The Section 301 exclusions have been extended to January 9, 2027. The USTR notice, published November 6, 2026 at 91 FR 72610, covers all 178 exclusions: 164 under HTS 9903.88.69 and 14 solar exclusions under 9903.88.70. The snapback rates are 25 percent for Lists 1 through 3 and 7.5 percent for List 4A. What matters for importers is the entry date, because the exclusion has to be in force on the day the goods enter.
What the extension covers
The USTR notice, published November 6, 2026 at 91 FR 72610, extends all 178 Section 301 exclusions to January 9, 2027. The set is 164 exclusions under HTS 9903.88.69 and 14 solar exclusions under 9903.88.70. The extension is a clean one: every exclusion that was in force continues, at the same terms, to the same date. Nothing was added, nothing was dropped, and nothing was changed.
That completeness matters. Earlier extensions covered subsets, and importers had to check whether their specific exclusion was in the list. This one covers the full set, which means the check is simpler: if the exclusion applied before the notice, it applies until January 9, 2027. The work now is to confirm the exclusion is still in the set, and to plan for what happens on January 10.
The snapback, and what it costs
When an exclusion expires, the Section 301 duty comes back at the snapback rate: 25 percent for Lists 1 through 3, and 7.5 percent for List 4A. On a $100,000 entry, that is $25,000 in duty that was not there the day before, or $7,500 for a List 4A product. The snapback is not a gradual phase-in. It is a cliff, and the cliff is January 10, 2027.
The cost is why the entry date matters so much. The exclusion has to be in force on the day the goods enter, not the day they ship, and not the day the order was placed. Goods that are on the water on January 9 and enter on January 10 pay the snapback rate. Goods that enter on January 9 do not. The difference is a day, and the duty is the full snapback amount.
What to check before January 9
The first check is whether your product is actually covered by an exclusion. The exclusion is tied to a specific HTS code and a specific description, and a product that is close to the description but not in it does not qualify. Pull the exclusion list, find your code, and read the description. If the description does not match your product, the exclusion never applied, and the extension does not help you.
The second check is the entry date on every shipment in the pipeline. Anything scheduled to enter after January 9 needs a plan: enter early, pay the snapback, or hold the goods in a bonded warehouse or FTZ until the picture is clearer. The third check is the cash flow, because the snapback on a quarter of imports is a real number, and it hits in the same month as the post-holiday inventory build.
What happens after January 9
The honest answer is that nobody knows yet. The USTR has extended these exclusions before, and it may extend them again. It may also let them lapse, or replace them with a new process. The pattern so far has been short extensions, a few months at a time, with the notice arriving close to the expiry date.
The practical approach is to plan as if the exclusions lapse, and treat an extension as good news. Accelerate entries that can enter before January 9. Price the snapback into any order that will enter after. And watch the Federal Register in December, because the notice, if it comes, will come late, and the importers who are watching will have time to act. The ones who are not will learn about it from the duty bill.
Keep reading
Related guides on this site: Chapter 99 and where the tariff action lives in the 9903 lines GRI and the six rules that decide every classification fight Section 232 exclusion requests and how the steel and aluminum process works More from Tariff rules tracked down to the SKU.
Frequently asked questions
When do the Section 301 exclusions expire?
January 9, 2027. The USTR notice published November 6, 2026 extends all 178 exclusions to that date, after which the snapback rates apply unless there is another extension.
How many exclusions are covered?
164 exclusions under HTS 9903.88.69 and 14 solar exclusions under 9903.88.70, for a total of 178. The notice covers the full set, not a subset.
What are the snapback rates?
25 percent for Lists 1 through 3, and 7.5 percent for List 4A. The snapback rate is the Section 301 duty that applies once the exclusion expires.
What date governs whether an exclusion applies?
The entry date. The exclusion has to be in force on the day the goods enter, not the day they ship or the day the order was placed. Goods that enter after the exclusion expires pay the snapback rate.