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9903.05.65 Qatar Section 301 Forced Labor: 12.5% Duty

Published: September 13, 2026  ·  7 min read
9903.05.65 Qatar Section 301 Forced Labor: 12.5% Duty
Photo: Anoop VS / Pexels

Key Points

On this page

  1. What HTS 9903.05.65 is and who needs to act
  2. Program background: Section 301 Forced Labor and U.S. note 52
  3. Products and countries in scope
  4. The 12.5 percent rate and its effective window
  5. How 9903.05.65 stacks with other duties on a Customs entry
  6. How the code appears on a CBP entry
  7. What importers should do
  8. Key references

HTS 9903.05.65 is the Chapter 99 tariff code that adds a 12.5 percent ad valorem duty to all products of Qatar entering the United States, effective July 24, 2026. It was created by a USTR Section 301 Forced Labor Investigation (FLIP) final action and is governed by U.S. note 52 to Chapter 99. Any importer whose goods originate in Qatar, and any customs broker filing entries for those goods, must report this code on every covered entry filed on or after July 24, 2026.

The links in this article go to the primary documents: the official USTR and CBP guidance, the Harmonized Tariff Schedule itself, and Federal Register and White House source pages. Read the source.

What HTS 9903.05.65 is and who needs to act

Chapter 99 of the Harmonized Tariff Schedule of the United States (HTSUS) is a temporary-measures chapter. Codes in this chapter do not stand alone; they ride alongside the permanent Chapter 1-97 classification for the goods. Code 9903.05.65 is specifically designated for Qatar under the Section 301 Forced Labor program, sitting within the country-specific heading range 9903.05.20 through 9903.05.84 that covers all Section 301 forced-labor country actions under U.S. note 52.

Importers sourcing any product from Qatar, freight forwarders arranging such shipments, and customs brokers classifying those entries are the primary audience. If your goods are of Qatar origin, this code applies regardless of what the goods are.

Note: codes 9903.05.01 through 9903.05.09 cover a separate Section 301 action against Brazil. Do not confuse those codes with the forced-labor country headings beginning at 9903.05.20.

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

The Section 301 Forced Labor Investigation (FLIP) is a U.S. Trade Representative action taken under Section 301 of the Trade Act of 1974. When USTR finds that a trading partner's practices, including the use of forced labor, burden or restrict U.S. commerce, it may recommend additional duties. The Qatar action reached its final stage on July 23, 2026, the date of USTR's FLIP final action. CBP implementation guidance was issued through CSMS message 69326983. The tariff mechanism for all country-specific forced-labor actions in this series is U.S. note 52 to Chapter 99, which defines scope and applicability rules.

You can review the current HTSUS Chapter 99 text, including U.S. note 52, directly at hts.usitc.gov. For CBP operational guidance, check cbp.gov and search CSMS message 69326983.

Other countries have been assigned separate codes in the same heading range. For comparison, see related articles on 9903.05.61 Oman, 9903.05.63 Peru, and 9903.05.64 Philippines, all carrying 12.5 percent additional duties under the same program.

Products and countries in scope

Country scope

9903.05.65 applies to products of Qatar (country code QA). Origin for customs purposes is determined under CBP's standard rules of origin, not merely where goods were shipped from. If a product is manufactured in Qatar but transshipped through a third country, it remains subject to this duty if it retains Qatar origin. Confirm origin determinations with your broker or through a CBP binding ruling if there is any ambiguity.

Product scope

As of September 13, 2026, the scope covers all Chapter 1-97 products of Qatar, per U.S. note 52(a). No product-specific exclusions are stated in the facts for this code. If you believe an exclusion may apply, confirm with the current HTSUS text at hts.usitc.gov or with a licensed customs broker, as the HTSUS is the controlling document.

The 12.5 percent rate and its effective window

The additional duty rate is 12.5 percent ad valorem, applied on top of all other applicable duties. This rate has been in effect since July 24, 2026, and has no announced end date as of September 13, 2026. Until USTR or CBP formally terminates or modifies the action, every qualifying Qatar-origin entry is subject to the full 12.5 percent additional duty.

The 12.5 percent rate is calculated on the customs value of the goods, the same base used to compute the standard MFN (Column 1) duty. The facts block for this code does not reference any MFN cap for Qatar, but confirm the current HTSUS for any cap provisions that may apply to specific goods.

How 9903.05.65 stacks with other duties on a Customs entry

The 12.5 percent additional duty under 9903.05.65 is cumulative with other applicable duties and fees. Depending on the goods, an importer of Qatar-origin merchandise may owe:

Use the CustomsGenius duty calculator to model total landed cost with all applicable layers. For a broader view of 2026 tariff code changes, see the 2026 tariff code overview.

How the code appears on a CBP entry

On CBP Form 3461 (entry/immediate delivery) and the formal entry summary (CBP Form 7501), 9903.05.65 appears as a second HTS line beneath the substantive Chapter 1-97 classification for the goods. You do not replace the underlying code; you add 9903.05.65 as an additional line with a reported duty rate of 12.5 percent. CBP's Automated Commercial Environment (ACE) system expects both lines to be present for Qatar-origin goods subject to this action.

Failing to report 9903.05.65 on a covered entry exposes the importer to potential duty underpayment, liquidation adjustments, and interest. If you have filed entries for Qatar-origin goods since July 24, 2026, without this code, work with your broker to assess whether prior disclosure or a post-summary correction is appropriate. Confirm current ACE filing requirements through cbp.gov and CSMS 69326983.

For more on who bears the importer-of-record responsibility and associated liability, see Incoterms Customs Responsibility: Who Is Really the Importer.

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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