11.8%

What changed this week

Nothing category-specific in the April 10–17 Federal Register window. The relevant story is the ongoing one: most apparel HTS sits in the 10% §122 baseline, so apparel importers have outsized exposure — and an outsized claim on the $175B refund pool. A $10M-revenue apparel brand with 65% Vietnam / 35% China sourcing may have paid $120K–$250K in recoverable IEEPA duty over 2025.

What it means — current duty stack

MFN base rates vary by specific 10-digit HTS; ranges shown.²⁸²⁹³⁰

Section 232 does not apply to apparel directly. Apparel with metal trim or hardware may be caught by the April 6 derivative expansion if metal content is substantial — technical outerwear with aluminum/steel components should audit.

The play — fiber-content reclassification (6202)

The women’s outerwear heading 6202 is structured by shell fiber content and the duty rate moves materially across subheadings:²⁸³¹

The delta between 6202.13 (MMF) and 6202.12 (cotton) is ~18.8 percentage points of MFN alone. If an outerwear construction is currently classified under 6202.13 because the shell is >50% polyester/nylon, shifting to ≥50% cotton blend (or introducing a cotton outer layer) drops the classification to 6202.12 and strips 18.8 points off the MFN. On $100K imported under that HTS, savings are ~$18,800 per cycle.

This is a defensible classification move, not a reclassification gimmick. CBP Form 177 binding rulings on fiber-content shell classification are well-established — pull a few on CROSS to confirm scope before committing.³²

Caveat: we have not verified this play against a specific brand’s product spec. Framework is sound; the fabric-premium and break-even assumptions should be stress-tested against supplier quotes before acting.

What changed this week

The Section 232 derivative expansion (April 6) is the sleeper story. Annex I-B of the April 2 proclamation covers, among other items: household articles, cutlery, door hardware, bearings, various machinery, insulated electrical conductors, certain automotive parts, certain vehicles and trailers.⁷³³ For small-goods sellers, the operationally relevant items are insulated electrical conductors (HTS 8544), many small-appliance housings, and anything with substantial steel/aluminum content.

Current duty stack — China-origin

For Vietnam origin, subtract the §301 column (no direct §301, though CBP circumvention enforcement on China-to-Vietnam transshipment is active). Mexico: USMCA may zero the MFN but §122 still applies; §232 derivative exposure is origin-agnostic.

The §232 derivative trap — the most-missed change

Pre-April 6, a power strip containing $3 of aluminum heat-sink paid §232 only on the $3. Post-April 6, that same power strip — if classified as a covered derivative — pays 25% on the full customs value of the power strip, not the aluminum content. For a $40 landed power strip, that’s $10 of new duty, not $0.75. This hits harder on products where the metal is structural rather than trim: aluminum-housing LED fixtures, steel-body small appliances, wired goods with copper/aluminum conductor.

De minimis — dead for your business model

Section 321 is fully suspended globally. Every commercial small-parcel shipment requires formal entry, regardless of value or origin.⁸⁹ Any inventory model built on China-origin <$800 parcels flowing direct-to-consumer via §321 is no longer viable. Formal entry means: full MFN + §301 + §122 + §232 + any AD/CVD.

The play — First Sale for Export (FSFE)

FSFE is a customs valuation method that lets the importer declare duty on the price paid by the middleman to the factory, not the price paid by the US importer to the middleman. For FBA operators sourcing through Hong Kong trading companies, Alibaba reseller aggregators, or multi-tier agents, the gap between factory price and invoiced price is typically 15–35%. Applying FSFE on a high-MFN-rate SKU (e.g., HTS 6402 footwear at 20%, or §301-hit electronics) drops the duty base by that same 15–35%.

The bar is real: bona fide documentation of the earlier sale, clear title transfer, and arm's-length pricing. Most FBA operators sourcing direct-from-factory don't qualify. But operators using trading companies often do, and most don't realize it — brokers rarely volunteer FSFE because the documentation burden falls on them.

What changed this week — and it’s everything

The April 6 restructuring is the category-defining event of 2026 so far. The prior regime’s quarterly inclusion process is terminated. Commerce + USTR may now expand coverage on a rolling basis at their own discretion without the product-petition comment cycle.⁷³⁶

Current duty stack — post-restructuring

Country treatment — collapsed to baseline

Prior country-specific TRQs (EU, UK, Japan, South Korea) are eliminated under the new regime. Country-rotation playbooks are dead plays.⁷¹⁷

The duty-base trap

Under the prior regime, a $100 steel derivative containing $20 of covered steel paid 50% × $20 = $10 of §232. Under the new regime, that same product pays 25% × $100 = $25 — a 2.5× increase on an identical article despite the nominal rate moving down from 50% to 25%.⁶⁷

The play — US-melted-and-poured sourcing

The ≥95% US melted-and-poured carve-out (10% rate, vs. 50%) is the largest structural arbitrage the new regime opens.⁷ For manufacturers with overseas machining or fabrication capacity, it is now economic to: source raw steel or aluminum from a US mill, ship to overseas fabrication, and re-import the finished component. Import pays 10% §232 — the US origin of the metal governs, not the country of fabrication. Documentation bar: mill test reports (MTRs) must establish US melt-and-pour with ≥95% metal content.