What the July 24 tariff change did to ten common parts

On July 24, 2026, the US Trade Representative’s Section 301 action on 60 economies took effect: 12.5% on goods from China and most other economies, 10% on the rest. Two groups are exempt — goods that qualify under a free-trade agreement, and everything already covered by Section 232. It replaced the 10% Section 122 surcharge that had run since February 24, after the Supreme Court struck the IEEPA reciprocal and fentanyl tariffs on February 20 (those amounts became refundable).¹

The headline number understates it for China and overstates it for everyone else. For China, the 12.5% stacks on the list rates in place since 2018–2019: 25% on Lists 1–3, 7.5% on List 4A, nothing on unlisted goods. So a China-origin part now pays MFN plus 37.5 points on List 1–3 headings, plus 20 on List 4A, plus 12.5 if unlisted. For other origins it is MFN plus 12.5% (10% for some) — unless the part is FTA-qualifying, in which case MFN is waived and no Section 301 applies at all. Rule of origin is checked per part, never assumed; a part that fails it pays MFN + 10%.

Here is what that means for ten parts that show up in re-quotes every week. Everything is as of September 26, 2026 and confirmed per HTS code in the re-quote.

How to read the stack

There are four classes of part, and the class matters more than the country.

• Lists 1–3 (most industrial parts). China: MFN + 25% + 12.5% = MFN + 37.5 points. A 12.5% origin: MFN + 12.5. An FTA-qualifying origin: 0%. Gap to the 12.5% origin: 25 points. Gap to the FTA origin: 37.5 points plus MFN.
• List 4A (many consumer goods and some plastics). China: MFN + 7.5% + 12.5% = MFN + 20 points. A 12.5% origin: MFN + 12.5. FTA-qualifying: 0%. Gap to the 12.5% origin: only 7.5 points — a higher factory price eats that quickly.
• Unlisted (headings on List 4B, which was never imposed). China: MFN + 12.5. A 12.5% origin: MFN + 12.5. Identical. Only an FTA-qualifying origin (or one of the 10% economies) changes the duty line; otherwise freight and FOB decide.
• Section 232 metals (since June 8, 2026, through Dec 31, 2027). 50% on articles essentially all steel, aluminum or copper, 25% on derivatives substantially made of them, on full customs value, at any origin. Under 15% metal content is exempt. Section 232 goods do not also pay the 12.5%/10%; the China list rate, where the heading is listed, still applies. An FTA waives MFN, not Section 232.

MFN rates below are approximate for the heading and marked illustrative; list assignments should be verified against your 8-digit code. The two rows marked ★ are the worked examples from our re-quote sheet and use its exact figures.

The ten parts

Read the duty column as cents on a dollar of factory price: the gasket pays 40 cents from China, 15 from a 12.5% origin, nothing from an FTA-qualifying one. The carton pays 37.5 cents, 12.5 cents, nothing. The toy pays 12.5 cents from China and 12.5 cents from a 12.5% origin — the same.

Two rows worked all the way through

The gasket moves. Molded EPDM gasket, HTS 4016.93.50 (MFN 2.5%, List 3), 120,000 units a year, freight to Dallas.

Net saving at the best origin: $23,040 a year, 11% after our fee. The 12.5% origin nets $11,280 (5.4%). The factory price is 15% higher at the winning origin and it does not matter, because the duty line is 40 cents against zero.

The enclosure stays put. Injection-molded PP enclosure, HTS 3926.90.99 (MFN 5.3%, List 4A). It lands $2.77 from China, $2.79 from a 12.5% origin, and $2.50 from an FTA-qualifying origin. Add 10% of FOB at the FTA origin and the net is under 1%. Our recommendation on that part is to stay in China and fix the inspection plan at the factory you already have. (Illustrative inputs that produce those figures: China $2.10 FOB, 25.3% duty, $0.14 freight; the FTA origin $2.45 FOB, no duty, $0.05 freight, $0.25 fee.)

Same buyer, same molding process, same re-quote. One part moves at 11%, the other doesn’t move at all. The difference is a 25% list rate against a 7.5% one and three points of MFN.

What jumps out

Lists 1–3 carry the gap that pays for a move. Harnesses, control boards, molded rubber and industrial plastics on List 1–3 headings pay 37.5 points more from China than from an FTA-qualifying origin, and 25 points more than from a 12.5% origin. A 10–15% higher factory price survives that easily; so does ocean freight from a 12.5% origin. This is where re-quotes land double digits.

Packaging is the quiet one. Printed cartons have a Free MFN rate, so the entire China duty is the 37.5-point add-on, and a 12.5% origin pays a third of it. The constraint on packaging is freight-to-value, not duty — flat-shipped cartons travel well by ocean, rigid boxes want a short transit.

List 4A needs the arithmetic done, not assumed. Mugs, pet beds and many molded consumer parts carry 20 points from China against 12.5 elsewhere. That 7.5-point gap is real money on thin retail margins, and it is also small enough that a higher FOB or a longer freight leg erases it — the enclosure above is the pattern. Against an FTA-qualifying origin the gap is MFN plus 20 points, and then it usually moves.

Unlisted goods: only an FTA origin changes the duty. A List 4B heading pays the same 12.5% from China and from a 12.5% origin. If your part is here, the comparison is FOB and freight, or it is an FTA-qualifying origin with the rule of origin proven per part.

Metal is the honest exception. Section 232 applies at 50% from every origin, and an FTA waives MFN but not 232. For a steel fastener or an aluminum bracket, the remaining difference between origins is the 25% China list rate, freight and lead time. Sometimes a nearer origin wins on the last two; sometimes staying domestic wins on all of them. A re-quote that pretends otherwise is not doing you a favor.

What to do with this

1. Pull the 8-digit HTS code for your top five parts. Your customs broker has it on every entry. Check which Section 301 list each is on — or whether it is unlisted — and whether the heading touches Section 232.
2. Run the landed-cost calculator with your actual FOB and MFN rate. Set the alternative-origin price multipliers to something conservative and see whether the gap survives.
3. If it does, get a real quote. Factory prices, freight quotes and a rule-of-origin check per part will move the number; a double-digit landed gap usually survives contact with reality. That is what the free 10-day re-quote is for.
4. If your part is List 4A or unlisted, ask a different question: not “where is duty lowest” but “is there an FTA-qualifying origin that can hold the spec” — and if not, whether the current factory needs a better inspection plan more than a replacement.
5. If your part is metal, ask a third question: where lead time is shortest and MOQ most flexible for the same total cost. That is a nearshoring question, not a duty question.

Rates change; the method doesn’t. A second Section 301 investigation (excess capacity, 60 economies) opened in March 2026 and is still open, which is why every account gets a quarterly origin review. Every figure above is dated September 26, 2026 and confirmed per HTS code in every quote we produce. If you want the second source without giving up the first, that is a China plus one program.