Section 301 Tariffs on Packaging: HTS Codes, Rates, and the Vietnam Workaround (2026)

A procurement-focused breakdown of which packaging HTS codes carry Section 301 tariffs, current rates, what's exempt, and how Vietnam-origin imports avoid them entirely.

What Section 301 actually is

Section 301 of the Trade Act of 1974 lets the United States Trade Representative (USTR) impose tariffs on goods from a country judged to be engaging in unfair trade practices. The current China Section 301 action — initiated in 2018, expanded through 2019, and reviewed in 2024 — covers four lists of HTS codes. Lists 1, 2, and 3 carry an additional 25% duty. List 4A carries 7.5%. These are layered on top of the standard MFN (most-favored-nation) duty, not replacing it.

Important: Section 301 attaches to country of origin, not country of shipment. A box manufactured in Vietnam from Vietnamese paperboard is Vietnam-origin and falls outside Section 301 — even if it ships through Hong Kong. A box manufactured in China and merely repackaged in Vietnam is still China-origin and still subject to Section 301.

The HTS chapters that hit packaging

Almost all B2B packaging imported into the US falls into two HTS chapters. Chapter 48 covers paper and paperboard articles — corrugated cartons, folding cartons, rigid gift boxes, paperboard bags. Chapter 39 covers plastics — poly mailers, films, foam inserts, plastic clamshells.

Exclusions: most have expired

Between 2018 and 2020, USTR ran an exclusion process — narrow, product-specific carve-outs from Section 301. Most packaging-related exclusions expired in 2020–2022. The 2024 USTR review (announced September 2024) maintained the broader Section 301 framework and, for some sectors, increased rates. As of early 2026, virtually no broad packaging exclusions remain active for new entries.

Practical implication: don't plan a sourcing strategy around the hope of an exclusion grant. Exclusions are political, narrow, and usually retroactive only to the petition date. Plan around country of origin instead.

How to verify your HTS code

1. Pull the HTS classification used on your last 5 entries from your customs broker. They should have it on the entry summary (CBP Form 7501).
2. Cross-check that classification against the live USTR Section 301 lists, published at ustr.gov.
3. For ambiguous classifications — for example, a mailer that combines paperboard with a plastic insert — request a binding ruling from US Customs and Border Protection. Rulings take 30–90 days but lock in the classification.
4. If you're new to the SKU, ask the manufacturer for the HTS code they use on commercial invoices to other US customers. Cross-check it against your own broker's read.

The Vietnam workaround

When the same SKU is re-sourced from a Vietnamese factory with the substantial transformation occurring on Vietnamese soil, the duty picture changes completely:

• Country of origin: Vietnam
• HTS classification: usually identical to the China-sourced version
• MFN base rate: typically Free for paperboard, 3% for plastics
• Section 301: not applicable
• Section 232 (steel/aluminum): not applicable to packaging
• Anti-dumping or countervailing duties: rare for packaging from Vietnam

For our customers switching a high-volume corrugated SKU from a Shanghai-area supplier to our Hai Duong factory, the typical landed cost reduction is 20–28% — driven almost entirely by the removal of the Section 301 layer.

A note on stacked tariffs

Section 301 is just one of several US import tariff regimes. The full duty stack on a given import can include the MFN base rate, Section 301 (China-specific), Section 232 (steel and aluminum — usually not packaging), Section 201 safeguard tariffs (currently solar cells and washers — not packaging), and case-specific anti-dumping or countervailing duties. For Chinese-origin packaging, Section 301 is the dominant cost driver, and removing it via a country-of-origin change is the single highest-leverage move available to a US buyer.