On July 23, the Office of the United States Trade Representative (USTR) announced final Section 301 action imposing tariffs on goods from 60 economies over failures to prohibit or effectively enforce bans on imports made with forced labor. For Taiwanese exporters, the immediate task is not to quote one flat rate: for non-exempt Taiwanese goods, the most-favored-nation (MFN) duty and this Section 301 duty must be considered together, with a combined rate capped at 10%. The action applied from 12:01 a.m. Eastern Time on July 24. Certain goods loaded before that time and entered within the notice’s deadline may meet the stated transit exception.
First, check whether each product falls within the action and exemptions
Do not estimate cost from a Taiwan origin label alone. Procurement teams, customs brokers, and the U.S. importer should review each HTSUS classification against the Taiwan-specific exemptions in USTR’s final notice, then confirm the product’s MFN duty. If a non-exempt product has an MFN rate below 10%, the Section 301 duty brings the combined rate to 10%; if the MFN rate is already 10% or more, the notice describes the Section 301 duty as zero. This is a combined-duty rule, not a flat additional 10% on every Taiwanese product.
Update customs data and commercial terms together
Because the effective date has passed, first map goods in transit, in bonded storage, and not yet shipped. For every consignment, retain the loading date, proof of final-mode transit, expected entry date, origin data, and the basis for tariff classification. Those records support the entry process and help assess the notice’s transition for goods loaded before July 24 and entered before July 28. For future orders, put classification, origin, exemption review, importer details, and broker instructions into a pre-shipment checklist instead of recalculating cost at the port.
Bring forced-labor risk back to supply-chain evidence
The policy context for this action is the prohibition and enforcement of imports made with forced labor. Tariff calculation is not the same as completed due diligence. Even where an item has no additional duty or is exempt, an exporter should be able to explain its supply-chain sources and documentary trail to the customer. Start with a product-level supplier list, raw-material and processing locations, purchase orders, commercial invoices, packing lists, and traceability records. Make procurement, quality, sales, and the U.S. importer accountable for the same current file. For higher-risk materials or subcontracting, ask the U.S. customer and its customs adviser early which evidence format they require.
Turn quotation terms into an updateable cost mechanism
The notice includes product exemptions, and a tariff-rate quota mechanism for some textiles and apparel will be announced separately when USTR determines it is feasible. Do not write today’s assessment into a permanently fixed landed cost. In quotations and contracts, separate product price, freight, current duties, and responsibility for import charges, while preserving a re-estimation mechanism if classifications, exemptions, or government notices change. For textiles, electronic components, and multi-country processing, assign one owner to monitor USTR notices, HTSUS changes, and actual entry feedback from the U.S. importer.
Four checks to complete now
- Confirm HTSUS, origin, and MFN duty for every U.S.-bound SKU.
- Match the item to the Taiwan exemptions in USTR’s final notice; do not infer from a product name.
- Keep loading and entry-time evidence for transit goods and have the U.S. importer and broker assess it.
- Share traceability records and the revised duty-cost assumption with sales teams and customers.
If you need to bring U.S. duties, origin, and shipping documents into one operating workflow, contact Wei Yao Trading to clarify the pre-shipment evidence and communication checkpoints.
