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9903.05.48: Japan Section 301 Forced Labor 12.5% Cap Heading

Published: November 1, 2026  ·  5 min read
9903.05.48: Japan Section 301 Forced Labor 12.5% Cap Heading
Photo: Michael Pointner / Pexels

Key Points

On this page

  1. What 9903.05.48 is
  2. Who qualifies: Japan origin and the column 1 test
  3. Exceptions: headings 9903.05.85 to 9903.05.92
  4. Dates and rate window
  5. How it appears on an entry and interacts with other provisions
  6. What importers should do
  7. Key references

9903.05.48 is a Chapter 99 heading in the Section 301 Forced Labor program that adds no duty to Japanese goods already carrying a column 1 rate of 12.5 percent or higher. If your Japan-origin goods meet that test, the forced-labor duty is 0 percent from July 24, 2026 onward. This article reflects the facts as of November 2026.

The links in this article go to the primary documents: the proclamations, Federal Register notices, and official tariff schedule pages themselves. Read the source.

What 9903.05.48 is

The program is Section 301 Forced Labor. The legal authority recorded for this heading is the USTR 301 FLIP final action of July 23, 2026, CBP's CSMS message 69326983, and U.S. note 52 to the subchapter. You can check the heading text in the official Harmonized Tariff Schedule and the message in CBP's trade guidance.

The official heading text reads: "Except for products described in headings 9903.05.85-9903.05.92, articles the product of Japan, with an ad valorem (or ad valorem equivalent) rate of duty under column 1 equal to or greater than 12.5 percent, as provided for in U.S. note 52 to this subchapter."

The key point is what this heading is not. It is an exemption-style branch. The duty heading for Japan sits beside it in the 9903.05 series, and goods that fall under that heading are treated differently. 9903.05.48 is the branch for goods that already pay at or above the 12.5 percent column 1 level, and it adds nothing on top.

Who qualifies: Japan origin and the column 1 test

Country scope

The scope rule on this code is all products, with Japan (JP) as the country. The heading says "the product of Japan," so country of origin is what matters, not country of export or shipment. Confirm origin with your supplier documentation and broker before you rely on the heading.

The column 1 rate test

The heading looks at the ad valorem or ad valorem equivalent rate of duty under column 1 of the tariff line. Column 1 is the general rate column of the HTSUS. A line qualifies when that rate is equal to or greater than 12.5 percent.

The facts here do not say how to convert compound or specific rates into an ad valorem equivalent. For lines with specific or mixed rates, confirm the treatment in U.S. note 52 and with your broker rather than computing it yourself.

Exceptions: headings 9903.05.85 to 9903.05.92

The heading begins with an exception: products described in headings 9903.05.85 to 9903.05.92 are carved out of 9903.05.48. If your goods are described in one of those headings, you read that heading instead. The facts block does not list what those headings cover, so check their text in the current HTSUS before choosing a Chapter 99 line.

Dates and rate window

Because no end date has been announced, check the HTSUS and CBP messages again before each filing period in case the program text changes.

How it appears on an entry and interacts with other provisions

As with other Chapter 99 headings, 9903.05.48 is reported in addition to the regular chapter 1-97 line, not instead of it. You still declare the underlying subheading and pay the column 1 rate that applies to it. The Chapter 99 line records that the forced-labor program adds 0 percent.

The facts here say nothing about how this heading stacks with other tariff programs. Do not assume it exempts the goods from any other duty. Confirm other Chapter 99 requirements for the same goods in the current HTSUS or with a broker. The EU equivalent is a useful comparison: see 9903.05.38, the Section 301 Forced Labor EU column 1 cap heading. The Japan heading has its own text and its own 12.5 percent threshold.

This family is separate from the Section 301 China headings in the 9903.88 and 9903.91 ranges. Do not apply China-program rules or rates to 9903.05.48. For a wider view of the year's headings, see the 2026 tariff code overview.

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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