The mid-year update to the US Harmonized Tariff Schedule introduces no MFN duty rate changes, but significantly reshapes product scope for Section 301 tariffs on China and implements widespread statistical reporting changes, particularly for chemicals and food products.
The US International Trade Commission’s latest update to the Harmonized Tariff Schedule is primarily a housekeeping and scope-adjustment revision. HTSUS Revision 11, effective 2 July 2026, introduces no changes to standard MFN duty rates. Instead, its nearly 460 changes are dominated by a large-scale statistical reclassification of commodity lines, mainly effective 1 July, and a significant churn in the product scope for Section 301 tariffs on goods from China. Dozens of new HTS lines were created and an equal number removed, concentrated in organic chemicals, cocoa, and beverages, signaling a move toward more granular trade data collection.
What this revision does
HTSUS Revision 11 is a significant update focused on statistical modernisation and trade-remedy scope adjustments, not on broad-based tariff movements. The revision contains no changes to standard Most-Favored-Nation (MFN) duty rates for commodity lines in Chapters 1 through 97. The vast majority of the 457 changes in this update are statistical in nature, driven by 325 modifications made under the authority of Section 484(f) of the Tariff Act of 1930, which governs statistical enumeration of imports and exports. These changes, primarily effective on 1 July 2026, are concentrated in specific sectors, with the most activity seen in Chapter 29 (Organic chemicals), Chapter 18 (Cocoa and cocoa preparations), Chapter 22 (Beverages, spirits and vinegar), and Chapter 7 (Edible vegetables).
This revision is best understood as a housekeeping action designed to improve the granularity of US trade data, combined with a targeted recalibration of existing trade-remedy programmes. For importers, the key impacts are not in new baseline duty rates but in ensuring compliance with new 10-digit reporting numbers and verifying whether specific products have moved into or out of the scope of Chapter 99 tariffs.
Trade-remedy programs
Activity in Chapter 99, which houses duties from trade remedies, was a central feature of this revision, particularly concerning Section 301 tariffs on goods from China.
Section 301 (China): The scope of Section 301 tariffs saw significant churn. This revision did not enact a simple expansion or reduction, but rather a re-shaping of product coverage. Twenty-nine commodity lines were removed from the scope of Section 301 tariffs, while 25 other lines were brought into scope. These changes affect a range of products, including certain vegetables (HS heading 0704), citrus fruits (0805), sugars (1702), and cocoa preparations (1805, 1806). Companies importing these goods from China must immediately verify whether their specific HTS classifications are now subject to, or have been released from, the additional Section 301 duties.
Other Programs: The revision also included minor adjustments to other trade programs. Three commodity lines—including products under headings for enzymes (3507), ferro-manganese (7202), and vehicle parts (8708)—were brought into the scope of a non-301 program. In a symmetrical move, three lines covering similar products were removed from scope. Additionally, the descriptive text for a Chapter 99 duty on certain semiconductor articles (heading 9903.79.01) was modified per U.S. Note 39(a), a technical change that does not alter the duty rate itself.
Tariff & line changes
This revision contains no changes to standard Most-Favored-Nation (MFN) duty rates in Chapters 1–97. Importers will find that baseline tariffs for ordinary goods remain unchanged.
The primary structural change to the tariff schedule was the parallel addition of 35 new commodity lines and removal of 35 existing lines. This one-for-one replacement strongly indicates statistical breakouts, where a single, broader HTS number is replaced by multiple, more specific HTS numbers to capture trade data with greater precision. This was particularly prevalent in food, beverage, and chemical sectors. Notable new HTS lines established in this revision include:
- 0704.20: Brussels sprouts
- 1805.00: Cocoa powder, not containing added sugar
- 2209.00: Vinegar and substitutes for vinegar
- 2918.30, 2918.99, 2920.90, 2922.19, 2924.29, 2932.99: Various organic chemicals
Importers of goods in these and other affected chapters must transition to the new, more granular HTS numbers for customs declarations to ensure compliance and avoid clearance delays.
What takes effect, and when
The changes in Revision 11 carry several effective dates, reflecting their different legal origins:
- 6 April 2026: A single change, originating from a Presidential Proclamation, took effect earlier this year.
- 1 July 2026: The vast majority of changes—325 records—became effective the day before this revision’s publication. These correspond to the large-scale statistical modifications implemented under Section 484(f).
- 2 July 2026: The remaining 131 changes, including the Section 301 scope adjustments, were formally introduced with the publication of this revision.
Announced but not yet reflected
While this revision implemented numerous changes, other significant trade policy actions announced by the US government in the preceding weeks have not yet been incorporated into the Harmonized Tariff Schedule.
In mid-to-late June 2026, the US Trade Representative (USTR) announced the initiation of a Section 301 investigation into Germany’s pricing policies for pharmaceutical products. USTR will examine whether these practices are unreasonable or discriminatory and burden US commerce. As is standard, such investigations precede any potential tariff actions. This revision does not yet reflect any tariff measures related to this new investigation.
What to watch
The key takeaways from HTSUS Revision 11 are operational and strategic. First, importers dealing in chemicals, cocoa, beverages, and certain vegetables must immediately update their classification databases to reflect the new statistical breakouts, ensuring the use of correct 10-digit HTS numbers on all entries going forward. Second, any company importing goods from China in the affected product categories must conduct a thorough review to determine if their products have been newly added to or removed from the Section 301 tariff lists. Finally, the newly announced Section 301 investigation into German pharmaceuticals, while not yet affecting the tariff schedule, signals a potential area of future trade friction that warrants close monitoring by firms in the life sciences sector.
By the numbers
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