The November cliff did not happen. On November 10, 2026, the Office of the U.S. Trade Representative (USTR) published a notice extending all 178 remaining Section 301 exclusions on Chinese goods through 11:59 p.m. Eastern on January 9, 2027, with no gap from the previous extension. If your entries already claim HTSUS heading 9903.88.69 or 9903.88.70 correctly, nothing changes for what you file today. What changes is the calendar: you now have about eight weeks, running through the year-end holidays, to confirm coverage, model the snapback, and plan entries around the next cutoff.
What USTR Did on November 10
The exclusions come from the Section 301 investigation into China's practices around technology transfer and intellectual property, the tariff program that produced Lists 1 through 4A in 2018 and 2019. Most exclusions from those duties expired years ago. What remains is a small, fixed set: 178 exclusions, and that is the whole universe.
They split into two groups. 164 product exclusions are claimed under Harmonized Tariff Schedule of the United States (HTSUS) heading 9903.88.69 and described in U.S. notes 20(vvv)(i) through (iv) to chapter 99. 14 solar manufacturing equipment exclusions are claimed under heading 9903.88.70 and described in note 20(www).
The new notice, published at 91 FR 72610 (FR Doc. 2026-22925), extends every one of them. None were added and none were dropped. The extension covers goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern on November 10, 2026 and before 11:59 p.m. Eastern on January 9, 2027. The prior extension (90 FR 55232, December 1, 2025) ran through 11:59 p.m. on November 9, 2026, so coverage is continuous. Effective November 10, the article descriptions of both headings now read "January 9, 2027" where they used to read "November 9, 2026."
USTR's stated reason is brief: the extension is made "in light of ongoing discussions with China." The notice says the decision also weighed the comments received on USTR's September 16, 2025 request for comments. It closes with the same reservation as the last one: USTR "may continue to consider further extensions or additional modifications as appropriate." It also says U.S. Customs and Border Protection (CBP) "will issue instructions on entry guidance and implementation." As of November 10, 2026, CBP had not yet issued that guidance through its Cargo Systems Messaging Service (CSMS).
One detail governs everything else in this article: the date that matters is the entry date, not the date the goods were ordered, shipped, or arrived. An exclusion applies based on when merchandise is entered for consumption or withdrawn from a warehouse for consumption.
What This Means for Entries You File This Week
Most importers fall into one of three situations, and each calls for something different.
You were claiming the exclusion and kept claiming it. Keep doing what you are doing. The heading and the product descriptions are unchanged apart from the end date, and the exclusions remain available for any product that meets the description, whoever filed the original request.
Your filer dropped the heading in anticipation of the deadline. Until the notice appeared, the heading text said the exclusions ended November 9, so some filers planned to stop claiming them. Entries dated November 10 or later that leave 9903.88.69 or 9903.88.70 off the entry summary will carry Section 301 duty the extension now excludes. Tell your filer today to resume the claim on qualifying goods, then list anything entered since November 10 without it. Once those summaries are filed and paid, a Post Summary Correction, covered below, is the mechanism for fixing them.
You are waiting on CBP. CBP has said it will issue entry guidance. Until it does, watch CSMS rather than secondhand summaries. If an entry claiming either heading is rejected in the Automated Commercial Environment (ACE), the CBP system that processes U.S. customs entries, CBP's earlier exclusion messages direct questions about ACE rejections to your CBP client representative. Those same messages carry a filing rule worth repeating: when 9903.88.69 is submitted, the importer does not also submit the corresponding chapter 99 number for the Section 301 China duties.
How to Confirm You're Actually Using an Exclusion
A surprising number of importers don't know whether they rely on one. Exclusions are claimed by the filer as a secondary HTSUS line on the entry summary, and if a broker has handled it quietly for two years, it may never have come up.
The fastest check is your own entry summaries in ACE: search for headings 9903.88.69 and 9903.88.70. If either appears, you are relying on an exclusion that now ends January 9, 2027. Without direct ACE visibility, ask your broker for a twelve-month duty report by HTS code and look for the same two headings, in writing.
Then confirm you actually qualify, because exclusion scope is narrower than it looks. Per the new notice, each exclusion is governed by both a ten-digit HTSUS statistical reporting number and the product description in the chapter 99 notes. An exclusion for a particular pump part does not cover everything classified under that part's ten-digit code. If your product drifted (a design change, a new supplier, a different specification), re-read the description against what you import now.
There is a 2026-specific wrinkle. Some ten-digit numbers in the HTSUS changed effective July 1, 2026, and USTR amended five exclusions to match (91 FR 56538, September 2, 2026, and 91 FR 64211, October 7, 2026). CBP's CSMS #70261629 of October 22, 2026 lists the new numbers: pump parts now under 8413.91.9039, 8413.91.9046, 8413.91.9059 or 8413.91.9099; plastic articles under 3926.90.9915 or 3926.90.9920; and goods under 8479.90.9591. If you import under those notes, check that your entries carry the current numbers.
What Your Duty Bill Looks Like When the Exclusions End
The extension defers the snapback; it does not remove it. When an exclusion lapses, the underlying Section 301 rate returns automatically, with no transition rate and no phase-in. The rates go back to where the lists sat before the exclusion: 25% for Lists 1, 2, and 3, and 7.5% for List 4A, which USTR reduced from 15% effective February 14, 2020.
That is on top of the most-favored-nation (MFN) rate your goods already pay, the standard duty rate in the tariff schedule, and on top of anything else layered onto the entry. In 2026 that stack is crowded. The separate Section 301 forced-labor action took effect for entries on or after July 24, 2026 across 60 investigations, China among them. It is a distinct action: your 9903.88.69 or 9903.88.70 exclusion does not exclude you from it. The forced-labor notice's text does not reference either heading, and its HTSUS note keeps other chapter 99 duties in place alongside it. Section 232 duties and any antidumping or countervailing duty orders sit on top as well. Our guide to tariff stacking in 2026 walks through how these layers interact on a single entry, and our forced-labor tariff page covers that action's exemption structure.
Run the number before it surprises you. Take a hypothetical importer bringing in $2 million a year of List 3 goods covered by an exclusion. Today it pays no Section 301 duty on that value. If the exclusion ends after January 9, that becomes 25%, roughly $500,000 a year or about $41,700 a month in new duty. The extension defers about two months of that; it doesn't erase the rest. (That is our arithmetic on an illustration, not a forecast.) For a business on a 15% gross margin, that is a pricing decision, a sourcing decision, or both. Model it against your actual volume by SKU, because the cost lands unevenly depending on how your shipments cluster.
The Extension Record, and What It Tells You
Nobody outside USTR knows whether there will be another extension, and anyone telling you otherwise is guessing. The procedural history is public, though, and it is worth reading closely. As recited in the November 10 notice:
- May 31, 2025. USTR extended 164 exclusions to this date in May 2024 (89 FR 46948). The 14 solar equipment exclusions, granted in September 2024 (89 FR 76581), also ran through May 31, 2025.
- August 31, 2025. Both sets were extended together (90 FR 23987, June 5, 2025).
- November 29, 2025. A 90-day extension (90 FR 42500, September 2, 2025).
- November 9, 2026. Announced November 26, 2025 and published December 1, 2025 (90 FR 55232), following the trade deal the White House announced on November 1, 2025.
- January 9, 2027. Published November 10, 2026 (91 FR 72610).
Three things stand out. First, at about two months this is the shortest extension in the sequence, and it is tied explicitly to "ongoing discussions with China" rather than to a finished agreement. Second, there was no fresh comment notice this time. Before the November 2025 deadline, USTR asked for public comments on September 16, 2025. This round, it relied on those 2025 comments and issued no new request. Third, the notice arrived at the last possible moment: filed with the Office of the Federal Register at 8:45 a.m. on November 9, 2026, the final day of the old coverage, and published November 10, the first day entries would otherwise have lost it.
The practical lesson is that the advance warning importers used to watch for may not come. A comment notice is no longer a reliable signal, and an extension can land on the deadline itself. So plan as though the tariff returns after January 9 and treat any further extension as upside. Building your first-quarter pricing around a renewal that hasn't been announced is a bet with a $500,000-a-year downside in the example above.
Entries That Straddle January 9
The days around the cutoff are where mistakes happen. Eligibility turns on entry date, so goods sitting in the same warehouse can carry different duty treatment depending on when they are entered.
Note what the November 10 notice, like the December 2025 notice before it, does not contain: an in-transit savings clause. Some tariff actions include one. The forced-labor Section 301 notice, for instance, spared goods loaded and in transit before 12:01 a.m. Eastern on July 24, 2026 if they were entered before 12:01 a.m. on July 28. The exclusion extensions have no equivalent. Goods on the water on January 9 get no protection from the fact that they shipped while the exclusion was in force.
Two practical consequences follow. First, if you have flexibility on entry timing and the goods are available, entering before the cutoff preserves the exclusion for that merchandise. This is ordinary entry planning, not a loophole, but it has to be real. The merchandise must genuinely be entered for consumption, with correct classification, valuation and country of origin. Filing a sloppy entry to beat a deadline trades a known duty increase for an unknown penalty exposure.
Second, if you withdraw goods from a bonded warehouse, the withdrawal date is your entry date for this purpose. Bonded inventory that qualifies today loses the exclusion on withdrawals made after January 9 unless USTR extends again. Because this window runs through Thanksgiving, Christmas and New Year's, when carrier schedules and staffing both thin out, have that conversation with your broker in November rather than the first week of January. Getting classification right across the catalog underpins all of it, and our HTS classification guide covers how to build and maintain that.
Fixing Entries After the Fact: PSC and Protest
Two correction paths exist, and it helps to be clear about what each can and can't do.
A Post Summary Correction (PSC) is the electronic method for correcting an entry summary before it liquidates, liquidation being CBP's final calculation of the duties owed. Per CBP, a PSC can be filed within 300 days of the entry date, or up to 15 days before the scheduled liquidation date if that comes first. The entry summary must be paid, in accepted status, and not under CBP review. If a qualifying entry was filed without the exclusion claim, including one dated November 10 or later by a filer who had stopped claiming it, a PSC is the mechanism for correcting that filing. Our PSC filing guide covers the process in detail, and our post-summary corrections service is $150 per entry for up to 10 lines.
What a PSC cannot do is change your entry date. No correction makes an entry dated after the cutoff eligible for an exclusion that had already ended. A PSC fixes what was filed, not when it was filed.
Once an entry liquidates, the PSC window closes. CBP's PSC page notes that after liquidation the remaining options are a prior disclosure or a protest, and by statute a protest is due within 180 days after liquidation. That is a slower, more formal process. Neither path guarantees an outcome, because CBP decides each on the filing and the documentation behind it. Both expire on their own schedules, which is why an inventory of affected entries and their liquidation dates is worth building before year-end.
An Eight-Week Checklist
Between now and January 9, 2027, five things deserve calendar time. Confirm coverage: pull your 9903.88.69 and 9903.88.70 usage and verify each product against its description and current ten-digit number. Re-check entries since November 10: list any qualifying entry that dropped the claim. Model the cost: apply the correct list rate to your actual volume by SKU and put a real annual number in front of whoever owns pricing. Plan entry timing: decide deliberately on shipments and bonded withdrawals near January 9, allowing for holiday schedules. Audit recent filings: check exclusion claims on every entry still inside the PSC window.
Importers who handle more of this in-house tend to spot issues earlier, simply because they are closer to the entry data. Our self-filing software page covers what that involves, at $30 per entry with licensed broker support when something gets complicated. Importers who would rather hand the whole problem to a licensed broker can do that instead, at $100–$250 per entry depending on complexity. Either way, watch CSMS for CBP's implementation guidance and the Federal Register for whatever USTR does before January 9.
No. USTR's notice published November 10, 2026 (91 FR 72610) extended all 178 exclusions, without a gap, through 11:59 p.m. Eastern on January 9, 2027. If USTR does not extend again, the underlying list rate (25% for Lists 1 through 3, 7.5% for List 4A) applies to entries after that cutoff, in addition to the MFN rate and any other duties.
Can I still claim an exclusion on goods that arrive before January 9 but are entered after it?
No. Eligibility turns on the date the goods are entered for consumption or withdrawn from warehouse for consumption, not the shipping or arrival date. The extension notice includes no in-transit savings clause. Goods arriving in early January should be evaluated on entry timing specifically.
Does my Section 301 exclusion also cover the 2026 forced-labor tariffs?
No. The 9903.88.69 and 9903.88.70 exclusions apply only to the technology-transfer Section 301 action that produced Lists 1 through 4A. The forced-labor Section 301 action that took effect July 24, 2026 is a separate determination with its own exemption annexes, and it applies to products of China regardless of your exclusion status.
USTR extended the exclusions again. Do I need to do anything?
No re-application is required. The notice says the extended exclusions are available for any product that meets the exclusion description, and it updated the heading text to January 9, 2027 automatically. The practical steps are on your side of the entry: make sure your filer keeps claiming the heading on qualifying goods, correct any entry dated November 10 or later that dropped the claim while it is still inside the PSC window, and watch CSMS for CBP's implementation instructions, which had not issued as of November 10, 2026.
Get Ahead of the January Deadline
The importers who handle this well won't be the ones who find a clever workaround, because there isn't one. They'll be the ones who know by early December which SKUs are covered, what the snapback costs them, and which recent entries still have a correction window open. After a notice that landed on the deadline itself, that is a few hours of work now instead of a scramble in January.
That work maps onto the four ways we help. We clear your entries at all U.S. ports with the exclusion claimed correctly. We consult on which SKUs rely on these exclusions and what the snapback costs at your volume. We help you comply by auditing recent filings and preparing PSCs where an entry missed the claim. And we automate routine filing through self-filing software for importers who want to own it. For a second set of eyes on any of that, talk to our team. We would rather help you plan for January 9 in November than untangle it in February.