/19/1509