The Trade Stack Issue #15 — Section 232 steel derivative list widens again, China textile classification push, AD/CVD on Southeast Asia solar expands

This Week in Tariffs

1) Section 232 — second tranche of derivative articles added

Commerce posted the second tranche of derivative articles under the active Section 232 steel/aluminum regime. New inclusions cover stampings, forgings, and certain finished articles meeting the new "substantially complete or finished" test. Many importers will see this change border-line the classifications they have relied on for years.

Who's affected: Steel product importers, particularly those importing stampings, complex forgings, and finished steel articles from non-exempt origins. Source: Commerce / Federal Register, week of May 4, 2026.

2) Section 301 — China textile CF-29 push

CBP continues pushing CF-29 (Notice of Action) requests on Chapter 61/62 (apparel) and 60 (knitted fabric) entries. The two most-requested bits of technical info are fabric construction and end-use garment category. Importers running high-volume apparel programs should pre-stage a documentation binder for brokers to expedite these requests.

Who's affected: China-origin apparel importers and finished garment importers. Source: CBP CSMS messaging, April-May 2026.

3) AD/CVD — Southeast Asia solar expands

A second wave of AD/CVD preliminary determinations on solar cells/modules from Southeast Asia now includes Cambodia and Thailand in addition to the existing Vietnam/Malaysia actions. Preliminary rates will meaningfully raise landed cost on solar sourcing from these origins.

Who's affected: Solar product importers, particularly those using HTS 8541.43 (cells) and 8541.42 (modules). Source: Commerce AD/CVD Access, May 2026.

Duty Savings Spotlight

Apparel knit vs. woven — chapter 61 vs. chapter 62

Knit-versus-woven is the most common apparel misclassification pair. The duty difference is material:

• HTS 6110.20.20 (knit cotton pullovers) — 16.5% MFN + Section 301 (China) if applicable
• HTS 6205.20.20 (woven cotton men's shirts) — 16.6% MFN + Section 301 (China) if applicable

How to check: Open USTradeStack HTS Classifier and describe the garment's construction (knit/woven), fiber content, and gender/age. Verify Section 301 list placement and any active AD/CVD orders with your broker before entry. The USITC HTS database is the authoritative source.

Run the HTS Classifier →

Compliance Alert

CBP Section 321 de minimis CN22 enforcement expanded

CBP is steadily enforcing CN22 / Section 321 de minimis reporting requirements on e-commerce parcels. Merchants splitting shipments to stay below the $800 de minimis threshold are increasingly receiving CBP requests for transaction records and consignee info. The agency is also closely pairing Section 321 traffic with UFLPA/UFLPA-related entity list scrutiny, particularly on cotton and textile shipments.

Impact: Direct-to-consumer importers and online retailers relying on Section 321 de minimis. Source: CBP CSMS and Federal Register notices on de minimis, 2026.

Quick check: USTradeStack's Landed Cost Calculator lets you model the per-parcel landed cost under both Section 321 and formal entry workflows so you can compare the true economics.

Run the Landed Cost Calculator →

One Tool, One Win — Landed Cost Calculator

Solar imports in particular are running through a moving target — between Section 301 (China), AD/CVD (multiple countries), and Section 232 stacking. Before you quote a supplier price to your team, run it through this.

1. FOB purchase price + freight + insurance
2. Duty rate by HTS chapter (USITC) + AD/CVD order exposure
3. MPF + HMF + Section 301/Section 232 stacking
4. Total landed cost per unit

Run the Landed Cost Calculator →