9903.05.80 UAE Section 301 Forced Labor: 12.5% Duty

Key Points

• HTS 9903.05.80 imposes an additional 12.5 percent ad valorem duty on all products of the United Arab Emirates (country code AE) entering under chapters 1 through 97 of the HTSUS.
• The duty took effect on 2026-07-24 and has no announced end date as of the facts available for this article (as of September 17, 2026).
• The legal authority is the USTR Section 301 Forced Labor Investigation final action dated 2026-07-23, implemented under U.S. note 52, and announced in CSMS 69326983.
• 9903.05.80 is a Chapter 99 overlay: it rides alongside the regular chapter 1-97 classification line on each entry; importers must report both codes.
• Do not confuse this code with 9903.05.01 through 9903.05.09, which cover a separate Section 301 Brazil program, not forced labor actions.

On this page

1. What this code is and who must care
2. Legal authority and program background
3. Affected products and country scope
4. The 12.5 percent rate and its effective window
5. How 9903.05.80 stacks with other duties
6. How the code appears on a customs entry
7. What importers should do
8. Key references

HTS 9903.05.80 is a Section 301 forced labor tariff code that adds 12.5 percent ad valorem to the duty owed on all products of the United Arab Emirates, covering every chapter 1-97 commodity, effective 2026-07-24. Any U.S. importer whose supply chain runs through the UAE needs to account for this additional charge on entries filed on or after that date. The links in this article go to primary documents: the official tariff schedule, CBP system messages, and government authority pages themselves. Read the source.

What this code is and who must care

9903.05.80 sits within the country-specific headings of the Section 301 Forced Labor Investigation program, which spans codes 9903.05.20 through 9903.05.84. Each heading in that range targets a specific country. Code 9903.05.80 is assigned exclusively to the United Arab Emirates.

If you import any physical goods that originate in or are products of the UAE, this code applies to your entries filed on or after 2026-07-24. It does not matter what commodity you are importing: the scope covers all products classifiable in chapters 1 through 97. Importers of goods from the UAE, their customs brokers, and trade finance teams pricing landed costs all need to factor in the 12.5 percent surcharge immediately.

Importers researching similar country-specific forced labor codes for other trading partners can also review the coverage for Turkiye (9903.05.79) and Korea (9903.05.71) as companion examples.

Legal authority and program background

The United Arab Emirates duty was established by the USTR Section 301 Forced Labor Investigation final action, issued on 2026-07-23. The action operates under U.S. note 52 to the Harmonized Tariff Schedule of the United States. CBP operationalized the duty through CSMS message 69326983.

Section 301 of the Trade Act of 1974 authorizes USTR to investigate and respond to foreign practices that burden or restrict U.S. commerce. The forced labor variant of this authority targets sourcing practices in specific countries. U.S. note 52 sets out the legal mechanics that govern which country headings apply, in what circumstances, and at what rates. Confirm the current text of U.S. note 52 directly in the official HTSUS at hts.usitc.gov.

Note carefully: codes 9903.05.01 through 9903.05.09 are a separate Section 301 program covering Brazil and are entirely unrelated to this forced labor action. Do not conflate the two blocks.

Affected products and country scope

The scope of 9903.05.80 is intentionally broad:

• Country: United Arab Emirates (ISO country code AE).
• Products: All products classifiable in chapters 1 through 97 of the HTSUS. There is no commodity carve-out or exclusion list reflected in the facts available as of September 17, 2026.
• Effective from: 2026-07-24 onward, with no announced end date.

Because the scope covers every chapter 1-97 product, the additional duty applies regardless of whether you are importing industrial components, consumer goods, food products, chemicals, textiles, or machinery of UAE origin. If you believe a specific product may be excluded or are uncertain about origin rules, confirm with your broker or check the current HTSUS.

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. This rate has been in effect since 2026-07-24 and has no announced end date as of September 17, 2026.

Because the rate is ad valorem, your actual dollar exposure scales directly with the declared customs value. On a shipment valued at $100,000, the additional duty from 9903.05.80 alone is $12,500, before any other applicable duties are added.

No MFN cap or rate ceiling for this code appears in the available facts. If you have reason to believe a cap may apply to a specific commodity, verify with your broker against the current HTSUS and U.S. note 52.

How 9903.05.80 stacks with other duties

The 12.5 percent under 9903.05.80 is an additional duty. It does not replace the regular column 1 (MFN) rate that applies to the chapter 1-97 classification, nor does it replace any other Section 301, Section 232, or Section 201 duties that may already apply to the same product.

In practice, your total duty liability on a UAE-origin entry is the sum of:

• The standard MFN (column 1-general) rate for the chapter 1-97 classification.
• Any other Chapter 99 overlay duties already applicable to that commodity (for example, any existing Section 232 steel or aluminum surcharges, if relevant).
• The 12.5 percent additional duty from 9903.05.80, effective 2026-07-24.

Stacking can move total effective rates well above 12.5 percent. Run the full landed cost calculation before finalizing purchase orders for UAE-origin goods. You can model combined rates using the CustomsGenius duty calculator.

How the code appears on a customs entry

Chapter 99 overlay codes like 9903.05.80 do not replace the underlying chapter 1-97 classification. On a CBP entry, you will report two HTS lines for each affected line item:

1. The standard chapter 1-97 classification (for example, a specific heading under chapter 84 for machinery).
2. 9903.05.80 as a secondary line, triggering the 12.5 percent additional duty.

CBP activated this reporting requirement through CSMS 69326983. Verify the exact ACE entry instructions with that message and with your broker. Omitting 9903.05.80 from the entry when it applies is an underpayment of duties and can expose the importer to penalties. For a broader look at how Chapter 99 codes appear on entries in 2026, see the 2026 tariff code overview.

If you have already filed entries for UAE-origin goods after 2026-07-24 without reporting 9903.05.80, speak with your broker about a post-summary correction or prior disclosure posture. For information on how CBP evaluates culpability in duty shortfalls, see CBP Gross Negligence vs Fraud in Customs Violations.

What importers should do

• Audit open and upcoming shipments. Identify every entry filed on or after 2026-07-24 for goods of UAE origin and confirm that 9903.05.80 was reported alongside the chapter 1-97 classification. Correct any omissions promptly.
• Update landed-cost models. Add 12.5 percent to the duty calculation for all UAE-origin commodities in chapters 1 through 97. Use the duty calculator to factor in stacking with existing duties before finalizing new purchase orders.
• Review sourcing and origin documentation. Confirm country of origin for all products sourced from or transiting through the UAE. Substantial transformation rules determine origin; if origin is genuinely a third country, document that determination carefully.
• Monitor for updates. There is no announced end date for this duty as of September 17, 2026. Watch cbp.gov CSMS messages and the HTSUS for any modifications to U.S. note 52 or the 9903.05.80 rate.

Key references

• Harmonized Tariff Schedule of the United States (hts.usitc.gov) - Official HTSUS including U.S. note 52 and the full Chapter 99 forced labor headings.
• CBP CSMS 69326983 - CBP system message implementing 9903.05.80 for UAE products, effective 2026-07-24.
• USTR Section 301 Forced Labor Investigation final action, 2026-07-23 - The USTR determination establishing the 12.5 percent additional duty on UAE products.
• Federal Register - Search for the Section 301 forced labor final action notice corresponding to the 2026-07-23 determination.
• 19 U.S.C. 2411 (Section 301, Trade Act of 1974) - Statutory authority for USTR Section 301 actions.
• Section 301 Tariff Exclusion Request: The Importer's Playbook - Guidance on the exclusion request process for Section 301 duties.
• CBP Form 19: Protest Rules, Deadlines, and ACE Filing - How to file a protest if duty was incorrectly assessed or overpaid.