Section 301 China Conforming Amendment – Updated CBP Guidance

On October 22, 2026, U.S. Customs and Border Protection (CBP) issued Cargo Systems Messaging Service (CSMS) # 70261629, which updates guidance previously provided in CSMS# 69990649 regarding an additional conforming amendment affecting five Section 301 China product exclusions. The update aligns the exclusions with Harmonized Tariff Schedule of the United States (HTSUS) statistical reporting number changes that became effective July 1, 2026. ACE programming to accept these changes became available on October 23, 2026, at 6:00 p.m. ET.

Key Takeaways

• The Office of the U.S. Trade Representative (USTR) issued conforming amendments through Federal Register notices 91 FR 56538 (September 2, 2026) and 91 FR 64211 (October 7,2026).
• The amendments do not create new exclusions. Rather, they update existing exclusions to reflect revised HTS statistical reporting numbers that became effective on July 1, 2026.
• The changes impact exclusions under HTSUS 9903.88.69, including certain pump parts and plastic articles that were previously classified under statistical reporting numbers that have since been replaced.
• The affected statistical reporting numbers include:
  • 8413.91.9065
  • 8413.91.9085
  • 9413.91.9096
  • 3926.90.9910
  • 8479.90.9596

Importers should review the specific technical amendments and product descriptions to determine whether their merchandise qualifies for the updated exclusions.

Importers and customs brokers should ensure that entries claiming these Section 301 exclusions utilize the updated statistical reporting numbers in ACE.

Importers should review entries filed on or after July 1, 2026, that may qualify for these exclusions. If Section 301 duties were paid on qualifying entries due to the reporting number changes, importers may be eligible to pursue corrections or refunds through the appropriate CBP post-entry processes.

Please contact your C.H. Robinson representative with any questions.

Resources

CSMS # 70261629 - UPDATED GUIDANCE: Section 301 China Conforming Amendment

Federal Register: Notice of Conforming Amendments to Product Exclusions: China's Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation

Federal Register: Notice of Conforming Amendment to Product Exclusion: China's Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation