Section 301 Exclusions Expire November 2026: What Hardware Founders Must Recost Now

Short answer: the U.S. Trade Representative extended the 178 remaining Section 301 product exclusions, and that relief now runs through 11:59 p.m. eastern daylight time on November 9, 2026. If any line on your bill of materials is China-origin and quietly depends on one of those exclusions, your landed cost can change the day the exclusion ends.

This guide is written for founders and product teams moving from a functional prototype toward production quotes in industrial, medical, electromechanical, pet, and hunting hardware. It is educational, not legal or customs advice.

USTR extended the 178 current exclusions connected to the Section 301 investigation of China acts, policies, and practices related to technology transfer, intellectual property, and innovation. Two annexes carry the relief.

Annex A covers exclusions under HTSUS heading 9903.88.69 and U.S. notes 20(vvv)(i) through 20(vvv)(iv). Annex B covers exclusions under HTSUS heading 9903.88.70 and U.S. note 20(www), which are the solar manufacturing equipment exclusions.

The extension applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EST on November 30, 2025, and before 11:59 p.m. EDT on November 9, 2026.

The decision followed the November 1, 2025 White House announcement of a U.S. and China trade and economic deal, and USTR also weighed public comments and interagency advice.

USTR has said it may continue to consider further extensions or additional modifications as appropriate, so treat November 9, 2026 as the planning date, not a guaranteed cliff.

One detail matters more than the headline count: the scope of each exclusion is governed by the ten-digit HTSUS numbers and the product descriptions in the cited U.S. notes. A product that looks similar to an excluded product is not automatically covered.

Exclusion relief is product-specific and HTS-specific. In practice, a contract manufacturer quote can reflect exclusion pricing without ever saying so on the quote sheet. When the exclusion ends, covered entries are again subject to the underlying Section 301 additional duties that apply to that product list assignment. We are deliberately not naming a rate here. Confirm the exact rate for your HTS codes with a licensed customs broker.

The cost of reacting late is not the duty alone. It is the tooling you already cut, the supplier you already qualified, and the retail or distributor price you already published. Sourcing changes are inexpensive while the design is still fluid and expensive once steel is committed. If you are sizing production economics, our guide to estimating mass production cost is the right companion piece to this one.

Work through this once per program, and keep the output next to your BOM so the next quote round starts from evidence instead of memory.

The path from idea to a functional prototype, then to design for manufacturing, then to production, gives you exactly one cheap window to change materials, fasteners, motors, enclosures, or electronics modules. That window closes when tooling is cut. Duty exposure belongs in the DFM conversation next to material cost and cycle time, not in a spreadsheet opened after the first production purchase order.

For teams still choosing a partner for that stage, how to choose a product development company covers the evaluation criteria, and product development consulting explains how we scope the work. At LA NPDT we take concepts to functional prototypes and into low volume production for industrial, medical, pet, and hunting hardware, so sourcing risk usually surfaces during DFM rather than after launch.

If you are still proving the concept, start with a fixed-scope feasibility or prototype plan so sourcing choices stay reversible. If you are already quoting production, rebuild landed cost with and without exclusion assumptions before you commit tooling. Talk with our team if you want a second set of eyes on the BOM, or read more from Konstantin Dolgan on taking hardware from idea to production.