How US Import Duties Stack: MFN + Section 301 + Section 232

The base duty rate on your customs entry is just the beginning. Additional tariffs from multiple authorities can stack to 50%, 80%, or even 130%+ on certain products from certain countries.

The layers

US import duties are not a single rate. They're built from multiple independent authorities, each adding their own percentage:

LayerAuthorityTypical rangeApplies to
MFN rateUSITC HTS Schedule0-25%All countries (base rate)
Section 301USTR (Trade Act 1974)+7.5% or +25%China only
Section 232Commerce Dept+25%Steel/aluminum from most countries
Reciprocal tariffsVarious+10% to +50%Country-specific
AD/CVDCommerce/ITCVaries widelySpecific products from specific countries

These rates are additive. Each layer is calculated on the entered value of the goods and added to the total duty owed.

Real examples

Example 1: Steel plate from China

MFN rate (7208.51.00)Free
Section 301 — List 3 (9903.88.03)+25.0%
Section 232 — Steel (9903.91.01)+25.0%
Total duty50.0%

The base rate is "Free" but the actual landed cost includes 50% in additional duties. An importer looking only at the MFN rate would underestimate their cost by 50 percentage points.

Example 2: Surgical face masks from China

MFN rate (6307.90.98)7.0%
Section 301 — List 4a (9903.88.15)+7.5%
Section 301 — additional (9903.88.03)+25.0%
Section 301 — PPE surcharge+50.0%
Total duty89.5%

Face masks were hit by multiple tariff waves — originally on List 4a at 7.5%, then escalated with additional provisions targeting PPE from China. An importer looking at the MFN rate of 7% would estimate duties at $700 on a $10,000 shipment. The actual bill: $8,950. This isn't a theoretical scenario — it's what CBP collects at the port.

Example 3: Cotton t-shirt from China

MFN rate (6109.10.00)16.5%
Section 301 — List 4a (9903.88.15)+7.5%
Total duty24.0%

Example 4: Cotton t-shirt from Vietnam

MFN rate (6109.10.00)16.5%
No additional tariffs
Total duty16.5%

Same product, different origin — 24% from China vs 16.5% from Vietnam. This 7.5pp difference is why supply chains are shifting.

Example 5: Cotton t-shirt from Mexico (USMCA)

MFN rate (6109.10.00)16.5%
USMCA preferential rate0%
Total duty0%

With USMCA rules of origin met, the MFN rate is replaced by the preferential rate. 24% from China, 16.5% from Vietnam, 0% from Mexico.

Penalties for underpayment. Under 19 U.S.C. §1592, if CBP determines you underpaid duties due to incorrect classification or failure to apply additional tariffs, penalties can reach 2-4x the lost duties. Ford paid $365M in 2024 for van misclassification.

Section 301: China tariffs

Section 301 tariffs apply exclusively to goods from China. Four "Lists" cover different product categories at different rates. See the full lookup tool.

Section 232: Steel and aluminum

25% additional duty on steel and aluminum products from most countries. Some countries have negotiated exemptions or quota arrangements. The provisions cover HTS chapters 72-73 (steel) and 76 (aluminum), plus derivative products.

How to calculate total duty

  1. Classify the product — get the 10-digit HTS code
  2. Look up the MFN rate — the base rate in the HTS schedule
  3. Check Chapter 99 provisions — Section 301/232/reciprocal tariffs
  4. Check FTA eligibility — does the origin country have an FTA?
  5. Check AD/CVD orders — product and country-specific anti-dumping duties
  6. Add it all up — MFN + all additional duties = total
The HTS API does steps 1-3 in one call. Describe your product and country of origin — get the HTS code, MFN rate, and Section 301/232/reciprocal effective rates from Census data in a single response, plus the share of imports under that code that claimed FTA preference. Try the demo.

The real number most importers miss

Most trade compliance tools — including the USITC's own website — show you the MFN rate. That's Layer 1. They don't show Layers 2-5 because those come from different legal authorities (USTR, Commerce, presidential proclamations), published in different Federal Register notices, codified in different parts of the tariff schedule (Chapter 99 provisions like 9903.88.03).

The result: importers routinely underestimate their duty liability by 2-10x. A compliance officer budgeting for "Free" duty on Chinese steel gets a 50% bill. A sourcing team comparing China vs Vietnam costs sees 7% vs 7%, when the real comparison is 89.5% vs 7%.

The Chapter 99 data is public — it's in the same USITC schedule that defines the MFN rates. But it's stored in footnotes that most tools strip out. We parse every footnote across all 26,118 HTS codes and resolve them to actual rates.

Supply chain implications

The stacking of tariffs is reshaping global supply chains:

Understanding exactly how duties stack is the first step in optimizing your landed cost. The classification determines which rates apply — get it wrong and you either overpay or face penalties.

Ready to calculate? Try the HTS API with any product description. See MFN + Section 301/232 + FTA rates in one response.

Sources

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