CustomsGenius
← All Publications
News

9903.05.56 Morocco Section 301 Forced Labor: 12.5% Duty Explained

Published: September 10, 2026  ·  7 min read
9903.05.56 Morocco Section 301 Forced Labor: 12.5% Duty Explained
Photo: MAG Photography / Pexels

Key Points

On this page

  1. What this code is and who needs to act
  2. Program background: Section 301 Forced Labor and U.S. note 52
  3. Affected products and country scope
  4. Rate, effective date, and rate window
  5. How 9903.05.56 stacks with other duties
  6. How this code appears on a customs entry
  7. What importers should do
  8. Key references

HTS 9903.05.56 is a Chapter 99 special-program code that adds 12.5 percent ad valorem to the dutiable value of all goods produced in Morocco and entered for consumption on or after July 24, 2026. Any importer, customs broker, or trade attorney handling Moroccan-origin merchandise must classify entries under both the standard Chapter 1-97 HTS number and this secondary code. The additional duty has no announced expiration date as of September 10, 2026.

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

What this code is and who needs to act

9903.05.56 is a country-specific Chapter 99 tariff heading created under the Section 301 Forced Labor program. It applies to every importer whose goods are of Moroccan origin, regardless of the commercial sector or product category. Customs brokers filing entries on Moroccan merchandise, and trade attorneys advising on sourcing decisions or compliance reviews, should treat this as an active, open-ended additional duty as of its effective date.

Importers who have filed entries on Moroccan goods on or after July 24, 2026, without including 9903.05.56 should review those filings immediately. Entries filed before July 24, 2026, are not subject to this code.

Program background: Section 301 Forced Labor and U.S. note 52

The Section 301 Forced Labor program is administered by the Office of the United States Trade Representative (USTR) under Section 301 of the Trade Act of 1974. The Morocco action was finalized by USTR on July 23, 2026. The operative rule governing this and all country-specific codes in the range 9903.05.20 through 9903.05.84 is U.S. note 52 to Chapter 99 of the Harmonized Tariff Schedule of the United States (HTSUS). U.S. note 52(a) establishes that all Chapter 1-97 products of covered countries are subject to the additional duty unless otherwise specified.

CBP issued CSMS 69326983 to provide operational guidance on how these codes are to be reported in the Automated Commercial Environment (ACE). Check cbp.gov for the current text of that message.

A critical boundary: codes 9903.05.01 through 9903.05.09 cover the entirely separate Section 301 Brazil program. Those codes have different legal bases, different rates, and different product scopes. Do not conflate them with the forced labor series beginning at 9903.05.20.

Affected products and country scope

Under U.S. note 52(a), all products classified in Chapters 1 through 97 of the HTSUS that are products of Morocco (ISO country code MA) are covered by 9903.05.56. No product-specific exclusions or carve-outs appear in the facts as of September 10, 2026. If you believe a particular product may be excluded or that an exclusion request process exists, confirm that in the current HTSUS or with a licensed customs broker, as the facts block is silent on that question.

The country scope is Morocco only. Goods of other countries, even if transshipped through Morocco, do not qualify as Moroccan-origin for duty purposes and would fall under a different (or no) forced labor code. Origin is determined by the standard CBP substantial-transformation rules or applicable trade agreement rules of origin; confirm the origin determination for each shipment.

Rate, effective date, and rate window

The additional duty rate is 12.5 percent ad valorem, applied to the customs value of the imported merchandise.

Because no sunset date exists in the current record, treat this rate as indefinite until USTR or CBP issues a modification or termination notice. Monitor the Federal Register and CBP CSMS for any future changes.

How 9903.05.56 stacks with other duties

The 12.5 percent additional duty is cumulative. It stacks on top of:

The facts block does not indicate that this rate is MFN-capped for Morocco. Confirm in the current HTSUS or with a broker if you have questions about capping rules for a specific classification.

How this code appears on a customs entry

Chapter 99 codes like 9903.05.56 are reported as a secondary HTS line on the entry summary, alongside the primary Chapter 1-97 classification for the merchandise. The entry will carry two HTS numbers: the standard classification (for example, a textile under Chapter 61 or an agricultural product under Chapter 7) and 9903.05.56 as the additional-duty line. The 12.5 percent is assessed on the same entered value used for the primary classification.

CBP processes these through ACE. CSMS 69326983 contains the specific ACE reporting instructions. Brokers should verify that their tariff management software has been updated to include 9903.05.56 and the July 24, 2026, effective date. For a broader look at new 2026 codes, see the 2026 tariff code overview. You can also model the combined duty impact using the duty calculator.

If you are reviewing past entries for compliance, the ACE Entry Summary Reports guide describes which reports to pull to identify affected transactions.

What importers should do

Key references


Recovering IEEPA tariff refunds? Get started with CustomsGenius to streamline your refund process.

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.

Request Beta Access

Get early access to CustomsGenius and start recovering IEEPA refunds faster.

Beta Pilot Ongoing