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9903.05.28 Cambodia Section 301 Forced Labor: 10% Duty

Published: September 1, 2026  ·  7 min read
9903.05.28 Cambodia Section 301 Forced Labor: 10% Duty
Photo: Quang Nguyen Vinh / Pexels

Key Points

On this page

  1. What this code is and who must care
  2. Legal authority and program background
  3. Product and country scope
  4. The 10 percent rate and its effective window
  5. How 9903.05.28 stacks with other duties
  6. How the code appears on a Customs entry
  7. What importers should do
  8. Key references

The links in this article go to the primary documents: the USTR final action, CSMS messages, and official tariff schedule pages themselves. Read the source.

HTS 9903.05.28 is a Chapter 99 classification that adds 10 percent ad valorem to the duty bill for every product of Cambodia entering the United States, under the Section 301 Forced Labor action that took effect July 24, 2026. Any importer whose goods originate in Cambodia, and any broker preparing those entries, must add this code to every affected line. The rate has no announced expiration as of September 1, 2026.

What this code is and who must care

Chapter 99 of the Harmonized Tariff Schedule of the United States is reserved for temporary and special-purpose duty provisions. Code 9903.05.28 sits within the heading range 9903.05.20 through 9903.05.84, which carries the Section 301 Forced Labor program country headings. Each heading in that range is country-specific; 9903.05.28 is assigned to Cambodia.

If your goods are manufactured in, or determined to originate from, Cambodia, this code applies to your entry regardless of the product category. Importers of Cambodian apparel, footwear, electronics, furniture, seafood, and any other merchandise in Chapters 1 through 97 are all within scope.

Customs brokers should flag all Cambodian-origin entries dated on or after July 24, 2026. Entries filed before that date are not subject to the additional duty based on the facts available as of September 1, 2026; confirm current CBP guidance for any edge cases.

Legal authority and program background

The Section 301 Forced Labor program is a trade action under Section 301 of the Trade Act. USTR issued its final action on July 23, 2026, and the duty became effective the following day, July 24, 2026. The operative tariff provision is U.S. note 52 to Chapter 99, which governs the full country-heading range for this program.

CBP operationalized collection through CSMS 69326983. Importers and brokers should pull that CSMS message directly to verify entry instructions, line-level reporting requirements, and any ACE system guidance.

Important distinction: codes 9903.05.01 through 9903.05.09 are Section 301 Brazil, an entirely different program with different legal underpinnings and different product scope. Do not confuse that block with the Section 301 Forced Labor block beginning at 9903.05.20. See also our coverage of other country headings in this program: 9903.05.26 Bangladesh (10%) and 9903.05.22 Argentina (10%).

Product and country scope

Country of origin

The duty applies to products of Cambodia (ISO country code KH). Country of origin is determined under CBP's standard substantial transformation rules. If your supply chain sources components from Cambodia but finishes goods elsewhere, confirm origin with your broker before assuming the duty does or does not apply. Transshipment through a third country does not change the country of origin if Cambodia is still the country of substantial transformation.

Sourcing shifts and circumvention concerns for this type of program are addressed in our article on AD/CVD Circumvention: Legal Sourcing Shifts vs. Evasion, which covers analogous fact patterns.

Product scope

U.S. note 52(a) covers all Chapter 1 through 97 products of Cambodia. No product category is carved out of scope in the facts available as of September 1, 2026. If you believe a specific product may be excluded or if your goods are classified under a Chapter 98 or Chapter 99 provision that could affect treatment, confirm in the current HTSUS or with a broker.

The 10 percent rate and its effective window

The official heading text for 9903.05.28 reads: Products of Cambodia, Section 301 forced-labor action, U.S. note 52: +10% ad valorem.

The rate is 10 percent additional ad valorem, applied on top of any other applicable duties. It has been in effect since July 24, 2026, and no end date has been announced as of September 1, 2026. Unlike some other country headings in the 9903.05.20 through 9903.05.84 range that carry a 12.5 percent rate (see, for example, 9903.05.25 Bahrain at 12.5%), Cambodia's rate is set at 10 percent.

The facts block does not reference any MFN cap for this code. Confirm with your broker whether any cap applies to your specific subheading before filing.

How 9903.05.28 stacks with other duties

The 10 percent Section 301 Forced Labor duty is additive. It stacks on top of:

The facts block does not specify an MFN cap for 9903.05.28. If your product carries a high MFN rate, verify whether any cap mechanism in U.S. note 52 limits the combined duty exposure. Use a duty calculator to model the full stacked rate for your specific classification, and review the 2026 tariff code overview for context on other new Chapter 99 provisions.

How the code appears on a Customs entry

Chapter 99 codes never replace your Chapter 1 through 97 classification. On an ACE entry summary, the Cambodian-origin line will carry two HTS numbers:

  1. The regular classification from Chapters 1 through 97 (for example, a specific textile subheading under Chapter 61).
  2. 9903.05.28 as a secondary, Chapter 99 line, triggering the additional 10 percent duty.

The duty is assessed on the customs value of the merchandise. CBP's ACE system uses the CSMS guidance in CSMS 69326983 to validate that entries include the correct Chapter 99 code. Entries that omit 9903.05.28 for Cambodian-origin goods entered on or after July 24, 2026, are at risk of a CBP rate advance. Review CBP CSMS messages for the most current entry instructions.

What importers should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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