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9903.91.11 Explained: Section 301 China Four-Year Review, 25% Duty

Published: October 14, 2026 · 7 min read

Key Points

9903.91.11 is a Chapter 99 Section 301 four-year-review code that imposed an additional 25% duty on articles the product of China, as provided for in subdivision (j) of U.S. Note 31 to Subchapter III of Chapter 99.
The code became effective for entries on or after January 1, 2025, and applied to three tungsten-related HTSUS subheadings: 8101.94.00, 8101.99.10, and 8101.99.80.
All three product-scope windows closed on February 1, 2026; as of October 14, 2026, none of those subheadings remain covered under 9903.91.11.
Entries made between January 1, 2025, and February 1, 2026, that carried these subheadings from China were subject to the duty-in-the-applicable-subheading plus 25%; entries after February 1, 2026, are not covered by this code.
If your entry summary for goods in the January 1, 2025 through February 1, 2026 window does not reflect the correct stacking of 9903.91.11, you should review it with your broker now.

9903.91.11 is a Section 301 China tariff code, part of the four-year statutory review of the original Section 301 Lists, that imposed an additional 25% duty on three tungsten-related subheadings (8101.94.00, 8101.99.10, and 8101.99.80) for entries of Chinese-origin goods on or after January 1, 2025. All three subheading windows ended on February 1, 2026, meaning the code is currently inactive for all covered subheadings as of October 14, 2026. Importers with entries in the January 1, 2025 through February 1, 2026 window need to confirm correct classification and duty payment; importers with entries after February 1, 2026, should confirm these subheadings are no longer covered.

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 9903.91.11 is and what program created it

Section 301 of the Trade Act of 1974, codified at 19 U.S.C. § 2411, authorizes the U.S. Trade Representative to impose additional duties on goods from countries engaged in unfair trade practices. The original Section 301 action against China produced four lists of covered goods (commonly called Lists 1 through 4), enforced in the HTSUS primarily through the 9903.88.xx series of Chapter 99 codes.

The four-year statutory review process produced a separate set of escalated rates administered under the 9903.91 and 9903.92 series. 9903.91.11 is one such four-year-review code. Its official heading text, as it appears in the Harmonized Tariff Schedule, reads: "Effective with respect to entries on or after January 1, 2025, articles the product of China, as provided for in subdivision (j) of U.S. note 31 to this subchapter." The product scope is defined in subdivision (j) of U.S. Note 31 to Subchapter III of Chapter 99, which enumerates the specific eight-digit subheadings subject to this code.

Affected products and HTSUS coverage

Subdivision (j) of U.S. Note 31, as operative during the window described below, covered three subheadings, all in the tungsten family of Chapter 81 (other base metals):

8101.94.00 (unwrought tungsten, including bars and rods obtained simply by sintering)
8101.99.10 (tungsten waste and scrap)
8101.99.80 (other tungsten articles)

Only goods that are the product of China and classifiable under one of these three eight-digit subheadings fell within 9903.91.11. Goods from any other country, or Chinese goods classified under a different subheading, were not subject to this code. Confirm the precise scope in the current HTSUS or with your broker, because subdivision (j) governs; the subheading descriptions above are provided for orientation only.

For an overview of how 2026 tariff codes interact across programs, see our 2026 tariff code overview.

Rate and how it stacks with other duties

The HTSUS general column rate for 9903.91.11 is: the duty provided in the applicable subheading + 25%. This means the 25% is additive on top of whatever column 1 general rate applies to the underlying Chapter 81 subheading. It does not replace the normal rate; both are owed on the same merchandise.

When multiple Section 301 codes are potentially applicable to the same goods, importers and brokers need to determine which code takes precedence under the U.S. note structure. If you are unsure whether an earlier 9903.88.xx code or this 9903.91.11 code should appear on the same entry line, verify against U.S. Note 31 and any predecessor notes in Chapter 99. See our related articles on 9903.91.06 and 9903.91.04 for how other 25% four-year-review codes are structured, as the stacking logic is similar across the series.

Effective window and current status

As of October 14, 2026, the status of each covered subheading is as follows:

8101.94.00: covered January 1, 2025 through February 1, 2026. Window closed. Not in force.
8101.99.10: covered January 1, 2025 through February 1, 2026. Window closed. Not in force.
8101.99.80: covered January 1, 2025 through February 1, 2026. Window closed. Not in force.

All three windows are closed. As of the facts date of October 14, 2026, zero subheadings remain in force under 9903.91.11. Entries liquidated or filed after February 1, 2026, for these subheadings should not carry 9903.91.11. If they do, that is an error that may require correction through your broker or a post-entry amendment process with CBP.

How this code appears on a customs entry

Chapter 99 codes ride alongside, not instead of, the underlying Chapter 1 through 97 classification. On an ACE entry summary, you will see two lines for the same article: the primary eight-digit Chapter 81 subheading (such as 8101.94.0000) and 9903.91.11 as a secondary line in the HTS field. The duty rate on the secondary line reflects the additional 25%; CBP's automated system combines both to produce the total duty owed.

If your entry summary for goods imported between January 1, 2025, and February 1, 2026, does not show 9903.91.11 alongside the appropriate Chapter 81 subheading, you may have an underpayment. Review your entries with your broker. For guidance on checking whether your broker calculated duty correctly, see How Do I Check Whether My Broker Calculated the Duty Correctly?

Interaction with other Section 301 provisions

The 9903.91.xx series was created as part of the four-year review of the original Section 301 action, layering on or replacing rates established under earlier 9903.88.xx codes. Whether 9903.91.11 operated alongside or displaced a predecessor 9903.88.xx code for the same subheadings during the January 1, 2025 through February 1, 2026 window depends on the specific U.S. note language and any USTR guidance in effect at the time. Confirm the interaction for any open or unliquidated entries with your broker or by reviewing the HTSUS Chapter 99 notes directly.

Importers researching related four-year-review codes may also find these articles useful:

If you believe duty drawback or refund opportunities exist for entries made during the now-closed window, review the program rules carefully. Our article on Duty Drawback Software vs Duty Refund Recovery Software explains the distinction between drawback and post-entry refund mechanisms.

What importers should do

Audit past entries. Pull all entry summaries for Chinese-origin goods under 8101.94.00, 8101.99.10, or 8101.99.80 with entry dates between January 1, 2025, and February 1, 2026. Verify that 9903.91.11 appears and that the 25% additional duty was assessed and paid.
Confirm post-February 2026 entries. For entries filed after February 1, 2026, confirm that 9903.91.11 was not applied to these subheadings; if it was, work with your broker to correct the entry through CBP.
Check the current HTSUS for any updates. Always verify the current text of U.S. Note 31, subdivision (j), in the live HTSUS before filing, as notes can be amended.
Work with a licensed customs broker on any open or unliquidated entries, particularly if you are considering post-entry amendments or refund claims.

Key references

Harmonized Tariff Schedule of the United States (HTSUS): official source for 9903.91.11 heading text, rate, and U.S. Note 31 subdivision (j).
19 U.S.C. § 2411, Trade Act of 1974, Section 301: statutory authority for the Section 301 action against China.
U.S. Customs and Border Protection (CBP): entry processing, CSMS messages, and post-entry amendment guidance.
Federal Register: search for USTR notices implementing the Section 301 four-year review rate changes.
Office of the U.S. Trade Representative (USTR): four-year review determinations and product-scope documentation for Section 301 China tariffs.

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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.