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Importer of Record deadlines for Q4 2026: five dates and what each one changes at entry

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IORUSA
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In brief

HTS Revision 21 and an amended Section 301 exclusion, the November 9 exclusion expiry, the December 4 polysilicon minimum import prices and 15 percent duty, the January 1, 2027 wood product increases, and the Canada and pharmaceutical measures still in force, with what the Importer of Record needs in the file for each.

Five federal dates between now and January 1, 2027 change what the Importer of Record (IOR) owes or must document at entry for specific classes of goods. Each sits in a Federal Register document that is already published, and each lands on whoever is named as IOR on the entry, not on the seller, the forwarder, or the broker. This post lists each date, what it affects, and what has to be in the file before a shipment lands near it.

The dates, in order: a tariff schedule revision already in effect, a Section 301 exclusion expiry on November 9, Section 232 polysilicon measures on December 4, and Section 232 wood product increases on January 1, 2027, plus two sets of measures that are already in force and stay that way.

Now: HTS Revision 21 and an amended Section 301 exclusion

The United States International Trade Commission published 2026 Revision 21 of the Harmonized Tariff Schedule on October 9, 2026. Its change record lists two items: an erratum to subheading note 1 of chapter 38, and a modification to U.S. note 20(vvv)(i)(20) of subchapter III of chapter 99, effective July 1, 2026.

The second item implements an October 7, 2026 notice from the Office of the United States Trade Representative. When the USITC changed ten-digit statistical reporting categories on July 1, 2026, five of the Section 301 product exclusions on goods of China no longer matched the numbers they were written against. USTR amended four of them in a September 2, 2026 notice and the fifth on October 7, by inserting statistical reporting number 8479.90.9591, effective July 1, 2026, into note 20(vvv)(i)(20). Both notices state that CBP will issue entry guidance. An importer claiming one of the amended exclusions has two things to check: the classification on entries since July 1, 2026 and the Chapter 99 claim against the amended note.

November 9: 178 Section 301 exclusions expire unless extended

On December 1, 2025, USTR extended the 178 remaining product exclusions from the Section 301 duties on goods of China through 11:59 p.m. eastern daylight time on November 9, 2026. The notice describes the decision as extending the exclusions “until November 10, 2026.” Separately, on October 7, 2026, USTR published its determination at the close of the second four-year review that the Section 301 actions themselves continue. The duties stay; the exclusions have an end date. An exclusion is a claim made at entry under the matching heading in subchapter III of chapter 99. If an exclusion lapses, the Section 301 rate applies to goods entered for consumption after the expiry time, and the IOR owes it. Whether USTR extends any of the 178 again is a decision that would appear in a Federal Register notice; as of October 13, 2026, none has been published. Entries that straddle the date are the ones to document now: which heading the goods fall under, which exclusion is claimed, and the entry date on which the claim rests.

December 4: Section 232 polysilicon minimum import prices and the 15 percent duty

Proclamation 11052 of August 6, 2026, issued under section 232 of the Trade Expansion Act of 1962, 19 U.S.C. §1862, sets two measures that take effect for goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on December 4, 2026.

The first is a minimum import price program for polysilicon and the derivatives listed in Annexes I and II: $21 per kilogram for polysilicon, $100 per kilogram for polysilicon ingots and wafers, $0.22 per watt for solar cells, and $0.38 per watt for solar modules. CBP is to permit importers to submit documentation at entry establishing or certifying that the first arm’s-length sale of the merchandise in the United States will occur at or above the applicable price, or that the sale is under fixed terms in a contract signed before August 6, 2026. The proclamation states that an importer whose documentation is materially inaccurate, together with its affiliates, is permanently prohibited from importing these products. That certification is made in the IOR’s name.

The second is an additional 15 percent ad valorem duty on polysilicon ingots and the derivatives in the Annexes, from the same date.

The proclamation also directed Commerce to restrict imports by companies stockpiling ahead of December 4. The Bureau of Industry and Security did that in a temporary final rule published September 24, 2026, in effect from September 22 through December 3, 2026: Commerce monitors imports against each IOR’s volumes since August 6, 2026, and an IOR registered with CBP on or after that date may enter no more than a fixed weekly quantity without Commerce approval. CBP implemented the restriction in CSMS #69994928. The polysilicon stockpiling post has the quantities and the waiver process.

January 1, 2027: Section 232 wood product increases

Proclamation 10976 of September 29, 2025 imposed a 10 percent duty on certain softwood timber and lumber and a 25 percent duty on certain upholstered wooden furniture, kitchen cabinets, and vanities, effective October 14, 2025. Proclamation 11000 of December 31, 2025 delayed the scheduled increases by one year. Under clause 5 as amended, effective January 1, 2027, the rate on upholstered wooden furniture rises from 25 percent to 30 percent and the rate on kitchen cabinets and vanities from 25 percent to 50 percent, “except for countries with which the United States reaches an agreement that addresses the threatened impairment of the national security posed by imports of wood products.” The softwood timber and lumber rate is unchanged.

The proclamation’s rates apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after the effective date. The duty on a container of cabinets is therefore set by its entry date, not its shipping date or its invoice date. Country exceptions depend on agreements announced in the Federal Register as they are reached, so the exception for a given origin is a fact to confirm at the time of entry.

Still in force: Canada measures and pharmaceutical duties

Two sets of measures from September stay in effect through this period.

Products of Canada. Five proclamations signed September 8, 2026 and published September 14 changed the treatment of listed Canadian goods in two steps: an additional 50 percent duty on listed motor vehicle and alcoholic beverage products from September 15, 2026, and exclusion from importation of listed motor vehicle, dairy, and alcoholic beverage products from September 29, 2026. CBP implemented the exclusions in ACE in CSMS #70050117 and #70050970; covered entries not yet released were cancelled, and the covered products cannot be admitted to a bonded warehouse or foreign trade zone. The Canada post lists the headings.

Pharmaceuticals. Under Proclamation 11020 of April 2, 2026, the Section 232 duty of 100 percent on patented pharmaceuticals and the ingredients listed in Annex I applies to products of all companies entered on or after September 29, 2026, under headings 9903.04.60 through 9903.04.70 (CSMS #70054007). A September 23, 2026 BIS notice defines the specialty products that qualify for a zero rate under clause 3(d) and the eligible jurisdictions. The pharmaceutical Importer of Record page covers who holds the role in that supply chain.

What to have in the file before a shipment lands near these dates

  • The entry date each shipment will actually carry, because every one of these measures turns on entry for consumption or withdrawal from warehouse, not on departure or arrival
  • For goods of China claiming an exclusion, the Chapter 99 heading claimed and the amended note text it relies on
  • For polysilicon and derivatives, the price certification or the pre-August 6 contract that the IOR will submit at entry
  • For wood products, the origin and whether a published agreement excepts it
  • For listed Canadian products and patented pharmaceuticals, the heading and whether the goods fall inside the listed scope or an exception

Each of those items is answered from the IOR’s own records. If the IOR role sits with a party that does not hold those records, the Importer of Record page explains what the role requires, and the 2026 requirements summary carries the current enforcement position. Tell us what you import and how your entries are filed today, and we’ll show you where you stand: see if you qualify or write to ship@iorusa.com.

Sources

This post summarizes publicly available federal actions for general information. It is not legal advice. Requirements are subject to rulemaking and change. Verify current requirements against the Federal Register and CBP guidance.

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