U.S. Customs and Border Protection (CBP) has opened a refund opportunity for importers that paid Section 301 duties on certain Chinese pump parts and plastic products entered between July 1 and September 22, 2026.
The opportunity follows a September 2 Federal Register notice in which the U.S. Trade Representative (USTR) amended four existing Section 301 product exclusions. The amendments conform the exclusions to statistical changes made to the Harmonized Tariff Schedule of the United States (HTSUS) on July 1 and apply retroactively to that date.
Although the amendments reach back to July 1, the Automated Commercial Environment (ACE) did not begin accepting the updated exclusion claims until noon on September 23, as announced in CBP CSMS #69990649 on September 22.
Importers that paid Section 301 duties on qualifying merchandise during that window should review their entries to determine whether they qualify for refunds.
Why the Exclusions Needed To Be Updated
Effective July 1, the U.S. International Trade Commission replaced several ten-digit HTSUS statistical reporting numbers. Four Section 301 exclusions still described covered goods by the old numbers, which meant the new numbers fell outside the exclusion text.
To preserve the original product coverage, USTR amended U.S. notes 20(vvv)(i)(4), 20(vvv)(i)(5), 20(vvv)(i)(6), and 20(vvv)(iv)(4) to subchapter III of chapter 99. All four exclusions are claimed under HTSUS 9903.88.69.
The amendments map the former statistical numbers to the new ones as follows:
- Pump parts: formerly 8413.91.9065, 8413.91.9085, or 8413.91.9096; now 8413.91.9039, 8413.91.9046, 8413.91.9059, or 8413.91.9099
- Plastic products: formerly 3926.90.9910; now 3926.90.9915 or 3926.90.9920
These tariff numbers are not blanket exclusions for every product classified within them. The merchandise must satisfy the specific product description in the applicable U.S. note.
ACE Began Accepting the Corrected Treatment September 23
CBP activated ACE functionality for the conforming amendments at noon on September 23.
For qualifying entries, importers should report HTSUS 9903.88.69 and should not report the corresponding Chapter 99 number that imposes the Section 301 China duty.
Importers and brokers should confirm that their filing systems and product databases reflect the updated statistical numbers. Continuing to use a retired statistical number or an incorrect Chapter 99 number could result in an entry rejection or an unnecessary duty payment.
CBP directs questions about ACE entry rejections involving product exclusions to the importer’s CBP Client Representative. Questions about Section 301 entry-filing requirements go to CBP’s Trade Remedy branch at traderemedy@cbp.dhs.gov.
Importers May Be Entitled to Refunds
CBP specifically confirmed that importers may seek refunds of Section 301 duties paid on qualifying entries.
For eligible merchandise entered from July 1 through September 22, an importer may generally:
- File a Post Summary Correction (PSC) on or after September 23, if the entry is still within the PSC filing window
- Protest the liquidation if the PSC window has closed but the entry is still within the protest period
A PSC generally must be filed within 300 days of the date of entry and at least 15 days before the entry’s scheduled liquidation date. A protest generally must be filed within 180 days after liquidation. Because the affected entries date from July 2026 or later, many should still be eligible for a PSC, but each entry’s status should be confirmed before choosing a recovery method.
Companies should not wait until the end of these windows to begin the review. Identifying entries, confirming product eligibility, gathering technical documentation, and preparing corrected filings can take time.
Product Descriptions Control Eligibility
Classification under one of the listed statistical numbers does not automatically make merchandise eligible for the exclusion.
Importers should confirm that each product satisfies the full exclusion description, including relevant physical characteristics, materials, dimensions, technical specifications, and intended function.
Supporting records may include:
- Product specifications
- Engineering drawings
- Material-composition records
- Catalog descriptions
- Purchase orders
- Supplier statements
- Photographs
- Previous classification determinations
- Entry and payment records
Importers must exercise reasonable care when claiming the exclusion and should maintain documentation supporting the claim.
Companies Should Review More Than Previously Flagged Entries
Importers should review their complete entry population for July 1 through September 22 rather than relying only on entries previously identified as potential exclusions.
The HTSUS changes may have caused:
- Products to be assigned new statistical numbers
- Broker databases to retain outdated classifications
- Product records to lose an exclusion indicator
- Section 301 duties to be paid automatically
- Different brokers to apply inconsistent treatment to the same product
Companies using multiple brokers should compare treatment across their entry data. A product correctly excluded by one broker may have been charged Section 301 duties by another.
These Exclusions Expire November 9 Unless Extended
The four amended exclusions are among the 178 Section 301 exclusions USTR extended in late 2025. Under that extension, the exclusions cover goods entered through 11:59 p.m. EDT on November 9, 2026. Unless USTR extends them again, the full Section 301 duty will apply to these products after that date. Alba covered the extension in USTR Extends Section 301 China Tariff Exclusions Through November 2026.
Importers relying on these exclusions should factor the November deadline into landed-cost planning while they pursue refunds for the July through September window.
What Importers Should Do Now
Importers of Chinese pump parts and qualifying plastic products should:
- Identify entries made from July 1 through September 22.
- Search for both the former statistical numbers (8413.91.9065, 8413.91.9085, 8413.91.9096, and 3926.90.9910) and the new ones.
- Compare each product with the complete exclusion description.
- Confirm whether Section 301 duties were paid.
- Determine whether each entry is eligible for a PSC or a protest.
- Gather documentation supporting product eligibility.
- Verify the correct use of HTSUS 9903.88.69.
- Update broker instructions and internal product databases.
- Review whether the same error affected multiple brokers or importing entities.
- Track each refund through final processing.
Even when the refund on a single entry is small, the total recovery across multiple products, shipments, brokers, or importer numbers may be significant.
ASK Alba™
Contact the Alba team for help identifying affected entries, confirming exclusion eligibility, filing Post Summary Corrections or protests, and pursuing available duty refunds. Subscribe to the ASK Alba™ Trade Brief for timely updates on Section 301 exclusions, tariff refunds, and other opportunities to reduce import costs.
References
- U.S. Customs and Border Protection, CSMS #69990649, GUIDANCE: Section 301 China Conforming Amendment (September 22, 2026)
- Office of the U.S. Trade Representative, Notice of Conforming Amendments to Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation, 91 FR 56538 (September 2, 2026)
- Office of the U.S. Trade Representative, Notice of Product Exclusion Extensions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation, 90 FR 55232 (December 1, 2025)
- 19 CFR 101.9(b), Post Summary Corrections test (eCFR)
- 19 U.S.C. 1514, Protest against decisions of CBP
