What to know about each:
- China. The Section 301 duties on Chinese goods continue, with exclusion updates as recent as September 22, 2026.
Forced labor. These duties took effect July 24, 2026; goods already subject to Section 232 are exempt.
ACE blocked drawback on them from August 12 to 18, 2026, until CBP corrected it.
- Brazil. A 25% duty imposed by a July 15, 2026 memorandum, on goods entered from July 22, 2026.
You can recover Section 301 duty through unused merchandise drawback, by direct identification or by substitution within the same 8-digit HTS subheading, and through manufacturing drawback with a ruling.
One part isn't settled. A substitution claim is capped at the lesser of the import duty and the duty the exported article would bear if imported.
When a Chapter 99 duty depends on the country of origin, as these do, how CBP applies that cap isn't settled.
Your broker decides line by line.
- CBP CSMS #69567203, Aug 18, 2026[1]
- CBP CSMS #69535943, Aug 2026[2]
- CBP CSMS #69302472, Jul 21, 2026[3]
- CBP CSMS #69990649, Sept 22, 2026[4]
- 19 U.S.C. 1313(b), (j)(2)[5]
- Are Section 301 duties eligible for drawback?
- Can you recover Section 301 tariffs through duty drawback?
- Can I recover Section 301 tariffs through unused merchandise drawback?
Written by the Duty Recovery AI team from the primary sources linked on this page.
Not legal advice. Duty Recovery AI is not a government agency.
Duty Recovery AI is software used by licensed customs brokers.

