News

9903.05.62 Pakistan Section 301 Forced Labor: 10% Duty

Published: September 12, 2026 · 7 min read

Key Points

HTS 9903.05.62 imposes a 10 percent additional ad valorem duty on all products of Pakistan (country code PK) under the Section 301 Forced Labor program.
The duty took effect on July 24, 2026, and has no announced end date as of September 12, 2026.
The additional duty covers all Chapter 1-97 products of Pakistan; there is no product-specific exclusion list described in the facts available.
Legal authority rests on the USTR Section 301 FLIP final action dated July 23, 2026, implemented through U.S. note 52 and announced via CSMS 69326983.
This code sits in the 9903.05.20 through 9903.05.84 country-heading range; it is not related to the separate Section 301 Brazil program under 9903.05.01 through 9903.05.09.

HTS 9903.05.62 is a Chapter 99 special duty provision that adds 10 percent ad valorem to the dutiable value of all products of Pakistan, effective July 24, 2026, under the Section 301 Forced Labor program. Every importer whose goods originate in Pakistan must add this code to each entry line covering a Chapter 1-97 product. The additional duty stacks on top of whatever normal trade relations (NTR/MFN) rate and any other applicable Chapter 99 duties already apply to the goods.

What HTS 9903.05.62 is and who must care

Any company importing goods that originate in Pakistan needs to account for 9903.05.62 on every entry filed on or after July 24, 2026. The code appears in the U.S. Harmonized Tariff Schedule under Chapter 99, the chapter reserved for special import programs and temporary measures. It was created as part of a wave of country-specific Section 301 Forced Labor actions announced by the U.S. Trade Representative.

Customs brokers filing entries on behalf of Pakistani-origin shippers should treat this code as mandatory from the effective date forward. If your goods were already in transit before July 24, 2026, confirm the entry date with your broker to determine whether the additional duty applies. Confirm the current treatment in the Harmonized Tariff Schedule (hts.usitc.gov) or with your broker, because Chapter 99 provisions can be updated without advance public notice.

Program background: Section 301 Forced Labor

The Section 301 Forced Labor program uses the authority of Section 301 of the Trade Act to impose additional duties on goods from countries identified as engaging in, or tolerating, forced labor in their production supply chains. The country-specific codes for this program run from 9903.05.20 through 9903.05.84.

Note carefully: the codes 9903.05.01 through 9903.05.09 belong to a separate Section 301 action targeting Brazil. They are a different program with different legal underpinnings and different rates. Do not conflate them with the forced labor series.

The legal authority for 9903.05.62 is the USTR Section 301 FLIP final action dated July 23, 2026, implemented in the tariff schedule through U.S. note 52. CBP announced the operational details through CSMS message 69326983. You can search for that CSMS on the CBP CSMS portal.

For context on how this code compares to similar country-specific forced labor codes, see our articles on 9903.05.55 Mexico (10%) and 9903.05.54 Malaysia (10%).

Product and country scope

Country

9903.05.62 applies exclusively to products of Pakistan (country code PK). Country of origin, not country of export or country of shipment, determines applicability. Goods transshipped through a third country remain subject to the duty if they originate in Pakistan.

Products covered

The scope is broad: all Chapter 1-97 products of Pakistan are covered. There is no product-specific carve-out or exclusion list described in the available facts as of September 12, 2026. If you believe a product-specific exclusion exists or has been granted, verify that directly in the current HTSUS or with your broker, as the facts block for this code does not identify any.

The rule is implemented under U.S. note 52(a), which governs the full country-heading range for the Section 301 Forced Labor program.

When vetting Pakistani suppliers, a structured pre-purchase checklist helps surface forced labor and origin documentation risks early. See our New Supplier Customs Checklist for a practical starting point.

The 10 percent rate and its effective window

The additional duty rate is 10 percent ad valorem. It applies from July 24, 2026, onward. As of September 12, 2026, no end date has been announced. The rate should be treated as open-ended until USTR or CBP issues a formal modification or termination notice.

The rate for Pakistan is 10 percent. Rates for other countries in the same 9903.05.20-to-9903.05.84 series differ: for example, Oman, Norway, Nigeria, Nicaragua, New Zealand, and Morocco carry 12.5 percent rates under their respective codes. Always confirm the rate against the specific country code, not an average or neighboring code.

How 9903.05.62 stacks with other duties

The 10 percent additional duty is additive. It piles on top of:

The standard NTR (MFN) column 1 rate for the Chapter 1-97 classification of the specific product.
Any other Chapter 99 additional duties that apply to the same goods (for example, any Section 232 or other Section 301 measures that independently cover the product).
Any applicable merchandise processing fee (MPF) and harbor maintenance fee (HMF), which are calculated separately.

The facts block does not describe an MFN cap on this code. If you have reason to believe a cap may apply based on the product's normal rate, confirm directly in U.S. note 52 and the current HTSUS rather than assuming.

For an overview of how multiple Chapter 99 duties interact across a single entry line, see the 2026 tariff code overview. To model your total duty liability, use the duty calculator.

How this code appears on a customs entry

Chapter 99 codes like 9903.05.62 do not replace the underlying Chapter 1-97 classification. They ride alongside it on the same entry line. A correctly filed entry for a Pakistani-origin product will show:

Line 1: The Chapter 1-97 HTS number (for example, a textile classification in Chapter 61 or a sporting goods code in Chapter 95), with its normal NTR rate and dutiable value.
Line 2 (same entry line, separate SPI or additional classification field): 9903.05.62, assessed at 10 percent on the same dutiable value.

ACE will require both classifications to be present for Pakistani-origin goods entered on or after July 24, 2026. Brokers should verify that their entry software correctly handles the dual-classification requirement. CBP's CSMS 69326983 contains the operational filing instructions; search for it on the CBP CSMS portal.

If you are unsure which party is responsible for ensuring the correct classification appears on the entry, the answer often depends on your Incoterms arrangement. See Incoterms Customs Responsibility: Who Is Really the Importer for a plain-English breakdown.

What importers should do

Audit open and pending entries. Identify all Pakistani-origin products in your import pipeline. For any entry filed on or after July 24, 2026 that does not carry 9903.05.62, work with your broker to file a post-entry amendment or protest as appropriate.
Update your landed cost models. Add the 10 percent additional duty to every cost build-up for goods of Pakistani origin. Use the duty calculator to model the combined duty stack for specific products.
Instruct your customs broker in writing. Confirm that your broker's ACE filing templates include 9903.05.62 for all PK-origin lines. Provide written instruction so there is a documented record.
Monitor for program changes. Because no end date has been announced, track USTR and CBP communications for any modification, suspension, or termination of U.S. note 52 coverage for Pakistan. The Federal Register and CBP CSMS are the authoritative sources for those notices.

Key references

Harmonized Tariff Schedule (hts.usitc.gov) - Official HTSUS including Chapter 99 and U.S. note 52; confirm current text of 9903.05.62 here.
USTR.gov - Source of the Section 301 FLIP final action dated July 23, 2026; search for the Pakistan forced labor determination.
Federal Register (federalregister.gov) - Official publication of USTR actions and notices implementing U.S. note 52.
CBP CSMS portal (cbp.gov) - Search for CSMS 69326983 for operational ACE filing instructions for 9903.05.62.
9903.05.55 Mexico Section 301 Forced Labor: 10% Duty Explained - Related country code at the same 10% rate for comparison.
9903.05.61 Oman Section 301 Forced Labor: 12.5% Duty - Related country code in the same program series at a different rate.

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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.