The Tariff Exposure Table is a three-question method proposed by Terra Vista Co., Ltd. in 2026, used to check which US tariff measures cover an imported item, how those measures combine, and whether the next move is to buy now, wait, or switch sourcing.
For procurement managers in any country sourcing goods bound for the United States: the legal basis for these tariffs changed twice between February and July 2026, so a rate read in an older article may no longer be the rate US Customs and Border Protection (CBP) collects today. Run the three questions below against your own Harmonized Tariff Schedule (HTS) code, or send them through the Terra Vista contact page for a written exposure sheet.
Key points
- Four dates reset the baseline in 2026: a Supreme Court ruling on 20 February that the International Emergency Economic Powers Act (IEEPA) does not authorize tariffs, a 10% stand-in on nearly all trading partners from 24 February, a Section 232 metals rewrite from 6 April, and a new Section 301 tariff from 24 July.
- Section 232 and Section 301 can both apply to the same product. CBP’s Unstacking Chart (January 2026) covers only Section 232 and IEEPA and has no Section 301 column, so use the stacking rules below to combine them.
- Some widely repeated numbers are out of date. As of 3 October 2026, the “15%” rate under the US-Japan agreement still applies to passenger vehicles and parts but no longer to general goods. Since 24 July 2026 Japanese general goods have paid the new Section 301 tariff, which tops the most-favored-nation (MFN) duty up to 12.5%.
- The three questions stay the same even when the measures behind them change: coverage, then origin and content, then buy, wait or switch.
Why this method was proposed
A list of “current tariff rates” is only current until the next proclamation, court ruling or statutory deadline. Between February and July 2026, the legal basis for the largest US tariff programme changed twice, and a metals programme was rebuilt in between:
| Date | Change | Detail | Source |
|---|---|---|---|
| 20 Feb 2026 | US Supreme Court rules IEEPA does not authorize the tariffs | Learning Resources, Inc. v. Trump, consolidated with Trump v. V.O.S. Selections (Nos. 24-1287 & 25-250), decided 6-3; the ruling covers both the “fentanyl” tariffs and the “reciprocal” tariffs built on the same authority | Supreme Court opinion, 20 Feb 2026 |
| 24 Feb 2026 | CBP stops collecting IEEPA tariffs; a Section 122 surcharge of 10% on nearly all trading partners begins the same day | Section 122 of the Trade Act of 1974 caps this surcharge at 150 days by statute | CBP CSMS 67834313; CSMS 67844987; Federal Register (Section 122 proclamation) |
| 6 Apr 2026 | Section 232 tariffs on steel, aluminium and copper move to a full-customs-value basis | Each HTS line’s rate now depends on the annex list it appears on: 50% for Annex I-A, 25% for Annex I-B, with lower 15% and 10% tiers for some goods. The coverage table below gives the detail | White House proclamation, 2 Apr 2026; Federal Register |
| 24 Jul 2026 | The 150-day Section 122 surcharge expires; a new Section 301 “forced labor” tariff takes effect the same day | Covers 60 economies at 10% or 12.5%; China is confirmed at 12.5% | White House presidential action, 23 Jul 2026 |
Goods entered for consumption (or withdrawn from warehouse) before 24 July 2026 carried the Section 122 rate; goods entered on or after that date carry the new Section 301 rate where one applies. Goods loaded and in transit before 24 July and entered before 28 July are exempt from the new tariff (CBP heading 9903.05.85). No date has been announced by which this sequence is expected to stop changing, so the method below is built to be re-run against whatever is in force when read, not read once and kept on file.
Which US tariff measures cover my HTS code right now?
Start from your own HTS classification, then check it against each measure below. More than one row can apply to the same product; whether the rates add together is a separate question, covered next.
| Measure | Applies to | Rate | In force since | Source |
|---|---|---|---|---|
| MFN / Column 1 (baseline) | Every imported item, by its own HTS code | Varies by HTS code | Ongoing | USITC Harmonized Tariff Schedule |
| Section 232 – steel, aluminium, copper | Articles and derivatives on the annex lists (I-A, I-B, I-C and III); the HTS list sets the tier, not the product’s actual metal content | Annex I-A: 50% (all steel and aluminium articles, 76 copper HTS lines in HS 7406–7419, some derivatives). Annex I-B: 25% (derivatives; for copper only four HTS lines: 8544.42.10, 8544.42.20, 8544.42.90, 8544.49.10). 10% where at least 85% of the metal in the article, by weight, was melted and poured (steel) or smelted and cast (aluminium, copper) in the US; in Annex I-A only derivative articles qualify, so not steel or aluminium articles or the 76 copper lines. Temporary tiers to 31 Dec 2027 for listed aluminium and steel derivatives such as machinery and equipment: Annex III 15% including MFN (25% for countries without normal trade relations); Annex I-C 25%, or 15% including MFN for Japan, South Korea, the EU and a few other partners. UK goods with at least 95% UK-melted steel or UK-smelted or UK-cast aluminium: 25% (Annex I-A), 15% (Annex I-B). Russian aluminium 200%. Outside HS Chapters 72, 73, 74 and 76, an article with less than 15% of the listed metal by weight pays no Section 232 duty. Refined copper (cathode), copper ore and concentrate, and copper scrap are not covered | Steel and aluminium 50% since 4 Jun 2025; copper 50% (on copper content) since 1 Aug 2025; full customs value and the 25% / 15% / 10% tiers since 6 Apr 2026; Annex I-C, and the 85% threshold for the 10% tier (95% before), since 8 Jun 2026 | White House; Proclamation 11032 |
| Section 232 – passenger vehicles & light trucks | HTS 8703 and related lines | 25% (0% on the US-content share of USMCA-qualifying vehicles); Japan, the EU and South Korea 15% including MFN (Japan: HTS 9903.94.40–43) | Vehicles since 3 Apr 2025, parts since 3 May 2025. Domestic-assembly offset: manufacturers may apply for an offset equal to 3.75% of the MSRP of the vehicles they assemble in the US (5 Apr 2025 to 30 Apr 2030) | Congressional Research Service, IN12545; Proclamation 10984; Federal Register 90 FR 44638 |
| Section 301 – China, existing lists | Goods on Lists 1–3 and List 4A, unless separately excluded | 25% (Lists 1–3); 7.5% (List 4A); higher for strategic sectors: EVs 100%, steel and aluminium products 25%, semiconductors 50%, solar cells 50%, medical gloves 100% from 1 Jan 2026, and others | Ongoing: the first actions took effect on 6 Jul and 23 Aug 2018, and later lists were added. The 2024 four-year review kept the base rates and added or raised duties on strategic sectors. 178 product exclusions run through 9 Nov 2026 (11:59 p.m. EDT). A second statutory four-year review opened on 6 May 2026; as of 3 Oct 2026 Terra Vista Co., Ltd. has found no second-phase notice and no termination notice from USTR, and the Harmonized Tariff Schedule still carries the duties | USTR; Federal Register, 6 May 2026; 89 FR 76581; 90 FR 55232 |
| Section 301 – new “forced labor” tariff | 60 economies named in the July 2026 action | 10% or 12.5% (China: 12.5%). The EU and Taiwan: 10% including MFN. Japan, South Korea and Switzerland: 12.5% including MFN. For those five, the Section 301 duty tops the MFN rate up to that figure and is zero where MFN is already at or above it | 24 Jul 2026 | White House |
If your item is copper, the Section 232 copper tariff procurement guide sets out the semi-finished-product and derivative-article distinction in more detail.
Do Section 232 and Section 301 tariffs stack, or does only one apply?
CBP’s own Unstacking Certain Tariffs Chart states the general rule directly: once an item’s applicable row is found, use that row only, “even if the product in question has materials that may be subject to multiple different tariffs under Section 232 or IEEPA.” The chart describes itself as a reference tool, not a substitute for the underlying proclamations. Its columns cover only Section 232 and IEEPA measures, with none for Section 301 or antidumping and countervailing duties, so it does not settle how Section 232 combines with those.
The chart is dated 28 January 2026, before the 20 February Supreme Court ruling and before the 6 April Section 232 metals rewrite, so parts of it describe a structure that has since changed. The rules in force on 3 October 2026 are:
- Steel, aluminium and copper: an article listed under more than one metal pays the Section 232 metals duty once (Proclamation 11021, clause 9).
- Section 232 metals duties are paid in addition to MFN, antidumping and countervailing duties and other duties and charges (HTSUS note 16(b)). CBP’s filing instructions (CSMS 69326983) put the Section 301 heading first and the Section 232 heading after it on the same entry line, so goods of Chinese origin can pay both. Example: a Chinese-origin steel article on a 25% Section 301 line pays Section 232 at 50% and Section 301 at 25%, plus MFN.
- Articles covered by Section 232 are outside the new Section 301 forced-labor tariff that took effect on 24 July 2026 (HTS 9903.05.90), as they were outside the Section 122 surcharge that ran from 24 February to 23 July 2026.
- Articles under the Section 232 automotive tariffs, including Japan’s 15% rate (HTS 9903.94.40–43), do not also pay the metals duty (CRS IN12545, May 2026).
- Chinese-origin goods outside Section 232 pay MFN and any existing Section 301 duty on their line. They also pay the new 12.5% forced-labor duty unless Annex I or II of the USTR notice exempts the line.
Sources: Proclamation 11021 (clause 9; HTSUS note 16 in its Annex IV); Proclamation 11012; CBP CSMS 69326983 and the USTR notice on the Section 301 forced-labor duties; Congressional Research Service, IN12545.
Is the US-Japan “15%” tariff rate still in effect?
As of 3 October 2026 the answer depends on the product. Federal Register 90 FR 44638 set a baseline that topped up most Japanese goods to a 15% all-in rate where the MFN rate was lower, effective 7 August 2025 for general goods and 16 September 2025 for passenger vehicles and parts. The general-goods rate rested on the same IEEPA “reciprocal tariff” authority that the Supreme Court ruled invalid on 20 February 2026; the vehicle and parts rate sits in the Section 232 automotive tariff (Proclamation 10908).
For general goods, the 15% rate no longer applies. CBP stopped collecting IEEPA tariffs on goods entered on or after 24 February 2026 (CSMS 67834313). From 24 February to 23 July 2026 a 10% Section 122 surcharge applied to most goods on top of MFN. Since 24 July 2026 the new Section 301 tariff applies to Japan at 12.5% including MFN: it tops the MFN rate up to 12.5% and adds nothing where MFN is already 12.5% or more (USTR notice, 91 FR 47318, 47324). USTR calls this cap on total duties consistent with the terms of the Agreements on Reciprocal Trade or similar arrangements (91 FR 47320). Articles covered by Section 232, and articles exempted in the notice’s annexes, do not pay the new tariff.
For passenger vehicles and parts, the 15% all-in rate still applies. It is a Section 232 automotive rate (HTS 9903.94.40–43, since 16 September 2025), so the 20 February 2026 ruling does not reach it. The Congressional Research Service (May 2026) reports a 15% total tariff on auto imports from Japan, the EU and South Korea.
Check the current rate against CBP’s CSMS announcements and the Federal Register before quoting a number for a Japan-origin item.
How to use this table
- Look up your item’s HTS code and check it against every row in the coverage table above; more than one measure can apply.
- Confirm origin under the substantial-transformation standard and, for Section 232 metal articles and derivatives, the listed metal’s share of the article’s weight (the 15% test and the 85% US-metal test) and the smelt/cast country (for steel, the melt-and-pour country); see the table below.
- Check how your measures combine using the stacking rules above, and leave any rate you have not confirmed for your own HTS line out of the total.
- Decide buy now, wait, or switch sourcing using the decision table below, then re-check at the next dated event: 9 November 2026, when the 178 China Section 301 exclusions expire, or 31 December 2027, when the temporary Section 232 tiers end.
| Item | Rule | Since | If not declared | Source |
|---|---|---|---|---|
| Any product | Origin generally follows the “substantial transformation” test (new name, character or use); simple or minimal assembly usually does not qualify. A separate marking rule (19 CFR Part 102) can give a different answer for labelling purposes than for tariff purposes, on the same goods. | Long-standing standard | Origin defaults to the country of the last transformation CBP accepts as substantial | CBP Informed Compliance Publication |
| Aluminium and aluminium derivatives | Declare the primary (and any secondary) country of smelt and the country of most recent cast | Required since 12 Mar 2025 | For derivatives, an unknown country is reported as “UN” and the 200% Russian-aluminium rate applies, from 28 Jun 2025 | CBP CSMS 64384496; CSMS 65340246 |
| Steel and steel derivatives | Declare the country of melt-and-pour; for derivatives, the country where the steel was originally melted, or “OTH” for other countries | Required since 12 Mar 2025 | Reporting is mandatory; the CSMS sets no separate duty rate for a missing code | CBP CSMS 64384423 |
| Copper articles under HTS 8544.42.10, 8544.42.20, 8544.42.90, 8544.49.10 (insulated wire and cable) | Declare primary smelt country and cast country in ACE (secondary smelt optional) | Required from 30 Jul 2026 (CSMS #69252300, issued 15 Jul 2026) | Entry rejected in ACE from 14 Sep 2026 (CSMS #69711865) if not filed; “OTH” allowed if genuinely unknown | CBP CSMS #69252300 |
Note the scope of the copper rule: it names four specific HTS codes for insulated wire and cable. On its own text it does not extend to every copper article — check your own HTS code against the CSMS notice rather than assuming it applies.
| Check | Favors buy now | Favors wait | Favors switching sourcing |
|---|---|---|---|
| Where you sit on the timeline above | A measure affecting you is already in force with no announced successor | A measure affecting you is scheduled to expire or step down soon | A measure affecting you has no expiry and already stacks with another in force |
| Inventory coverage | Under about one month of cover | One to three months of cover, with a dated event ahead | Repeated exposure across order cycles, not a one-off |
| Price pass-through | Contract already lets you pass the tariff cost through | Contract review is under way | Contract has no pass-through clause and renegotiation is slow |
| Alternate-source readiness | No qualified alternate source exists yet | An alternate source is being qualified | An alternate source is already qualified and compliant |
Worked example (fictional product)
Example only, using figures confirmed above as of 3 October 2026 — not a real customs filing. A fictional buyer is sourcing a copper pipe fitting, close to 100% copper content, melted and cast in China, machined and assembled in China, for direct export to the United States.
| Layer | What decides it | This example | Status |
|---|---|---|---|
| MFN / Column 1 | Exact 8/10-digit HTS classification | Not looked up for this example | Unconfirmed — treat as a variable, not zero |
| Section 301 (China, existing lists) | Whether the HTS code sits on List 1–3 (25%) or List 4A (7.5%), and whether it is one of the 178 exclusions (164 earlier-extended exclusions plus 14 solar-manufacturing equipment lines) that run through 9 Nov 2026 | Neither the exclusions nor the list was checked against the official schedule for this example | Unconfirmed; 25% or 7.5% if the line is listed and not excluded |
| Section 232 (copper) | Whether the HTS line is on Annex I-A (50%) or Annex I-B (25%); the 15% weight test does not apply to HS Chapter 74 | A copper pipe fitting falls under HS 7412 (7412.10.00 or 7412.20.00), which is on Annex I-A, so Section 232 applies at 50% of the full customs value | Covered; 50% |
| New Section 301 (forced labor) | Whether the item is also covered by Section 232 | Section 232 already covers this item, and Section 232-covered goods are excluded from the new Section 301 tariff | Excluded, on the stacking rule above |
| Origin declaration (smelt/cast) | Whether the item’s HTS code is one of the four copper codes named in CSMS #69252300 | No: the fitting is in HS 7412, and all four named codes are insulated wire and cable in HS 8544 | Not required under this CSMS; a compliance step, not a rate |
Total: not calculable from confirmed figures. What is confirmed is that the fitting pays Section 232 copper at 50% on its full customs value and is excluded from the new Section 301 tariff. A specific total would still need the exact MFN rate and a check of whether the line sits on List 1–3 or List 4A or is excluded: the lookups the first question of this method exists to force.
Common practice and how this method differs
| Decision | Common practice | Tariff Exposure Table |
|---|---|---|
| Finding “the rate” | Copy a rate from the first search result or an older article | Re-run the three questions against the dated timeline above and the item’s own HTS code |
| Handling stacking | Assume every applicable measure adds up, or assume only one ever applies | Apply the stacking rules above to your combination of measures; the CBP chart covers only Section 232 and IEEPA and is dated 28 January 2026 |
| Handling changed rates (e.g. Japan’s current rate) | Repeat a headline figure such as “15%” carried over from before 20 February 2026 | Check the figure against CBP CSMS and the Federal Register and write the date next to it |
Official sources to check first
- Federal Register: publishes the proclamations and executive orders that set each rate and effective date.
- CBP Cargo Systems Messaging Service (CSMS): CBP’s own notices on entry filing, declaration codes and enforcement dates.
- Office of the US Trade Representative: Section 301 investigations, lists and exclusions.
- The White House: presidential proclamations and actions under Section 232 and Section 301.
- Supreme Court of the United States: opinions, including the 20 February 2026 IEEPA ruling.
- USITC Harmonized Tariff Schedule: look up the MFN / Column 1 rate for your own HTS code.
What Terra Vista does with this table
Terra Vista Co., Ltd. runs the Tariff Exposure Table as a first step, then delivers a Tariff exposure sheet within 3 business days: which measures cover the item, the origin-determination points that matter for it, and a cost comparison across the buy-now, wait and switch-sourcing options, prepared by a trilingual team across English, Japanese and Chinese.
Frequently asked questions
What is the Tariff Exposure Table?
The Tariff Exposure Table is a three-question method proposed by Terra Vista Co., Ltd. in 2026, used to check which US tariff measures cover an imported item, how those measures combine, and whether the next move is to buy now, wait, or switch sourcing.
Do Section 232 and Section 301 tariffs stack on the same product?
Sometimes. Within steel, aluminium and copper, an article pays the Section 232 metals duty once, even if it is listed under several metals. Section 232 metals duties are paid in addition to MFN, antidumping and countervailing duties and other duties and charges; goods of Chinese origin can also carry the existing Section 301 duties. For example, a Chinese-origin steel article on a 25% Section 301 line pays Section 232 at 50% and Section 301 at 25%, plus MFN. Articles covered by Section 232 are outside the new Section 301 forced-labor tariff.
Is the US-Japan 15% tariff rate still in effect?
It depends on the product. As of 3 October 2026, general goods no longer carry the IEEPA-based 15% all-in rate: IEEPA tariffs stopped being collected on 24 February 2026, and since 24 July 2026 the new Section 301 tariff tops the MFN rate on most Japanese goods up to 12.5% and adds nothing where MFN is already 12.5% or more. Passenger vehicles and parts still carry a 15% all-in rate (HTS 9903.94.40–43) under Section 232. Check CBP CSMS announcements and the Federal Register before quoting a number for a Japan-origin item.
What metal details must I declare for Section 232, and what happens if the smelt/cast country isn’t declared?
Since 6 April 2026 the duty applies to the full customs value, so metal content no longer sets the tax base. It matters through two weight tests: outside HS Chapters 72, 73, 74 and 76, an article with less than 15% of the listed metal by weight pays no Section 232 duty, and at least 85% US-melted or US-smelted-and-cast metal can bring a derivative article down to 10%. Aluminium importers declare the countries of smelt and cast, and steel importers the country of melt-and-pour, since 12 Mar 2025. For aluminium derivatives, reporting “UN” for an unknown country brings the 200% Russian-aluminium rate from 28 Jun 2025. For four copper HTS codes (8544.42.10, 8544.42.20, 8544.42.90 and 8544.49.10) the primary country of smelt and the country of cast must be declared in ACE from 30 Jul 2026, and ACE rejects entry summaries without them from 14 Sep 2026 (“OTH” is allowed if a country is unknown).
Should I buy now, wait, or switch sourcing?
Check where you sit on the dated timeline, your inventory coverage in months, whether your contract lets you pass the tariff cost through, and whether an alternate source is already qualified and compliant. Buy now favors a measure already in force with no announced successor; wait favors one expiring soon; switching favors repeated exposure with no pass-through clause.
Related pages
Related: Section 232 copper tariff procurement guide; copper procurement timing, H2 2026; China Plus One: where Japan fits; supply chain sourcing services; named methods overview; Terra Vista contact page.
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