On 24 July 2026, at 12:01 a.m. Eastern, two things happened in the same minute.
The 10% universal surcharge that had been running under Section 122 of the Trade Act of 1974 since February hit its 150-day statutory ceiling and expired. In that same minute, a new Section 301 forced-labour action took effect, covering roughly 60 economies at either 10% or 12.5%.
If you were holding a DDP quote across that minute, nothing about your cargo changed. Your landed cost did. That is why this article exists: most DDP quotes never say what happens when the rate moves, and in 2026 the rate has moved twice.
First, what “Section 301” actually refers to now
This is where a lot of confusion starts, because there are two separate things wearing the same name.
The original China lists. These have been in place for years — roughly 25% on most covered goods across the earlier lists, 7.5% on the List 4A tier, with a few strategic categories carrying higher rates after the 2024 four-year review. These did not go away in July.
The new forced-labour action. Announced 23 July 2026 and effective the following minute, this covers around 60 economies at two tiers: 10% for those found to have at least partial forced-labour import protections in place, 12.5% for the rest. China sits in the 12.5% tier.
The critical word is stacks. The July action did not replace anything. It was added on top.
So a China-origin product currently faces, at minimum:
A product with a modest base rate that sits on the 25% list is now well past 40% combined. A product on the 7.5% tier lands differently. The only way to know your number is to run your own HTS code — which is exactly why any DDP quote that doesn’t name your HTS code is not really a quote.
A limited set of product exclusions exists and runs on its own timetable. Check whether yours qualifies rather than assuming. How that stack sits inside the rest of the DDP price: how DDP pricing from China to the US actually works.
The question that actually matters
Here it is, and it is worth asking before you book anything:
If the duty rate changes between this quote and the entry date, who absorbs it?
There are three honest answers:
- We absorb it. The forwarder is carrying the risk, which is usually priced in somewhere. Legitimate, and you should expect a slightly higher number.
- You absorb it. The quote is freight-firm and duty-variable. Also legitimate — and it means your landed cost is an estimate, not a price.
- We split it above a threshold. Common on longer-term arrangements.
And there is one dishonest answer: silence. A quote that doesn’t address it isn’t neutral. It means the question gets settled after the fact, in a conversation where you have already paid the deposit and the container is already on the water.
Duty is generally assessed at the rate in effect when the goods are entered, not when you were quoted. That gap — booking to entry — is where the exposure lives, and on ocean freight from China it’s usually several weeks.
Why “all-in, duties included” needs a follow-up question
“Duties included” tells you the forwarder intends to pay the duty. It does not tell you:
- What they’re declaring. A duty-inclusive price built on a lower-duty HTS classification is cheaper for a reason that isn’t efficiency.
- What value they’re declaring. Duty is calculated on customs value. Understate the value, understate the duty.
- What origin they’re declaring. Origin drives which tariff tier applies.
These three fields determine most of the spread between DDP quotes on identical cargo. Freight, terminal charges, and trucking are near-commodities. The declaration is where the variance is. Same pattern, on the quote itself: is the cheapest freight quote the best one?
And under US customs law, the Importer of Record carries responsibility for classification, valuation, and origin — regardless of what your commercial contract says. A misclassification found on audit is assessed retrospectively against prior entries, not just the one that got caught. Who that party is: what DDP actually covers, and who is legally responsible.
The saving is immediate. The exposure is deferred. That asymmetry is why the practice survives.
What changed on the compliance side, too
On 3 June 2026, Executive Order 14411, “Strengthening Customs Enforcement,” directed DHS and CBP to overhaul the rules governing importers of record. Most of the detail requires rulemaking, but the direction is not ambiguous:
- All IORs, US and foreign, will need minimum tangible domestic assets, bond coverage, or both — and minimum bond amounts are set to rise
- Foreign IORs face new restrictions, including a prohibition on filing informal entries
- Expanded disclosures covering ownership, beneficial ownership, affiliations, domestic assets, and expected import volumes
- A “good standing” standard tied to compliance history
- A minimum penalty floor on mitigated violations
The order carries deadlines at 45, 90 and 180 days from signing, placing the bulk of it in the last quarter of 2026. Litigation on several 2026 tariff measures is also ongoing.
Practical translation: DDP structures that depend on an opaque or thinly-capitalised IOR are on a clock. If you can’t name the entity filing your entries, that’s worth resolving before December rather than after.
Four questions to ask your forwarder this week
- What HTS code will be declared on my goods?
- What is the combined duty rate at that code today — base, original 301, and the July action?
- If the rate changes before entry, who absorbs it?
- Which entity is the Importer of Record, and whose bond?
A forwarder doing this properly answers all four in one message. One who can’t isn’t selling you a logistics service — they’re selling you an outcome and keeping the method to themselves. Those are different products carrying different risk.
Where we stand
We quote DDP by the kilogram as our default for US-bound cargo, and we tell you the classification and the duty basis before you book — not after. When a rate moves between quote and entry, we say in writing beforehand who carries it.
We’re rarely the cheapest DDP quote. Quotes below ours generally don’t differ in freight. They differ in what gets written on the entry, and that difference doesn’t stay with the forwarder.
Send us the product. We’ll show the current duty stack.
A photo and a description is enough if you don’t have the HTS yet. Free, no obligation. Mon–Sat, 08:00–22:00 China time (GMT+8).
Tariff measures described here were current as of August 2026 and remain subject to rulemaking and litigation. Confirm rates against your own HTS classification with a licensed customs broker. This is general information, not legal advice.