After 9 November: New Landed Costs for First Aid Kits

Updated as of 2 November 2026. The 178 Section 301 product exclusions (HTS 9903.88.69 and 9903.88.70) are scheduled to expire at 11:59 p.m. Eastern on 9 November 2026. No extension had been announced as of this date. This article is written to survive whichever way the decision goes.

1. The deadline is real, and so is the uncertainty

For most of the past year, the US tariff conversation has been about deadlines: the truce deadline, the exclusion deadline, the vessel-fee deadline. The next one is 9 November, and as we write — one week out — the position is genuinely unresolved:

*The 178 remaining Section 301 product exclusions — 164 product-specific lines carried forward in May 2024 plus 14 for solar equipment — expire at the end of 9 November unless USTR publishes an extension. As of 1–2 November, no extension has been announced.

*The suspension of maritime service fees on China-linked vessels was proposed by USTR on 26 October to be extended two months, to 9 January 2027. The comment period closed on 30 October. The extension is not yet adopted. If it lapses, vessel fees resume — up to USD 80 per net ton on Chinese-operated vessels under the current tier — and while the fee is owed by the vessel operator, the industry's consistent experience is that it migrates into freight rates and surcharges.

*The structural layers are unaffected by any of this: the 12.5% forced-labour duty on Chinese-origin goods (effective 24 July 2026, no expiry), the Section 301 list rates (25% on Lists 1–3, 7.5% on List 4A), Section 232 actions, and antidumping and countervailing duties where they apply.

We set out the deadline mechanics in detail in our 9 November analysis and the original exemption picture in the 2026 tariff guide. This article is about what comes after: how to structure your landed cost for the three realistic outcomes, and what to do this week so that none of them catches you unprepared.

2. The one rule that decides everything: entry date, not order date

Before the scenarios, fix this principle in place, because it governs all of them.

What matters is the date your goods enter for consumption — not the order date, not the invoice date, not the sailing date. Goods that clear customs before midnight on 9 November can still claim an exclusion; goods that clear on 10 November cannot, unless the exclusion is extended. A container loaded today on the ocean will not enter before the deadline — transpacific transit alone runs roughly two to three and a half weeks door-to-door. This is why, in the final week, air freight has become an entry-date control tool rather than a speed convenience: a shipment tendered now can realistically clear before the window closes; one on the water cannot.

The same logic applies in reverse: if an extension is announced late — and the historical precedent is that USTR extensions have sometimes been published after the original expiry date — entries made in the gap have generally paid the full rate and not been refunded automatically. Filing for retroactive correction is possible but slow and not guaranteed. Prudent importers plan around the published deadline, not around the hope of a late rescue.

3. Scenario A: the exclusions lapse on 10 November

This is the baseline the Federal Register currently supports.

What changes mechanically. Entries on or after 10 November can no longer claim 9903.88.69 or 9903.88.70. The product pays its normal Section 301 list rate — typically 25% (Lists 1–3) or 7.5% (List 4A) — stacked on top of its base MFN duty, the 12.5% forced-labour duty, and any other applicable layers. There is no phase-in: the same SKU pays a different total depending on the day it clears.

What it means for a first aid kit programme. For an importer bringing in USD 500,000 per quarter of goods that were riding a 25% list exclusion, the difference is roughly USD 125,000 per quarter — straight off gross margin unless it is repriced. Most kit components are not on the exclusion lists in the first place, but some specific components and materials are, and if any of your SKUs claim an exclusion today, the arithmetic below applies to them from 10 November.

The actions this scenario demands — ideally completed this week:

1.Pull twelve months of entry summaries and list every line currently claiming 9903.88.69 or 9903.88.70, with the exact 10-digit HTS code and exclusion description. A description mismatch discovered at the port on 10 November is an expensive way to learn you were never covered.

2.Re-run the landed cost at the full list rate for every affected SKU. Decide now — not after the first post-deadline entry — whether you absorb, reprice, or re-source.

3.Rank SKUs into "must land before the deadline" and "can wait." High-velocity, high-margin excluded items already in transit may justify accelerating entry; slow movers can ride the ocean and take the duty.

4.Check your customs bond. A step-change in duty spend can trigger a bond insufficiency notice from your surety. Size the bond to the new duty reality before CBP flags it, not after.

4. Scenario B: USTR extends before the deadline

This is entirely possible. The exclusion programme has been extended repeatedly since 2018, the extension decision in 2025 followed the US–China trade arrangement announced on 1 November, and both governments have a stated interest in keeping the truce intact through its current horizon.

What changes if it happens. Very little, immediately — exclusions continue to be claimable, and the planning question reverts to the next deadline. The vessel-fee extension to 9 January 2027, if formally adopted, removes the near-term rate-and-surcharge risk on affected services.

Two cautions even in this scenario. First, a late announcement creates a gap risk: if the extension is published after 9 November, entries in the interim are exposed, and history says this is a real pattern, not a theoretical one. Second, an extension is a postponement, not a resolution — every extension to date has carried a new expiry, and building your pricing on "the exclusion is permanent" is exactly the assumption this year was designed to break. Treat any extension as buying planning time, not as cancelling the scenario-A work above.

5. Scenario C: a lapse followed by retroactive relief

The least discussed and most operationally annoying outcome: the exclusions lapse, entries pay full rates for days or weeks, and USTR then extends retroactively or reissues the programme.

What this means practically. Retroactive relief of this kind does not reliably flow back to importers automatically. Correcting entries after the fact is possible through post-summary corrections and protests, but it is administrative work — filing, evidence, timelines, fees — and cash is out the door in the meantime. If your programme has meaningful exclusion exposure, the hedge is documentation: complete entry records, HTS substantiation and a broker who can move quickly if a correction window opens. You do not control whether relief comes; you control whether claiming it is easy when it does.

6. The landed cost maths you should be able to do from memory

Whichever scenario lands, the stacking order for Chinese-origin first aid products into the US currently reads, from the bottom up:

1.Base MFN duty — product-specific, usually single digits for dressings, plasters and kit cases

2.Section 301 list duty — 25% (Lists 1–3) or 7.5% (List 4A), unless an exclusion applies.

3.The 12.5% forced-labour duty — effective since 24 July 2026, no expiry, not part of the truce.

4.Any Section 232 / AD / CVD layers — product-specific.

5.Freight, insurance, fees — currently elevated: transpacific rates remain roughly double to triple their year-ago levels even after the autumn peak, per the market data we track in our freight capacity piece.

For a typical assembled kit, the practical total of duty layers for Chinese-origin goods sits in the region of 37–40% today — and the exclusion question determines whether a specific line sits at the bottom, middle or top of that range. One caution repeated from our earlier coverage: most first aid kits are duty-stacked line by line, not as a whole box. The kit's case, the dressings, the instruments and the wipes can carry different HTS classifications and different treatments. Averaging across the kit is how importers end up with a landed cost model that does not match their entry summaries — and with USMCA-qualified or non-Chinese-origin alternatives now commercially relevant for some components, the line-by-line view also tells you where alternative sourcing actually pays.

Also remember that the de minimis escape hatch is gone: duty-free treatment for shipments under USD 800 was suspended indefinitely in June 2026, so every unit carries a duty line whether it arrives in a container or a poly mailer. E-commerce sellers repricing for Q4 need the full stacked rate, not the container-only assumption.

7. What this means for how you buy

There is a supplier-side version of every point above, and it is the part we can actually influence.

Component-level documentation is now a duty tool, not just a quality tool. Because treatment can differ line by line, a kit quotation that carries the BOM broken to component level — which is how we quote — lets your broker classify precisely instead of estimating. The difference between a well-documented BOM and a generic contents list is, this year, potentially several percentage points of duty on the wrong lines.

Origin questions deserve a straight answer. Where a component line genuinely benefits from an exclusion or an alternative origin, the documentation has to support it. We flag origin-relevant lines at quotation rather than leaving them to be discovered at the port.

Timing conversations are production conversations. If entry timing matters to your duty position, tell us — production slotting, inspection scheduling and document readiness all move the achievable entry date. We would rather shape the production plan around your clearance window than have a real date turn into a missed one.

Repricing a programme for 2027 with the new duty stack? Send us the kit list and your entry pattern — we will provide the component-level BOM, carton data and honest production dates so your broker can run the stacked landed cost properly. That is the whole basis of a 2027 price that holds.

8. FAQ

The exclusions expire 9 November. Has an extension been announced?

As of 2 November 2026, no. USTR's most recent tariff action was the proposed two-month extension of the vessel-fee suspension to 9 January 2027, which had not been adopted at the time of writing. Check the Federal Register and your broker for the latest before acting on this article.

Will duties be refunded if an extension comes late?

Not automatically. Historical precedent shows extensions published after the original expiry create gap periods where entries paid full rates; recovery requires post-summary corrections or protests, with no guarantee. Plan around the published deadline.

Does the 12.5% forced-labour duty apply to first aid kits?

It applies to Chinese-origin goods generally under its scope, unless a product qualifies for a specific exemption or preference. We addressed the exemption picture — including which medical-consumable categories were named as exempt — in the 2026 tariff guide. Your broker should confirm treatment by HTS line.

Should I air freight everything before the deadline?

No — and it is no longer physically possible for new ocean orders anyway. Air freight in the final week is a targeted tool for goods already produced and for high-velocity excluded SKUs. The better long-term strategy is the landed-cost restructure described above.

How do I know if my SKUs claim an exclusion?

Ask your broker for twelve months of entry summaries and search for the 9903.88.69 and 9903.88.70 claims. If you find none, scenario A costs you nothing on the exclusion line — but the bond, pricing and sourcing review is still worth doing for the layers that never expire.

Can Kebon help with the classification side?

We provide the component-level documentation your broker needs to classify accurately — BOMs, materials, origin-relevant lines. The legal classification opinion is your broker's job; the quality of the inputs is ours. Start with a quote request and ask for the documented BOM alongside it.