Fast-moving topic
Last verified: September 28, 2026 — tariff rules are changing quickly; confirm current rates with CBP and your customs broker.
Section 301 forced labor tariffs are additional duties of 10% or 12.5% on products of 60 economies, applied to goods entered, or withdrawn from warehouse, for consumption on or after July 24, 2026. On the dock, that makes country of origin, origin marking, segregation by origin and withdrawal timing matter more than before.
This guide covers what the 2026 tariff changes do to freight physically (at the terminal, on the dock and in storage), not what you owe. Since February the legal basis for U.S. import tariffs has changed three times. The Supreme Court held that IEEPA does not authorize tariffs[1]. A temporary Section 122 surcharge then ran from February 24 to July 24[2], and Section 301 forced labor tariffs took effect on July 24, 2026[3]. RapidShips is a warehouse and cross-dock in East Brunswick, NJ, not a customs broker. Nothing here is legal or customs advice. Take rates, classification and refunds to your licensed customs broker.
In this guide
- 2026 tariff timeline at a glance
- What are the Section 301 forced labor tariffs?
- What is tariff stacking, and why does origin decide the rate?
- Country of origin on the dock
- Warehouse withdrawals, FTZ admissions and timing
- How do IEEPA tariff refunds work?
- What’s next: vessel fees and dates to watch
- Dock checklist for importers this quarter
- Where a New Jersey warehouse fits (and where it doesn’t)
- Frequently asked questions
Key takeaways
- Section 301 forced labor tariffs are 10% or 12.5% depending on the economy, so an origin marking or paperwork error can now change the rate.
- Every 2026 action keys duty to the entry or warehouse-withdrawal date, not the arrival date.
- Only the importer of record or its filing broker can claim IEEPA refunds in CBP’s CAPE tool. A warehouse can’t do it for you.
2026 Tariff Timeline at a Glance
| Date | What changed | Why it matters on the dock |
|---|---|---|
| Feb 20, 2026 | Supreme Court decides Learning Resources, Inc. v. Trump: IEEPA does not authorize the President to impose tariffs.[1] | The IEEPA tariffs lose their legal basis. |
| Feb 24, 2026 | CBP stops collecting IEEPA duties on goods entered, or withdrawn from warehouse, for consumption on or after 12:00 a.m. ET.[4] | The entry or withdrawal date decides which duties applied. |
| Feb 24 – Jul 24, 2026 | Section 122 surcharge: an additional 10% ad valorem for 150 days, from 12:01 a.m. EST Feb 24 through 12:01 a.m. EDT Jul 24.[2] | One flat rate for most origins. |
| Jun 29, 2026 | CBP’s CAPE refund tool starts accepting entries flagged for reconciliation where the reconciliation entry has not been filed.[5] | Refund paperwork, not freight movement. |
| Jul 7, 2026 | Warehouse entries (types 21 and 22) are no longer accepted on a CAPE Declaration. Refunds are claimed on the warehouse withdrawals on which IEEPA duties were paid.[6] | Withdrawal records per lot become important. |
| Jul 24, 2026 | Section 301 forced labor tariffs of 10% or 12.5% on products of 60 economies begin at 12:01 a.m. ET.[3] | Origin now sets the rate tier. |
| Jul 28, 2026 | Cut-off for the in-transit exemption. Goods already on the water before Jul 24 had to be entered or withdrawn before 12:01 a.m. ET Jul 28.[3] | Late-arriving boxes from that window don’t qualify. |
| Nov 9, 2026 | USTR’s suspension of the China maritime Section 301 action (fees on maritime transport services) runs through 11:59 p.m. EST.[7] | Ask your ocean carrier how any fees would be passed through. |
What Are the Section 301 Forced Labor Tariffs?
The Section 301 forced labor tariffs are additional import duties that USTR imposed on all products of 60 economies. USTR found that each economy failed to impose and effectively enforce a ban on importing goods made with forced labor.[3] They apply to products entered, or withdrawn from warehouse, for consumption on or after 12:01 a.m. eastern time on July 24, 2026.[3]
- 10% applies to an economy that has a forced labor import ban, has committed to one through an Agreement on Reciprocal Trade, or has a partial regime that blocks some forced labor goods. 12.5% applies to every other economy.[3]
- Examples from CBP’s guidance: products of China and Vietnam carry 12.5%. Products of India, Canada and Mexico carry 10%, subject to the listed exemptions.[8]
- How entries show it: country duties use Chapter 99 headings 9903.05.20–9903.05.84.[8]
- Not covered: informational materials, donations, accompanied baggage, articles and parts of articles subject to Section 232 tariffs, and products listed in the notice’s annexes.[3] Goods of Canada and Mexico entered duty-free under USMCA have their own exemption headings.[8]
What Is Tariff Stacking, and Why Does Origin Decide the Rate?
Tariff stacking means more than one additional duty applies to the same article on top of its normal rate. CBP’s guidance says products covered by the forced labor tariffs remain subject to antidumping, countervailing and other duties, taxes, fees and charges.[8] Articles subject to Section 232 tariffs are excluded from the forced labor action.[3]
For the European Union, Japan, South Korea, Switzerland and Taiwan, CBP applies a combined “column one and Section 301” rate. If the product’s existing rate is already at or above the target, no additional duty is assessed.[8]
On the dock, this means two identical-looking cartons can carry different duty if they came from different economies. Section 122 was a flat 10% for most origins.[2] Now origin decides the tier, and the origin on the entry has to match the goods, cartons and marks.
Country of Origin on the Dock: Marking, Labels and Segregation
Under 19 U.S.C. 1304, every article of foreign origin, or its container, must be marked “in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit” to show an ultimate purchaser the English name of the country of origin.[9] Articles that aren’t properly marked, exported or destroyed face a separate 10% ad valorem marking duty.[9]
Where origin problems show up physically
- Mixed-origin containers. Cartons from two supplier countries share one box; if they are transloaded without keeping origin traceable, it gets hard to show what was what.
- Marks covered by new labels. A retail or carrier label applied over the origin mark can leave the mark no longer conspicuous. See our retail relabeling guide for label placement.
- Missing or wrong marks. If the origin on the cartons doesn’t match the commercial invoice, the broker has to resolve it before or after entry. The physical fix is remarking under the importer’s direction. Our country-of-origin marking guide covers the CBP Notice to Mark and how the correction is done.
At transload, receive by origin as well as by SKU: photograph marks per lot, note unmarked cartons and keep origin groups on separate pallets. That doesn’t decide duty; it gives your broker clean facts.
Warehouse Withdrawals, FTZ Admissions and Timing
Every 2026 change used the same trigger: goods entered for consumption, or withdrawn from warehouse for consumption, on or after a stated time.[4][2][3] For freight sitting in a CBP bonded warehouse, the withdrawal date decides which tariff regime applies, not the vessel arrival date.
- Bonded warehouse inventory. Unless exempt, lots withdrawn from February 24 until 12:01 a.m. EDT on July 24 were subject to Section 122,[2] and lots withdrawn after that are subject to the forced labor tariffs.[3] Withdrawal timing is the importer’s and broker’s call.
- Foreign-trade zones. Goods subject to the forced labor duty that are admitted to an FTZ may only be admitted in privileged foreign status, unless they are eligible for domestic status.[8] Ask your broker what that means for your zone inventory.
- Duty-paid storage. Freight in an ordinary, non-bonded warehouse has already been entered, and storing it longer doesn’t change the duty. Its value is getting boxes off the terminal clock while labels or origin questions are sorted. See short-term freight storage.
For the full comparison of bonded storage, FTZs and duty-paid storage, read our bonded warehouse vs. FTZ guide. If a container can’t be entered because paperwork is stuck, the general order cargo guide explains what happens to unentered freight.
Exams and holds haven’t changed hands
CBP still selects shipments for exam, and your broker handles the response. If a box is held, see our CBP exam holds guide.
How Do IEEPA Tariff Refunds Work?
IEEPA duty refunds are claimed through CBP’s Consolidated Administration and Processing of Entries (CAPE) function in ACE. Only the importer of record, or the licensed customs broker who filed the entries, can file a CAPE Declaration.[5] From CBP’s refund page (last modified September 2, 2026):
- ACE accepts CAPE Declarations for entries liquidated within the preceding 80 days, so CBP can reliquidate within the 90-day window for voluntary reliquidation under 19 U.S.C. 1501.[5]
- All refunds are paid electronically by ACH, and CBP must have your bank information on file.[5]
- TIB (23), duty deferral (08), reconciliation (09) and drawback (047) entry types are not accepted. Warehouse entries (21, 22) and entries designated on a drawback claim are listed as under evaluation for later deployments.[5]
- For warehoused goods, CBP says to submit CAPE Declarations with the warehouse withdrawals on which IEEPA duties were paid, not the original warehouse entry.[6]
A warehouse can’t file or speed up a refund. It can keep receiving and shipping records that help match withdrawals to freight.
What’s Next: Vessel Fees and Other Dates to Watch
USTR suspended its Section 301 China maritime action from 12:01 a.m. EST on November 10, 2025 through 11:59 p.m. EST on November 9, 2026.[7] The suspension covers the fees on maritime transport services and the duties on ship-to-shore cranes and certain cargo handling equipment.[7] Whether it is extended is USTR’s decision, so watch USTR and carrier notices in early November. CAPE is also still rolling out in phases.[5]
Dock Checklist for Importers This Quarter
- Confirm with your customs broker the origin, rate and any exemption heading for each product before the box lands.
- Make sure cartons carry a conspicuous, legible origin mark that matches the commercial invoice.
- Split mixed-origin freight by origin at devanning or transload, keep new labels clear of origin marks, and photograph marks per lot.
- For bonded or FTZ inventory, tell the warehouse which lots are being withdrawn and when. The broker times the withdrawal.
- Keep receiving, withdrawal and shipping records together per lot for any CAPE refund work.
- If paperwork is stuck, get the box off the terminal clock into duty-paid storage once it is released.
Where a New Jersey Warehouse Fits (and Where It Doesn’t)
RapidShips runs a 24/7 warehouse and cross-dock at 25A Cotters Lane, East Brunswick, NJ, serving the Port Newark and Elizabeth corridor. We are not a customs broker. We don’t classify goods, determine origin, file entries or refunds, or reduce duties. We do the physical side after release:
- Devanning and transloading with freight received and palletized by origin group.
- Remarking, relabeling and restacking through our freight rework service, done to the importer’s written instructions.
- Short-term, duty-paid storage to keep boxes off the terminal clock while documents are sorted.
If you have a container that needs to be sorted, marked or held after release, call 800-376-2808 or send us the details.
Frequently Asked Questions
When do Section 122 tariffs expire?
Will Section 122 tariffs be refunded?
What is tariff stacking?
Section 122 tariffs vs Section 301: what is the difference?
How do IEEPA tariff refunds work?
Can a warehouse reduce my tariffs or file my refund?
Sources
- Supreme Court of the United States, "Learning Resources, Inc. v. Trump, No. 24-1287 (decided February 20, 2026), slip opinion," accessed September 2026.
- U.S. Customs and Border Protection, CSMS, "CSMS # 67844987 – Imposing Temporary Section 122 Duties," accessed September 2026.
- Office of the United States Trade Representative, "Notice of Actions in Section 301 Investigations … Related to the Failure of Each Economy to Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced with Forced Labor," accessed September 2026.
- U.S. Customs and Border Protection, CSMS, "CSMS # 67834313 – Ending Collection of International Emergency Economic Powers Act Duties," accessed September 2026.
- U.S. Customs and Border Protection, "International Emergency Economic Powers Act (IEEPA) Duty Refunds," accessed September 2026.
- U.S. Customs and Border Protection, CSMS, "CSMS # 69127837 – UPDATE: CAPE for IEEPA Refunds – Warehouse Entries," accessed September 2026.
- Federal Register, "Notice of Modification of Section 301 Action: China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance (2025-19873)," accessed September 2026.
- U.S. Customs and Border Protection, CSMS, "CSMS # 69326983 – GUIDANCE: Section 301 Forced Labor Import Duties," accessed September 2026.
- Legal Information Institute, Cornell Law School, "19 U.S. Code § 1304 – Marking of imported articles and containers," accessed September 2026.
This guide is general operational information about handling freight, not legal, customs or tax advice. Tariff rates, exemptions and refund procedures are changing quickly. Last verified September 28, 2026; confirm current requirements with CBP and your licensed customs broker before acting. RapidShips is not a customs broker and cannot reduce duties.