Section 301 Coverage of ICT Hardware (Lists 1–4A)
/ˈsɛkʃən θriː oʊ wʌn ˌaɪ siː ˈtiː ˈhɑːrdwɛər/
Section 301 tariffs on Chinese information and communications technology (ICT) hardware apply subheading by subheading, not product category by product category. In short: computer units and parts (servers, storage and I/O units, motherboards) are largely on List 3 at 25%; desktop computers and much telecom equipment are on List 4A at 7.5%; semiconductors now carry 50% after the 2024 four-year review; and laptops and smartphones were on List 4B, which never took effect. Whether a given device owes a Section 301 duty depends on its 8-digit HTSUS subheading and its country of origin.
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In Detail
The Section 301 China action was rolled out in tranches, each reproduced as a subheading list in U.S. Note 20 to Subchapter III of Chapter 99. List 1 (July 6, 2018, 25%, heading 9903.88.01) includes some ADP input and output units (8471.70) and parts (8473.30.20). List 3 (September 24, 2018, 10% raised to 25% on May 10, 2019, heading 9903.88.03) carries most of the computer hardware: processing units such as servers (8471.50.01), input/output and storage units (8471.60, 8471.70), other ADP units (8471.80), and parts including printed circuit assemblies (8473.30.11). Semiconductors were originally on List 2 (August 23, 2018, 25%). Following the 2024 four-year review, the covered semiconductor subheadings of headings 8541 and 8542 have been dutiable at 50% since January 1, 2025, under heading 9903.91.05 (U.S. Note 31).
List 4A took effect September 1, 2019 at 15% and was cut to 7.5% on February 14, 2020 under the Phase One agreement (heading 9903.88.15). For ICT it covers desktop-type computers (8471.41, 8471.49), telephone base stations and transmission equipment (8517.61, 8517.71, 8517.79), headphones and earphones (8518), many television and display subheadings in 8528, and data-transmission apparatus in 8517.62, except modems (8517.62.0010) and switching and routing apparatus (8517.62.0020). List 4B, which held laptop computers (8471.30.01), cell phones, video game consoles and computer monitors, was scheduled for December 15, 2019 but was suspended indefinitely and never collected. That is why a laptop or a smartphone generally owes no Section 301 duty under the China lists, while many of the servers, boards and peripherals around them do.
Status changes through exclusions, extensions and modifications that USTR publishes in the Federal Register. Most of the product-specific exclusions granted in 2018–2020 have expired. The remaining 178 exclusions, mostly machinery, manufacturing equipment and medical goods, were extended in November 2025 through November 10, 2026. To answer the status question for a specific product, confirm the 8-digit subheading (and the 10-digit number where a list carves out statistical breakouts), check it against the Note 20 lists and Note 31 in effect on the date of entry, then check for an active exclusion that names the product.
Classification Significance
Section 301 exposure for ICT hardware is a downstream consequence of classification. The same device can move between a covered and uncovered subheading depending on whether it is classified as a complete machine, a unit of a machine, a part, or a separately classifiable accessory. For example, 8471.30 portable computers versus 8471.50 processing units versus 8473.30 parts. Misclassifying a server as a part, or a module as a complete unit, can flip a 0% Section 301 outcome to 25%, or the reverse. CBP evaluates the Chapter 99 duty against the subheading you declare, so the classification reasoning is what has to hold up.
How Kanon Handles This
Kanon first resolves the HTSUS subheading through a recorded GRI traversal, including the Section XVI and Chapter 84/85 notes that decide machine-versus-part questions for ICT hardware, and then evaluates Chapter 99 overlays against that subheading and the declared country of origin. The Classification Support Package records which Section 301 list was checked, whether the subheading appears on it, and which corpus version the determination was pinned to, so the answer can be re-run when USTR changes the lists.
Frequently Asked Questions
Are laptops subject to Section 301 tariffs?
Generally no. Laptops (portable computers under 8471.30.01) were on List 4B, which was suspended in December 2019 and never took effect. Parts and some peripherals classified elsewhere can still be covered by List 1, 3 or 4A.
Are desktop computers and servers subject to Section 301 tariffs?
Usually yes, at different rates. Desktop-type computers under 8471.41 and 8471.49 are on List 4A at 7.5%. Processing units such as servers under 8471.50.01, and most other ADP units and parts, are on List 3 at 25%.
Are smartphones subject to Section 301 tariffs?
Generally no. Cell phones were on List 4B, which never took effect. Other Chapter 99 measures can still apply depending on country of origin and date of entry, so check every overlay, not just Section 301.
What Section 301 rate applies to semiconductors?
50%. Semiconductors were originally covered by List 2 at 25%. After the 2024 four-year review, the covered subheadings of headings 8541 and 8542 have been dutiable at 50% since January 1, 2025, under heading 9903.91.05.
What is the current status of Section 301 Lists 1, 2, 3 and 4A?
Lists 1, 2 and 3 apply 25%, with higher rates on some products after the 2024 four-year review, and List 4A applies 7.5%. List 4B was never implemented. The remaining 178 product exclusions run through November 10, 2026 unless USTR extends them again. To estimate the combined effect on landed cost, use the import duty calculator.