News

9903.05.32 Colombia Section 301 Forced Labor: 12.5% Duty

Published: September 2, 2026 · 7 min read

Key Points

HTS 9903.05.32 imposes an additional 12.5 percent ad valorem duty on all products of Colombia, effective July 24, 2026, with no announced end date.
The duty applies to all Chapter 1 through 97 products of Colombian origin, meaning no product category is carved out on this code.
Legal authority is the USTR Section 301 Forced Labor Investigation (FLIP) final action dated July 23, 2026, codified under U.S. note 52 of Chapter 99.
CSMS message 69326983 is the CBP operational notice importers and brokers should pull for entry-filing instructions.
This code is separate from the Section 301 Brazil program codes (9903.05.01 through 9903.05.09); do not confuse the two program blocks.

HTS 9903.05.32 is a Chapter 99 overlay code that adds 12.5 percent in additional duties to all Chapter 1 through 97 products of Colombia under the Section 301 Forced Labor Investigation program. It took effect on July 24, 2026, and applies to every Colombian-origin shipment entered on or after that date, regardless of product type. Importers sourcing any goods from Colombia, and the brokers filing their entries, must add this code alongside every regular Chapter 1 through 97 classification line.

What 9903.05.32 is and who needs to care

As of September 2, 2026, HTS 9903.05.32 reads: "Products of Colombia, Section 301 forced-labor action, U.S. note 52: +12.5% ad valorem." That heading text is the official description as it appears in the Harmonized Tariff Schedule of the United States, accessible at hts.usitc.gov.

Any importer whose goods are manufactured in or exported from Colombia is directly in scope. Customs brokers filing entries for Colombian-origin merchandise on or after July 24, 2026 must include this overlay code or risk underpaying duties, which exposes the importer to CBP liquidation adjustments and potential penalties.

Note carefully: codes 9903.05.01 through 9903.05.09 belong to a different program entirely, the Section 301 action targeting Brazil. The forced labor program runs from 9903.05.20 through 9903.05.84. 9903.05.32 sits inside that forced-labor block and is Colombia-specific.

Legal authority and program background

The duty is grounded in the USTR Section 301 Forced Labor Investigation (FLIP) final action, issued on July 23, 2026, one day before the duty took effect. The action is codified in U.S. note 52 of Chapter 99 of the HTSUS. U.S. note 52(a) governs product scope for this code, confirming it covers all Chapter 1 through 97 products of Colombia.

CBP issued CSMS message 69326983 as the operational implementation notice. That message, available through cbp.gov, contains ACE filing specifics that brokers need to process entries correctly. Confirm you have retrieved that exact CSMS before filing any entry on Colombian goods dated on or after July 24, 2026.

For importers who track the broader Section 301 forced labor landscape, similar codes exist for other countries. For example, 9903.05.29 covers Canada at 10 percent and 9903.05.27 covers Brazil at 12.5 percent, each with its own scope rules.

Affected products and country scope

The scope of 9903.05.32 is deliberately broad. U.S. note 52(a) and the migration record (migration_202607281700) confirm that the code applies to all Chapter 1 through 97 products of Colombia. There are no product-specific exclusions, no tariff-line carve-outs, and no sector exemptions specified in the facts available as of September 2, 2026.

Country of origin is the operative trigger. Only goods whose country of origin is Colombia (ISO country code CO) are subject to this additional duty. Third-country goods merely transiting Colombia, or goods with Colombian inputs but origin elsewhere, are not automatically captured, though standard CBP origin rules apply. If you have questions about how your specific product's origin is determined, confirm the analysis with a licensed broker or trade counsel using the applicable CBP regulations at ecfr.gov.

The 12.5 percent rate and its effective window

The additional duty rate is 12.5 percent ad valorem, calculated on the customs value of the imported merchandise. It applies to all qualifying entries with a date of entry on or after July 24, 2026. There is no announced end date as of the facts available for this article.

Because there is no sunset provision on record, importers should treat this duty as open-ended until a formal Federal Register notice or USTR action announces otherwise. Check federalregister.gov for any subsequent USTR actions modifying or terminating U.S. note 52 coverage for Colombia.

The 12.5 percent rate is the same rate applied to several other countries in the Section 301 forced labor block. The rate is not MFN-capped for Colombia based on the facts available, but confirm the current HTSUS notes if you have any doubt.

How 9903.05.32 stacks with other duties

Chapter 99 overlay codes are additive. The 12.5 percent under 9903.05.32 is layered on top of, not in place of, whatever duty applies on the Chapter 1 through 97 line. A Colombian good dutiable at, say, the standard column 1 general rate will owe that rate plus 12.5 percent under this code.

If the same shipment is also subject to other Chapter 99 provisions, including Section 232 steel or aluminum duties, Section 301 trade-war tariffs on specific product categories, or antidumping and countervailing duties, those all stack as well, each calculated on the applicable base according to their own rules. The interaction of multiple Chapter 99 provisions can shift the dutiable base for each layer; confirm the stacking sequence for your specific HTS classification before relying on a duty estimate. The duty calculator at CustomsGenius can help model multiple stacking scenarios.

For importers thinking about sourcing shifts to avoid this duty, review the distinction between legitimate sourcing decisions and evasion. The article on AD/CVD circumvention and legal sourcing shifts covers the compliance framework for that analysis.

How this code appears on a customs entry

On a CBP Form 7501 or its ACE equivalent, 9903.05.32 appears as a secondary HTS line beneath the primary Chapter 1 through 97 classification. The regular classification line carries the normal rate and provides the statistical basis. The Chapter 99 line carries the additional 12.5 percent and references U.S. note 52.

Every Colombian-origin line item on an entry must have the overlay added. Omitting it on even one line leaves that line under-declared. CSMS 69326983 at cbp.gov specifies the ACE entry-summary coding. Pull that message and verify your broker's template reflects it before the first post-July 24, 2026 filing.

For a broader orientation to Chapter 99 overlay codes introduced in 2026, see the 2026 tariff code overview.

What importers should do

Audit open and upcoming Colombian-origin shipments. Identify every entry with a date of entry on or after July 24, 2026 that includes Colombian-origin goods, confirm the 12.5 percent additional duty was or will be declared under 9903.05.32, and work with your broker to file any necessary post-summary corrections for missed declarations.
Update your ACE filing templates. Ensure every Colombian-origin HTS line in your entry templates carries 9903.05.32 as a secondary line. Reference CSMS 69326983 for the exact ACE coding requirements.
Build the cost into landed-cost models. The 12.5 percent adds materially to the total duty bill. Recalculate landed costs for all Colombian-origin SKUs and update pricing, purchase orders, or supplier agreements accordingly. Use the duty calculator to model stacked duty scenarios.
Monitor for changes. There is no announced end date. Subscribe to USTR and Federal Register updates at federalregister.gov and watch for any new CSMS messages at cbp.gov that modify the Colombia note 52 coverage.

Key references

HTSUS Chapter 99, heading 9903.05.32, U.S. International Trade Commission, official tariff schedule including U.S. note 52.
CSMS 69326983, CBP operational implementation notice for this Section 301 forced labor action on Colombia.
USTR Section 301 FLIP final action, July 23, 2026, Federal Register, the rulemaking establishing the 12.5 percent additional duty on Colombian products.
USTR Section 301 Forced Labor Investigation (FLIP) program page, Office of the United States Trade Representative.
19 C.F.R. Parts 134 and 102, CBP country-of-origin rules applicable to determining Colombian origin.
USTR Section 301 Exclusion Amendments and ACE HSU 2621: What Importers Must Do, CustomsGenius.

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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.