Section 301 China conforming amendments: ACE noon Sep 23, then PSC for refunds

USTR published conforming amendments to four Section 301 China product exclusions on September 2, 2026. The amendments keep the same exclusion coverage after USITC changed ten-digit statistical reporting numbers on July 1, 2026. CBP's ACE acceptance of the amendment goes live at noon on September 23, 2026.

If you imported covered lines between July 1 and September 22, paid Section 301 China duties, and the goods fall under HTSUS 9903.88.69, the operational move is a Post Summary Correction on or after September 23. This is a refund window driven by a statistical renumbering, not a new exclusion grant.

ACE accepts the conforming amendment at noon on September 23, 2026. File PSCs for July 1 through September 22 entries on or after that date.

What USTR amended

FR Doc. 2026-17925 (91 FR 56538) amends U.S. notes 20(vvv)(i)(4), 20(vvv)(i)(5), 20(vvv)(i)(6), and 20(vvv)(iv)(4) to subchapter III of chapter 99 of the HTSUS. Those notes sit under heading 9903.88.69. The conforming amendments are effective as of July 1, 2026 for goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern standard time that day.

CSMS #69990649 is the CBP filing guide. It maps the old statistical numbers to the post-July 1 numbers and tells filers how to claim the exclusion without stacking a separate Section 301 Chapter 99 line.

Statistical numbers that moved

For notes 20(vvv)(i)(4), (i)(5), and (i)(6), the notes now carry the pre-July 1 coverage through June 30, 2026, then the post-July 1 statistical reporting numbers 8413.91.9039, 8413.91.9046, 8413.91.9059, or 8413.91.9099 effective July 1, 2026. Through June 30, 2026, those goods were classified under 8413.91.9065, 8413.91.9085, or 8413.91.9096.

For note 20(vvv)(iv)(4), the note now covers goods described in 3926.90.9910 prior to July 1, 2026, and goods described in 3926.90.9915 or 3926.90.9920 effective July 1, 2026. Through June 30, 2026, that coverage sat under 3926.90.9910.

Who should file a PSC, and when

CBP's worked example in CSMS #69990649 is the one to operationalize. If you entered Chinese goods from July 1, 2026 through September 22, 2026 that are subject to the conforming amendments under 9903.88.69, and you paid Section 301 China duties, file a PSC on or after September 23, 2026 to obtain a refund of duties paid.

That PSC path only works inside the PSC filing timeframe. If the entry is beyond the PSC window, protest the liquidation within the protest filing timeframe. Do not wait for ACE noon on September 23 and then discover the entry already left the PSC window without a protest plan.

• Pull entry summaries for July 1 through September 22, 2026 on the affected pump-part and plastics statistical numbers.
• Confirm the goods match notes 20(vvv)(i)(4), (i)(5), (i)(6), or (iv)(4) under 9903.88.69.
• Confirm Section 301 China duty was paid and that 9903.88.69 was not claimed (or was claimed incorrectly).
• Queue PSCs for transmission on or after September 23, 2026 once ACE accepts the amendment.
• Track PSC vs. protest clocks separately for older liquidated entries.

Where questions go

ACE entry rejections involving product exclusions go to your CBP Client Representative. Section 301 entry-filing questions go to the Office of Trade's Trade Remedy branch at traderemedy@cbp.dhs.gov. USTR's notice points classification and exclusion-implementation questions to the same mailbox.

If you already run Section 301 China through drawback, treat this as an entry-summary cleanup first. A clean PSC that removes incorrectly paid 301 duty is usually cheaper and faster than trying to recover the same dollars later as drawback. Keep your drawback pool math consistent with whatever the PSC refunds.

This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.