9903.05.25 Explained: Bahrain Section 301 Forced Labor, 12.5% Duty

Key Points

• HTS 9903.05.25 imposes an additional 12.5 percent ad valorem duty on all Chapter 1-97 products originating in Bahrain, effective 2026-07-24, with no announced end date.
• The duty is authorized by the USTR Section 301 forced labor final action dated 2026-07-23, implemented under U.S. note 52 to Chapter 99, and confirmed in CSMS 69326983.
• The code covers all products of Bahrain regardless of HTS chapter, meaning no product category is carved out unless a subsequent ruling or notice says otherwise.
• 9903.05.25 is reported as a secondary Chapter 99 line alongside the primary Chapter 1-97 classification on every CBP entry summary for covered goods.
• Do not confuse this code with 9903.05.01 through 9903.05.09, which are Section 301 Brazil codes under a different program with different rates and authority.

On this page

1. What 9903.05.25 is and who must care
2. Legal authority and program background
3. Product and country scope
4. Rate and effective window
5. How 9903.05.25 stacks with other duties
6. How to report this code on a CBP entry
7. What importers should do
8. Key references

HTS 9903.05.25 is the Chapter 99 classification that adds 12.5 percent to the duty bill for every shipment of Bahrain-origin merchandise entered on or after 2026-07-24. It applies to all goods classifiable in Chapters 1 through 97 of the HTSUS and is part of the Section 301 forced labor program governed by U.S. note 52 to Chapter 99. Any importer, customs broker, or trade attorney handling Bahrain-origin goods needs to account for this additional charge on every entry filed from that effective date forward.

The links in this article go to the primary documents: the USTR final action, CSMS notice, and official tariff schedule pages themselves. Read the source. The facts below reflect the tariff schedule as of August 2026.

What 9903.05.25 is and who must care

9903.05.25 is one heading within the Section 301 forced labor action country range, which runs from 9903.05.20 through 9903.05.84. Each heading in that range corresponds to a specific country subject to additional duties based on USTR's forced labor investigations under Section 301 of the Trade Act of 1974. 9903.05.25 is assigned to Bahrain (country code BH).

If you import any merchandise that is a product of Bahrain, this code applies to you. There is no threshold, no minimum value, and no carved-out product list based on the facts available as of August 2026. Confirm current Chapter 99 notes in the official HTSUS at hts.usitc.gov before filing.

Importers sourcing goods through third countries should be especially careful: origin is determined by CBP rules of origin, not the country from which goods are shipped. If a product is a product of Bahrain under those rules, 9903.05.25 applies regardless of where the vessel departed.

Legal authority and program background

The duty was established by the USTR Section 301 forced labor final action dated 2026-07-23, implemented under U.S. note 52 to Chapter 99 of the HTSUS. CBP operationalized the code through CSMS 69326983. The program is distinct from the Section 301 tariffs on China and from the Section 301 Brazil program found at 9903.05.01 through 9903.05.09, which operate under different authority and different rates.

U.S. note 52 governs the entire 9903.05.20-through-9903.05.84 country heading block. That note defines which goods are covered, how origin is assessed for purposes of this action, and any interaction with other Chapter 99 provisions. Obtain the current text of U.S. note 52 directly from hts.usitc.gov, as note text can be amended without a change to the heading number itself.

For comparison, see how the same 12.5 percent rate applies to similarly situated country codes in this program: 9903.05.21 Angola, 12.5% and 9903.05.23 Australia, 12.5%.

Product and country scope

Country

The sole country in scope for 9903.05.25 is Bahrain (BH). No other country is covered by this heading. Other countries subject to the Section 301 forced labor action carry their own heading numbers within the 9903.05.20-9903.05.84 range.

Products

Per U.S. note 52(a), the duty applies to all products classifiable in Chapters 1 through 97 of the HTSUS that are products of Bahrain. There is no published exclusion list or positive product list specific to this code in the facts available as of August 2026. If you believe a product may be excluded or if you are uncertain whether a specific article qualifies as a product of Bahrain under CBP origin rules, confirm with your broker or verify against the current HTSUS notes.

The breadth here is significant: agricultural goods, manufactured articles, industrial inputs, consumer goods, and textiles are all within scope if they originate in Bahrain. No HTS chapter in the range 1-97 is excluded on the face of this provision.

Rate and effective window

The additional duty rate is 12.5 percent ad valorem. This rate applies to the dutiable value of the imported merchandise, the same customs value used to calculate the regular Chapter 1-97 duty. The rate is effective from 2026-07-24 onward. There is no announced end date. Until a subsequent USTR or CBP notice modifies or terminates the action, the 12.5 percent additional duty remains in effect for every entry of Bahrain-origin goods.

Goods entered or withdrawn from warehouse for consumption before 2026-07-24 are not subject to this additional duty. Entries filed on or after 2026-07-24 are subject to the full 12.5 percent regardless of when the goods were manufactured or shipped.

How 9903.05.25 stacks with other duties

The 12.5 percent is an additional duty. It is assessed on top of, not instead of, the regular Most Favored Nation (MFN) rate from the primary Chapter 1-97 classification. The combined duty obligation on a Bahrain-origin shipment is:

• The Column 1 (MFN) rate for the primary HTS heading, plus
• 12.5 percent under 9903.05.25, plus
• Any other applicable Chapter 99 additional duties (for example, Section 232 metals duties, if separately applicable), plus
• Any antidumping or countervailing duties assessed on the specific product and producer.

The facts block does not specify any MFN cap that limits the 9903.05.25 rate for Bahrain. Some other country headings in the Section 301 forced labor program are MFN-capped; confirm whether any cap applies to a specific product by reviewing the current text of U.S. note 52 at hts.usitc.gov.

Stacking can significantly change landed cost. Use a duty calculator to model the combined rate before committing to supplier pricing. See the CustomsGenius duty calculator for a quick stacking estimate, and review our 2026 tariff code overview for context on other Chapter 99 changes this year.

How to report this code on a CBP entry

Chapter 99 codes like 9903.05.25 are reported as a second HTS line on the entry summary, directly below the primary Chapter 1-97 classification for each affected line item. The primary line carries the regular duty; the Chapter 99 line carries the additional 12.5 percent. Both lines reference the same entered value.

CBP's ACE system requires a specific HTS reporting order for Chapter 98 and 99 codes. Review CBP's guidance on ACE HTS reporting order for Chapter 98 and 99 classifications to confirm the correct sequencing for your entry type. Errors in reporting order can cause ACE rejections or post-entry compliance issues.

The CSMS message 69326983, available through cbp.gov, contains CBP's operational instructions for this action, including ACE implementation details. Brokers should review that message before filing the first entry after 2026-07-24.

What importers should do

• Audit open and upcoming shipments. Identify all purchase orders for Bahrain-origin goods with arrival or entry dates on or after 2026-07-24, recalculate landed cost using the combined MFN plus 12.5 percent rate, and adjust financial provisions accordingly.
• Verify origin documentation. Confirm that suppliers can provide origin documentation sufficient to support a country of origin determination; where origin is ambiguous, obtain a binding ruling from CBP before filing.
• Review U.S. note 52 text directly. Pull the current Chapter 99 notes from hts.usitc.gov to check for any exclusions, caps, or amendments not yet reflected in secondary sources, and review CSMS 69326983 at cbp.gov for ACE filing instructions.
• Update broker instructions. Ensure your customs broker's classification and entry filing procedures include 9903.05.25 as a secondary line for all Bahrain-origin entries filed from 2026-07-24 forward, and confirm correct HTS reporting order in ACE.

Key references

• Harmonized Tariff Schedule of the United States, hts.usitc.gov - Official text of HTS heading 9903.05.25 and U.S. note 52 to Chapter 99.
• CBP CSMS 69326983 - CBP operational guidance and ACE implementation instructions for the Section 301 forced labor action on Bahrain.
• Federal Register, federalregister.gov - Search for the USTR Section 301 forced labor final action of 2026-07-23 for the full regulatory record.
• Office of the United States Trade Representative, ustr.gov - USTR Section 301 forced labor final action dated 2026-07-23, the originating agency determination.
• 19 U.S.C. 2411, law.cornell.edu - Section 301 of the Trade Act of 1974, the statutory authority for this action.
• 9903.05.21 Angola Section 301 Forced Labor, 12.5% Duty - Related country heading in the same program and rate tier.
• 9903.05.23 Australia Section 301 Forced Labor, 12.5% Duty - Related country heading in the same program and rate tier.
• CBP Updates ACE HTS Reporting Order for Chapter 98 and 99 Classifications - Guidance on correct sequencing of Chapter 99 codes on ACE entry summaries.