US Manufacturer's Playbook

Export Components to China for Assembly: How the 2026 Duty Stack Actually Works

By Emma Smith · Published 2 September 2026 · 15 min read

Export components to China for assembly and import them back to the USA — 2026 duty stacking guide by Trade Globe Consultants

Send components to China for assembly and bring the finished product back, and you're not paying one tariff — you're paying a stack of them layered on top of each other, and getting that stack wrong is the single most expensive mistake we see manufacturers make with China-based assembly. This guide breaks down exactly which duties apply, in what order, whether the HTSUS 9802.00.80 exemption still helps once Section 301 is layered on top, and the specific China-only rules — like the loss of the $800 de minimis exemption — that don't apply anywhere else in the world.

TL;DR — Exporting Components to China for Assembly in 2026

When you export components to China for assembly and import the finished product back, duty is calculated by stacking multiple layers on top of each other, not applying a single rate:

MFN base duty — the standard rate for the product's HTS classification, same as any country
Section 301 tariff — 7.5% to 100% depending on the product's tariff list, unaffected by the February 2026 Supreme Court ruling on IEEPA tariffs
Section 122 surcharge — a 10% flat rate that replaced the earlier reciprocal tariffs after that ruling
Section 232 tariff — applies on top if the product falls under steel, aluminum, or another covered category
HTSUS 9802.00.80 still works — CBP's own FAQ confirms all of these additional duties apply only to the value of the article less the cost of qualifying U.S. components, so the exemption's dollar value is actually larger in China's high-duty environment than almost anywhere else
The $800 de minimis exemption no longer applies to goods from China or Hong Kong — every shipment is dutiable regardless of declared value
178 Section 301 product exclusions remain active through November 10, 2026 under the U.S.–China agreement reached at the November 2025 Trump–Xi summit

Key Takeaways

What manufacturers need to know before sending components to China

Section 301 tariffs on China were completely unaffected by the February 2026 Supreme Court ruling that struck down IEEPA reciprocal tariffs — they remain the dominant cost driver.
A single product assembled in China can carry four or five duty layers simultaneously, and missing even one in your landed-cost estimate throws off your entire pricing.
The HTSUS 9802.00.80 deduction applies to every layer stacked on the assembled article, not just the base MFN rate — CBP's Section 301 FAQ confirms this directly.
China and Hong Kong lost the $800 de minimis exemption in 2025; every other country's low-value shipments can still qualify.
Section 301 exclusions are product-specific and time-limited — 178 are active through November 10, 2026, with no guarantee of further extension.
Sending export-controlled components to China for assembly can trigger a separate export licensing requirement entirely apart from the import duty question.

What does it mean to export components to China for assembly and import them back?

Exporting components to China for assembly means shipping U.S.-made or U.S.-sourced parts to a Chinese contract manufacturer, having them built into a finished product, and reimporting that finished article into the United States — a structure that triggers both U.S. export rules on the way out and a stacked set of import duties on the way back.

This is functionally the same supply chain structure covered in our guide on how to avoid paying duty twice when manufacturing overseas — export components, assemble abroad, reimport the finished good. What changes when China is the assembly location isn't the underlying mechanics, it's the duty environment those mechanics operate inside. The same 9802.00.80 exemption that works cleanly in a low-tariff country gets layered on top of Section 301, Section 122, and potentially Section 232 duties when the assembly happens in China specifically.

How much duty do you actually owe when importing products assembled in China?

Duty on a product assembled in China is calculated by adding the MFN base rate, the Section 301 tariff for that product's list, a 10% Section 122 surcharge, and — for certain product categories — a Section 232 tariff on top, all applied to the same dutiable value.

← Swipe to see all columns →

Duty layer	Typical rate	Applies to
MFN base duty	0–20%, product-dependent	Standard classification rate, same in any country
Section 301 tariff	7.5%–100%	China-origin goods on USTR's List 1, 2, 3, or 4A
Section 122 surcharge	10% flat	Replaced reciprocal/IEEPA tariffs after the Feb 2026 Supreme Court ruling
Section 232 tariff	25%–50%, product-dependent	Steel, aluminum, autos, and other covered categories only

Here's what most sourcing guides get wrong about this stack: they quote Section 301 as "the" China tariff, as if it's the only extra layer. It isn't. A product on Section 301 List 1 (25%) that also happens to be steel-adjacent could realistically carry MFN (say 3%) + Section 301 (25%) + Section 122 (10%) + Section 232 (25%) — pushing the effective rate above 60% before you've accounted for anything specific to your assembly structure. Landed-cost estimates built on Section 301 alone are routinely off by 20 to 35 percentage points.

Not sure what your actual duty stack looks like?

Get a full landed-cost breakdown before you commit to a China assembly partner

We map your specific HTS code against every applicable duty layer — MFN, Section 301, Section 122, and Section 232 where relevant — so your pricing model reflects the real number, not just the headline tariff rate. No charge for the initial review.

Explore export consulting →

Does HTSUS 9802.00.80 still work for products assembled in China?

Yes — CBP's own Section 301 FAQ confirms that all of these additional duty layers apply to the value of the article assembled abroad minus the cost of the qualifying U.S. components, exactly the same reduced base the 9802.00.80 exemption always uses, not to the full value of the finished article.

This is the detail almost every general "how to save on China tariffs" article misses entirely. The 9802.00.80 deduction doesn't just reduce your MFN duty — it reduces the base that Section 301, Section 122, and Section 232 all get calculated against too. For the full mechanics of how the three-part qualifying test works, see our dedicated guide on the HTSUS 9802.00.80 duty exemption; the eligibility rules don't change based on the assembly country.

← Swipe to see all columns →

Scenario	Dutiable value	Combined rate (example)	Duty owed
No 9802.00.80 claim	$60,000 (full article value)	38.5% (MFN 3.5% + Sec 301 25% + Sec 122 10%)	$23,100
9802.00.80 claimed correctly	$12,000 (assembly value only)	38.5%	$4,620
Duty avoided by claiming the exemption	$48,000	—	$18,480

The contrarian point most guides miss

Most sourcing content treats China's duty stack as a pure downside compared to lower-tariff countries. It's more complicated than that. Because 9802.00.80 shields the U.S. component value from every layer in the stack, not just one flat MFN rate, the exemption is worth proportionally more in China's high-duty environment than in a country where the total rate might be 5%. A manufacturer with heavy U.S.-made content assembled in China can end up with a smaller effective duty gap versus a lower-tariff country than the headline Section 301 rate would suggest — provided the components genuinely qualify under all three conditions of the test.

Does the $800 de minimis exemption still apply to goods from China?

No. The $800 de minimis exemption under Section 321 no longer applies to goods originating in or shipped from China and Hong Kong, following a 2025 executive order — every shipment from China is dutiable regardless of its declared value, while low-value shipments from most other countries can still qualify.

This is a China-specific rule that doesn't show up in general "how to avoid duty twice" guidance, and it matters most for businesses that also fulfill direct-to-consumer orders alongside B2B assembly shipments. CBP replaced the old de minimis treatment for low-value China parcels with a flat alternative tariff structure rather than simply removing the exemption outright, so the practical impact varies by shipment type and value. If your China-based operation includes any direct-to-consumer fulfillment, confirm current treatment before assuming last year's cost structure still holds.

What's the process to export components to China for assembly and reimport the finished product?

The process runs through six stages: confirming your components meet the 9802.00.80 test, checking export control requirements, filing export documentation, coordinating the assembly with your Chinese partner, and filing the reimport entry with the correct Chapter 99 classifications.

Confirm 9802.00.80 eligibility component by component. Every part must meet the three-part test — exported ready for assembly, no loss of physical identity, no advancement beyond assembly or incidental operations.
Check export control classification before you ship. Some components require a Commerce Department license before they can legally go to a Chinese destination, entirely separate from any customs duty question.
File Electronic Export Information (EEI) through AES. Required for most commercial shipments regardless of value; get the Internal Transaction Number before the shipment leaves.
Obtain the Assembler's Declaration from your Chinese manufacturer. This documents that only assembly and incidental operations occurred, supporting the 9802.00.80 claim on reimport.
Determine your correct Section 301 list and Chapter 99 code. Look up your specific 8-digit HTS classification to confirm which list applies and whether an active exclusion covers your product.
File the reimport entry with every applicable Chapter 99 overlay. A single entry may need separate Chapter 99 codes for Section 301, Section 122, and — if applicable — Section 232, layered correctly on top of the 9802.00.80 base reduction.

For the export-side documentation specifically, our guide on what is AES filing walks through the full electronic filing process and the penalty exposure for getting it wrong. On the reimport side, a shipment moving through West Coast ports has its own procedural quirks worth knowing in advance — see our breakdown of Los Angeles import customs clearance if that's your primary gateway.

Setting up a China assembly operation?

Get the export licensing and duty-stack setup right from the first shipment

From export control screening before components leave the U.S. to correctly layering Section 301, Section 122, and 9802.00.80 on reimport, our team builds a compliance structure that holds up under a CBP review — not just one that works until you're audited.

See export consulting services → See import consulting services

Can your product qualify for a Section 301 exclusion?

Maybe — 178 product-specific exclusions from Section 301 tariffs remain active through November 10, 2026 under the U.S.–China trade agreement reached at the November 2025 Trump–Xi summit, but there's currently no open process to request a new one.

If your product's 8-digit HTS code falls under one of the existing exclusion provisions, you claim it by entering the relevant Chapter 99 exclusion code on your entry summary — it must be valid on the date of importation, not the date you placed the order. Because these exclusions are a negotiated feature of an ongoing trade relationship rather than a permanent rule, treat November 10, 2026 as a real deadline to plan around, not a formality. Products that lose exclusion coverage after that date go back to full Section 301 rates with no transition period guaranteed.

Components or finished goods that involve export-controlled technology add another layer of complexity entirely separate from tariff exclusions — our export certification guide covers what triggers a licensing requirement before goods can legally leave the U.S. for a Chinese destination.

Is exporting components to China for assembly still worth it in 2026?

It depends entirely on whether your components genuinely qualify for the 9802.00.80 exemption and whether your product falls under a Section 301 exclusion — for manufacturers who check both boxes, China assembly can still pencil out; for those who don't, the combined duty stack often makes another country the better call.

China assembly still makes sense when: your U.S. component content is high, your product qualifies for a Section 301 exclusion, or your Chinese partner offers assembly capabilities you genuinely can't replicate elsewhere at comparable quality.
Reconsider China assembly when: your product carries no exclusion, sits on a high-rate Section 301 list, and also triggers Section 232 — the stacked total can exceed 60% before freight and other landed costs.

Manufacturers weighing alternatives increasingly compare China against Mexico or Canada, where CUSMA preferential treatment can eliminate duty entirely on qualifying goods rather than just reducing the base. Our guide on exporting to Canada covers how that comparison actually plays out for manufacturers considering a shift in assembly location.

"The manufacturers who get burned by China's duty stack aren't the ones who chose China — they're the ones who priced the shipment using only the Section 301 rate and found out about Section 122 and their 9802 eligibility gap after the entry was already filed."

What mistakes cause manufacturers to overpay on China assembly duty?

Pricing landed cost off Section 301 alone. Missing Section 122, and Section 232 where applicable, routinely understates the real duty by 15–25 percentage points.
Assuming a Section 301 exclusion still applies without checking the date. Exclusions are time-limited and tied to an evolving trade agreement, not a permanent carve-out.
Not claiming 9802.00.80 because "China duties are separate anyway." CBP's own guidance confirms the deduction still reduces the base for every additional layer.
Skipping export control screening on components headed to China. A duty-compliant shipment can still violate export licensing rules entirely separately.
Assuming de minimis treatment on small parcels from China. That exemption no longer exists for China and Hong Kong specifically.
Missing drawback eligibility on the Section 301 portion. Section 301 duties are generally drawback-eligible if the finished goods are later exported, unlike Section 232.

Frequently asked questions about exporting components to China for assembly

What duties apply when you export components to China for assembly and reimport?

Products assembled in China and reimported to the U.S. typically face a stacked duty structure: the MFN base rate, a Section 301 tariff of 7.5% to 100% depending on the product's list, a 10% Section 122 surcharge, and — for certain categories like steel, aluminum, or autos — a Section 232 tariff on top. All of these layers apply to the same dutiable value, unless the shipment qualifies for HTSUS 9802.00.80, in which case they apply to the reduced base instead.

Does HTSUS 9802.00.80 reduce Section 301 tariffs on Chinese-assembled goods?

Yes. CBP's official Section 301 FAQ confirms that for goods entered under heading 9802.00.80, the additional Section 301 duties apply to the value of the assembled article minus the cost of the qualifying U.S. components — the same reduced base used for standard duty. This means the exemption's dollar value is often larger on China-assembled goods than on goods assembled in lower-tariff countries.

Is the $800 de minimis exemption available for goods from China?

No. A 2025 executive order removed the $800 de minimis exemption specifically for goods originating in or shipped from China and Hong Kong, replacing it with an alternative flat tariff structure for low-value parcels. Shipments from other countries can generally still use Section 321 de minimis treatment, but China-origin goods cannot, regardless of declared value.

Were Section 301 tariffs on China affected by the 2026 Supreme Court ruling?

No. The February 2026 Supreme Court ruling struck down the IEEPA-based reciprocal tariffs, which were replaced by a 10% Section 122 surcharge, but it left Section 301 tariffs completely untouched. Section 301 duties predate IEEPA, rest on separate statutory authority under the Trade Act of 1974, and remain the primary duty driver on Chinese-origin goods.

How do I know if my product qualifies for a Section 301 exclusion?

Look up your product's 8-digit HTS code against the current list of active Section 301 exclusions, which covers 178 products through November 10, 2026 under the U.S.–China trade agreement. If your code is covered, you claim the exclusion by entering the relevant Chapter 99 provision on your entry summary, and it must be valid on the date of importation, not the order date.

Can I get a duty drawback refund on the Section 301 portion of a China assembly shipment?

Generally yes. Section 301 duties are typically eligible for duty drawback if the imported components, or products made from them, are later exported or destroyed — unlike Section 232 duties, which are permanently excluded from drawback under CBP guidance. Confirm eligibility for your specific HTS classification before filing, since treatment can vary by product.