The 10% customs duty under Section 122 of the Trade Act 1974 expired on July 24, 2026. 

Measures under Section 301 of the Trade Act 1974

Background

On March 12, 2026, the Office of the U.S. Trade Representative (USTR) initiated an investigation into forced labor in supply chains, under Section 301 of the Trade Act of 1974.

The purpose of the investigation was to determine whether the failure of certain trading partners of the United States to prohibit, or effectively implement, such a prohibition constituted an unfair trade practice that could harm the United States economy. The United States has prohibited the importation of goods wholly or partly produced with forced labor since 1930 under Section 307 of the Tariff Act.

On 1 June 2026, the USTR issued its findings and found two categories of non-compliance:

1. 54 economies have not introduced a legal ban on the import of goods from forced labor (nor ensured its effective implementation),
2. Six economies have a ban but do not effectively enforce it: Canada, Ecuador, the European Union, Indonesia, Mexico and Pakistan.

In the case of the EU, the USTR does not criticize the absence of a ban on the import of products from forced labor (see Regulation (EU) 2024/301 ). On the other hand, the USTR considers that the EU does not apply this ban effectively, for two reasons:

1. the Regulation only comes into force on 14 December 2027 and until it is applicable, it cannot, according to the USTR, be implemented ‘effectively’,
2. the european framework does not include some of the elements deemed decisive for effective enforcement, such as a public list of entities and a rebuttable presumption (once the use of forced labor is established for a given product, the burden of proof is reversed: it is then up to the importer to demonstrate that his goods are free of it, and not the administration to prove the opposite).

On 2 June 2026, the US administration proposed to impose additional duties of up to 10% on imports originating in the EU, under Section 301.

Implementation of a Flexible Additional Charge

Following public consultations and hearings organized by the USTR in early July 2026, the US administration decided to introduce a new additional duty under Section 301 of the Trade Act. This right has been in effect since July 24, 2026 at 12:01 a.m. (Washington time).

General

For the European Union, this duty takes the form of a maximum rate of 10%, modulated according to the MFN duty already applicable to the goods concerned.

If the applicable MFN duty is less than 10 %, the Section 301 duty added shall be the rate necessary to reach a total of 10 %.

If the applicable MFN duty is equal to or higher than 10 %, then no rate under Section 301 shall be applied. 

For example, a product subject to a MFN duty of 4 % is charged a rate of 6 % under Section 301, so as to reach a total of 10 %. If a product is initially subject to a MFN rate of 15%, then no Section 301 duty applies. 

Exemptions

There are several exemptions for products whose Section 301 taxation could « jeopardize U.S. supply », cause economic disruption, or cannot be produced in sufficient quantities in the United States.

The list of exemptions is available in the annex to the USTR memorandum of 23 July 2026.

Products subject to duties under Section 232 (see below) such as pharmaceuticals, steel, aluminum or copper products, and their derivatives are exempt from these duties under Section 301. Only the MFN rate already in force applies.

De minimis threshold

As of August 29, 2025, the de minimis exemption (which allows for the duty-free importation into the United States of packages valued at less than $800) has been eliminated for all U.S. trading partners. 

Shipments that do not pass through the international postal network

For these shipments (express freight, private carriers, etc.), all packages, regardless of their value, country of origin or mode of transport, must be subject to a full customs declaration in the ACE (Automated Commercial Environment) system and are subject to all applicable customs duties, taxes, fees and levies.

Shipments that pass through the international postal network

On June 24, 2026, the U.S. customs authorities issued a final interim regulation that enshrines in U.S. customs regulations the suspension of the de minimis exemption (which allows the duty-free importation into the United States of packages valued at less than $800) for an indefinite period.

This Interim Regulation establishes a new informal entry procedure for postal items with a value of USD 2 500 or less and replaces, as of 24 July 2026, the interim process established pursuant to Executive Order 14324 of 30 July 2025.

Scope of the new procedure

The new informal postal entry procedure applies until October 22, 2026 to shipments of goods valued at $2,500 or less, delivered by post and exclusively classifiable under Chapters 1 to 97 of the U.S. Customs Tariff (HTSUS).

As of 22 October 2026, the following goods will be excluded from the informal postal procedure:

• goods subject to the requirements of another federal agency;
• goods subject to duties under Chapter 98 or 99 of the HTSUS (Section 232, 301 duties, etc.);
• goods for which relief is claimed under Chapter 98 or a free trade agreement.

From 22 October 2026, these goods will have to be the subject of a formal entry or the new voluntary electronic entry type « Entry Type 13 » (opening of the test phase on 22 September 2026).

Shipments valued at more than $2,500, in-quota goods and goods subject to anti-dumping or countervailing duties continue to be subject to formal entry.

Persons entitled to deposit entry

Since July 24, 2026, the filing of the informal declaration is the responsibility of the owner or buyer of the goods shipped to the United States, or the authorized customs representative (licensed customs broker) duly designated by the owner, buyer or recipient.

The US customs authorities require shippers to provide a monthly spreadsheet (International Mail Duty Worksheet - IMDW) containing the tariff classification of goods, this constitutes a customs business reserved by law for authorized customs representatives. Unauthorized qualified third parties, about half of the current depositors – are therefore excluded from the scheme: foreign postal operators (FPO) and importers who used these third parties will have to contract with a customs representative. The filer code, a new mandatory data item, will allow CBP to verify the applicant's approval.

All information on the information requirements under this new entry procedure can be found on the "Customs formalities on importation into the United States" page.

Measures imposed under Section 232 of the Trade Expansion Act 1962

This legal basis serves as a basis for the application of the following additional rights:

• steel, aluminum and derived products thereof and semi-finished products of copper and derived products with a high copper content,
• heavy goods vehicles, medium-sized vehicles and their spare parts, buses, under 25 years of age,
• motor vehicles and motor vehicle spare parts,
• timber, timber and certain timber products,
• patented medicines and active pharmaceutical ingredients.

Additional duties on steel, aluminum, and products thereof, copper

On 10 February 2025, the United States decided to impose additional customs duties on its imports of steel and aluminum originating in the European Union and to apply those duties to a series of derived products containing steel and aluminum.

By announcement of June 3, 2025, the US administration increased these duties from 25% to 50% for all US trading partners except the UK, effective June 4, 2025.

On April 2, 2026, the U.S. administration amended the terms of these additional duties: the same terms apply to steel, aluminum, and copper.

The proclamation of April 2:

• changes the tax base: the additional customs duty now applies to the total value for duty of products imported into the United States rather than to the value for duty of metal inputs,
• reduce the rate of additional customs duties applicable to certain products with a moderate metal content,
• adds new products to the scope of this regulation,
• abolishes this additional duty for products with a low metal content.

This proclamation is structured in 5 annexes, with different rates:

1. Annex I-A (rate of 50 % of the total customs value): products of Chapters 72 to 74 and 76, structural steel, steel containers, wire, cables, etc.
2. Annex I-B (rate of 25 % on the total customs value): household articles, cutlery, door fittings, etc.
3. Annex II (products removed from the scope of additional duties): certain consumer goods, chemicals, engines, etc.
4. Annex III (temporary additional rate of 15% until 2027, see below): industrial equipment with a high metal intensity and electrical network equipment. After 2027, Annex III products will increase to the applicable 25 % rate under Annex I-B.
5. Annex IV (weight exemption, see below): for products not covered by Chapters 72, 73, 74 and 76, the additional duties in Annexes I-B and III shall apply only where the weight of the metal concerned represents at least 15 % of the total weight of the imported article.

These changes apply from 00:01 (Washington time) on 6 April 2026 (no exemption provided for goods already in transit).

There is now only one HTSUS code (9903.82.02) to be filled in for the application of additional duties on products wholly composed or derived from steel and/or aluminum and/or copper. The additional steel/aluminum/copper duties do not therefore cumulate with each other. For example, a tool made of steel, aluminum and plastic will be taxed at the MFN rate applicable to the U.S. Commodity Nomenclature Code + 50% for steel/aluminum/copper.

However, these additional duties are in addition to the MFN rate applicable to the goods concerned. Example: a knife of 8211.93.0035 (Annex I-B) is taxed at the rate of 25 % under Section 232 + at the MFN rate of 5,4 % and 3 cents per piece applicable to the product 

Taxation arrangements

Products wholly or almost wholly composed (Annex I-A)

Articles composed entirely or almost entirely of aluminum (Chapter 76 of the HTSUS), steel (Chapter 72 of the HTSUS and certain articles classified in Chapter 73 of the HTSUS) or copper (Chapter 74 of the HTSUS) are subject to a customs duty of 50 % on their total customs value.

Example: Iron or non-alloy steel angles, profiles and sections (HTSUS 7301.20.10) are taxed at the MFN rate applicable to the good (0%) + 50% under Section 232 duties.

Derivatives (Annex I-B)

Articles derived from steel and aluminum and certain copper articles which are not composed almost exclusively of aluminum, steel or copper shall be subject to a customs duty of 25 % on their total customs value.

Example: Wind turbine hubs (HTSUS code 8412.90.9075) are taxed at 0% for MFN + 25% for additional duties on steel/aluminum/copper.

Reduction in the rate of additional duties and use of US metallic raw materials

Items listed in Annex I-A and Annex I-B made from US steel, aluminum and copper, are subject to a 10 % customs duty instead of the additional duties of 50 % or 25 % listed above (these products were previously exempt from the additional duties provided for in Article 232).

This 10% rate applies to goods: 

• the aluminum content of the aluminum-derived article is composed of aluminum which has been melted and cast in the United States,
• the steel content of the steel-derived article is made of steel that has been melted and cast in the United States,
• the copper content of the copper article is composed of copper that has been melted and cast in the United States.

Example: Iron or non-alloy steel angles, profiles and sections made from cast and cast steel in the United States (HTSUS 7301.20.10) are taxed at the MFN rate applicable to the good (0%) + 10% under the applicable Section 232 duties for the content of cast and cast steel in the United States.

Products originating in the United Kingdom

The additional duty rate applicable in the United Kingdom remains at 25 % ad valorem on the products concerned. However, the proclamation of 2 April 2026 introduces new rules of origin to benefit from this tariff preference: 

• the aluminum must have been last melted or cast in the United Kingdom,
• the steel must have been melted and cast in the United Kingdom.

British steel and aluminum products that would otherwise have been subject to the 50% tariff (Annex I-A list) are now subject to a 25% tariff (HTSUS code 9903.82.04). British steel and aluminum products that would otherwise have been subject to the 25% tariff (Annex I-B list) are now subject to a 15% tariff (HTSUS code 9903.82.05).

Aluminum from Russia

All imports of aluminum articles and aluminum derivatives listed in Annex I-A and Annex I-B (and Annex III) originating in Russia, or for which any part of the primary aluminum used in the manufacture of those articles has been melted or cast in Russia, shall remain subject to the 200 % customs duty established by Proclamation No 10522 of 24 February 2023 (HTSUS codes 9903.85.67 or 9903.85.68 ).

Temporary reduction of customs duties for certain products (Annex III)

Certain industrial equipment of steel and aluminum, as well as certain equipment intended for electrical networks (listed in Annex III), are subject to a temporarily reduced additional customs duty rate. This rate is the higher of the additional 15% customs duty rate under Section 232 or the MFN rate applicable to the good. Example: An injection molding machine for footwear (HTSUS code 8477.10.30) is taxed at 0% for MFN + 15% for steel/aluminum/copper section 232 duties.

If the above goods are manufactured from steel, aluminum or copper melted and cast in the United States, then the temporarily reduced additional duty rate shall be the higher of 10 % under Section 232 or the MFN rate in force for the goods (products listed in Annex III to the Proclamation). Example: An injection molding machine for footwear (HTSUS code 8477.10.30) manufactured from cast steel/aluminum/copper in the United States is taxed at 0% MFN + 10% MFN steel/aluminum/copper duties in Section 232 (the higher rate between the MFN rate and the section 232 rate applicable to the product).

This reduction ends on ¹ January 2028. These goods will then be subject to the 25 per cent customs duty set out in the Schedule to Annex I-B (or the 10 per cent customs duty for products using U.S. inputs), in addition to the MFN rate.

Removal of additional duties of 50 % for certain products (Annex II)

Certain products derived from steel and aluminum are now excluded from the scope of these sectoral additional duties.

Exemptions (Annex IV)

Exemptions may be requested in several cases, as detailed in Annex IV:

• Weight exemption (recital 9 of the proclamation of 2 April 2026): An exemption applies to certain derived products for which the total weight of steel, aluminum and copper inputs is less than 15 % of the total weight of the imported product. Any product which cannot be classified in Chapters 72, 73, 74 and 76 of the HTSUS may benefit from this de minimis exception (HTSUS code 9903.82.03),
• Exemption for motorcycle parts: parts imported for the manufacture of motorcycles and classifiable in Chapters 84, 85 and 87 of the HTSUS are exempt from additional duties on steel, aluminum and copper (HTSUS code 9903.82.13),
• Exceptions for civil aircraft and their spare parts for certain countries with which the US has trade agreements (including the EU, see recital 10 of the proclamation of 2 April 2026): the exemptions are maintained.

On June 1, 2026, the White House again amended the 232 tariffs on steel, aluminum and copper through a Fact Sheet and Proclamation.

These amendments came into force on June 8, 2026 and will expire on December 31, 2027. They can be broken down as follows:

1. The additional customs duties on certain by-products listed in Annex III to the above-mentioned proclamation are reduced to 15% (agricultural machinery in particular),
2. A floor rate of 15% applies for 28 HTSUS codes linked to certain mobile industrial equipment (construction machinery, bulldozers, etc.) listed in Annex I-C of the proclamation of 1 June 2026:
   → If the MFN rate is already above 15 %, then no additional duty shall be applied,
   → If these products are made from steel/aluminum/copper originating in the United States, then the additional rate is 10%.
3. A reduction of duties from 25 % to 15 % for the EU on derivatives listed in Annex I-B and Chapters 84, 85 or 87 of the HTSUS, when imported exclusively for the manufacture of mobile industrial equipment (Annex I-C), agricultural equipment or industrial equipment (Annex III),
4. A lowering of the US content threshold required to benefit from the 10% preferential rate: a product is now considered to be made entirely from aluminum, steel or copper "melted and cast in the US" as soon as these metals represent at least 85% of its total weight (compared to 95% previously).
5. Addition of two new categories of derivatives subject to 25 % customs duties: steel racks and aluminum lithographic plates (Annex I-B).

Additional duties on heavy goods vehicles, medium-sized vehicles and their spare parts, buses, under 25 years of age

Under the proclamation of 17 October 2025, heavy goods vehicles, medium-sized vehicles and their spare parts (engines, transmission, chassis, tires, etc.) are subject to an additional duty of 25% (e.g. pick-up trucks, moving trucks, freight trucks, dump trucks) from 1 November 2025. Buses are subject to an additional 10% (school buses, city buses, coaches, etc.)

These additional duties are not superimposed on other additional duties under Section 232 (steel, aluminum and derived products, semi-finished copper products and derived products with a high copper content), nor with the 10% duty under Section 301 applicable to the EU.

For example, for an import into the United States of a new product falling within HTSUS code 8702.10.31.00 (bus), the applicable tax is 2 % MFN duty + 10 % Section 232 bus duty.

Certain exemptions are granted to Mexico and Canada under the USMCA.

The proclamation also establishes a compensatory import rate of 3.75 per cent. This percentage reflects the duties that would be payable if a 25% tariff were applied to 15% of the value of a medium or heavy truck assembled in the United States.

This compensation program is extended until 2030. Automakers in the United States will be able to offset a portion of the auto parts tariff equivalent to 3.75% of the manufacturer's suggested retail price for the cars they assemble in the United States.

Additional duties on motor vehicles and motor vehicle parts

An additional customs duty of 25% applies to passenger vehicles (sedans, sport utility vehicles, crossovers, minivans and vans), vans and certain motor parts (engines and engine parts, transmissions and powertrain parts, as well as electrical components) according to the following schedule:

• from 3 April 2025: for motor vehicles,
• from 3 may 2025: for automotive spare parts.

The products concerned are listed in Annex I to Presidential Decree 10908 of 26 March 2025.

This additional duty rate is capped at 15 % for imports originating in the EU since 1 August 2025.

Vehicles over 25 years of age are excluded from the scope of these additional duties.

For example, a product classified under 8703.22.0110 (TARIC code) is subject to an MFN customs duty rate of 2,5 % + 12,5 % of additional duties under Section 232 (to reach a total of 15 %).

Additional duties on timber, timber and timber products

Proclamation 10976 of September 29, 2025, which came into force on October 14, 2025, imposes additional duties of 10% to 25% on imports of softwood lumber, timber and timber products.

For imports of goods falling within HTSUS codes 9401.61.4011, 9401.61.4031, 9401.61.6011, 9401.61.6031, 9403.40.9060, 9403.60.8093 and 9403.91.0080 originating in the EU, the additional duty is capped at 15 % under HTSUS code 903.76.22.

If a product is subject to both the Section 232 duties on automobiles and automotive parts and the Section 232 duties on softwood lumber, timber and timber products derived therefrom, the additional duties on imports of softwood lumber, timber and timber products derived therefrom shall not apply.

Additional duties on patented medicines and active pharmaceutical ingredients

By the proclamation of April 2, 2026, the U.S. administration decided to impose additional duties under Section 232 on patented medicines and pharmaceutical active ingredients (Chapters 29 and 30 of the Customs Tariff).

These additional duties are applicable either from 29 September 2026 (date of general entry into force, i.e. 180 days after the date of the proclamation of 2 April 2026) or from 31 July 2026, depending on the companies concerned (see below).

Note: all products affected by these additional duties are exempt from the 10% customs duty imposed under Section 301.

Scope of these additional duties

This proclamation: 

• Establishes a basic ad valorem additional duty of 100 % on imported patented pharmaceutical products and their associated active ingredients,
• Establishes different dates of entry into force depending on the undertakings concerned,
• Applies different rates of additional customs duties depending on the products and companies concerned,
• Introduces several exemptions. 

These different elements are included in the 4 annexes:

1. Annex I lists patented pharmaceutical products and pharmaceutical ingredients subject to additional customs duties (100%, unless exempted or reduced),
2. Annex II lists the tariff agreements concluded between the US administration and certain companies which then benefit from an additional duty rate of 0% for their imports of patented pharmaceutical products and pharmaceutical ingredients,
3. Annex III lists the companies that will be subject to these additional duties as of 31 July 2026. Companies not included in this list will be subject to these additional duties from 29 September 2026,
4. Annex IV details the pharmaceutical products and ingredients that currently benefit from an exemption to the additional duty rate under Article 232.

Detailed taxation arrangements

Imposition of an additional duty of 100 % (Annex I)

The proclamation of 2 April 2026 establishes an ad valorem additional customs duty rate of 100% for products listed in Annex I for all countries that do not have a trade agreement with the US administration (EU, Japan, United Kingdom, South Korea, Switzerland, Liechtenstein) and whose companies have not concluded an agreement regarding the relocation of the production of medicines to the US (HTSUS code 9903.04.60).

Note: if the MFN customs rate already in force for a good concerned is higher than 100 %, then no additional duty under Section 232 shall be levied. 

Specific taxation for countries that have signed trade agreements 

Products originating in the European Union, Japan, South Korea, Switzerland and Liechtenstein are subject to a floor rate of 15% (HTSUS code 9903.04.62).

If the MFN rate is above 15%, then no additional rate applies. If the MFN rate already in effect for these products is less than 15%, then the additional rate under Section 232 on medicines achieves the 15% floor rate. 

Example: a product of 2933.79.0800 originating in the EU will be taxed at a rate of 4,2 % under the MFN duty in force + 10,8 % under the section 232 duty so as to reach a total of 15 % (date of entry into force varies according to the undertaking concerned, see below).

For products originating in the United Kingdom, the tax shall consist of the MFN rate already in force, to which an additional rate of 10 % shall be added (HTSUS code 9903.04.63). 

Taxation for companies with a plan to relocate production to the United States (Annex II)

The 13 companies listed in Annex II are subject to an additional rate of 20% (HTSUS code 9903.04.64) instead of the 100% rate due to the implementation of a plan to relocate their production to the United States.

However, this additional rate of 20% will be increased to 100% as of April 2, 2030.

Companies that demonstrate both the implementation of a plan to relocate their production to the United States and pricing agreements with the United States based on the most-favored-nation (MFN) clause are subject to an additional duty of 0% (HTSUS code 9903.04.65) until 20 January 2029.

Companies are required to submit periodic reports to the U.S. Secretary of State for Commerce on their progress in implementing their relocation plan. The rate of additional duties may be changed if the U.S. government believes that the companies have not complied with the terms of the agreements.

Date of application of this additional duty (Annex III)

Annex III lists the 17 companies that will be subject to the payment of additional duties from 31 July 2026 (i.e. 120 days after the date of the proclamation, 2 April 2026).

Undertakings not listed in Annex II or Annex III will be subject to the payment of these additional duties on 29 September 2026. Until that date, they may use HTSUS code 9903.04.61 to avoid payment of the additional duties.

Exemptions (Annex IV)

• Generic and biosimilar medicines: Generic medicines are currently exempt until April 2027. However, the proclamation states that in April 2027, the Ministry of Commerce will have to inform the President whether the imposition of additional tariffs on generics is justified (HTSUS code 9903.04.67). Annex IV may be updated and the range of products eligible for the zero duty rate may change accordingly.
• Products originating in the United States: these products are not subject to the additional duty under Section 232.
• Specialty products: Orphan drugs, nuclear drugs, plasma-derived therapies, fertility treatments, cell and gene therapies, antibody-drug conjugates, medical countermeasures related to chemical, biological, radiological and nuclear threats, and other specialty pharmaceuticals, as well as animal health products are subject to a zero additional duty rate (HTSUS code 9903.04.66). 

The above exemptions are also exempted from the payment of the 10 % duty under Section 301.

Example: HTSUS code 2934.99.7000 remains taxed only at 3,7 % under the MFN customs duty. 

In summary

Ongoing Investigations

Several sector inquiries under Section 232 are ongoing by the US administration (personal protective medical equipment, robotics and industrial machinery, etc.).

The list of ongoing investigations is available here.

Articulation between the various rights in force

The additional duty under Section 301 shall be superimposed on the MFN rate in force. If the MFN duty rate in force is 10 % or more, then no duty under Section 301 shall be applied. If the MFN rate in force is below 10 %, then the applicable 301 rate corresponds to the rate necessary to reach 10 % in total. 

Rate 301 does not superimpose additional duties already imposed under Section 232. A product covered by Duty 232 is therefore not taxed under Section 301.

For Section 232 duties on motor vehicles and motor vehicle parts, the additional duty is capped at 15% for imports originating in the EU.

Additional duties under Section 232 shall not overlap.

Reimbursement of IEEPA duties

The Supreme Court's decision does not contain provisions on the practical arrangements for implementing refunds of canceled IEEPA duties and refers the matter to the International Trade Court (ITC) for a ruling.

On 4 March 2026, the ILC issued a judgment ordering the US customs authorities to remove the illegal IEEPA customs duties imposed on imports that are being processed and therefore not definitively liquidated. 19 million declarations are concerned.

This decision of 4 March had the effect of interrupting the final winding-up of IEEPA duties.

On 27 March 2026, the ILC amended its decision of 20 March and required the US Customs Administration to include all imports, including those already definitively liquidated, in the IEEPA duty refund process.

The Court states that those declarations must be redeemed without the application of the IEEPA duties.

More information on the refund procedures is available on the Customs formalities for import to the United States page of the DGDDI website.