Mainrich International
Compliance10 min readMay 5, 2026

Section 301 25% Tariff on Chinese NdFeB Magnets: What US Buyers Should Price Into 2026 Quotes

On 1 January 2026 the longstanding Section 301 exemption for permanent magnets ended. Imports of NdFeB and SmCo magnets from China now carry an additional 25% USTR duty on top of the 2.1% MFN base rate. Here is how to read the tariff stack, run a landed-cost example, and structure 2026 POs so the duty stops being a surprise.

Mainrich International

Mainrich International

Engineering Team

Section 301 tariff NdFeBpermanent magnet tariff 2026HTS 8505.11 NdFeBChinese magnet import dutyUS tariff rare earth magnetmagnet procurement landed costSection 301 USTR magnetduty drawback magnet FTZ
Customs inspection bay at a US port of entry with NdFeB magnet shipments, HTSUS classification paperwork on a clipboard, and gantry cranes overhead.

Key Takeaways

  • USTR's 25% Section 301 duty on permanent magnets imported from China took effect 1 January 2026, ending an exemption that had held since the original 2018 List 4A action. The duty applies to HTSUS 8505.11 (sintered NdFeB and SmCo) and 8505.19 (other permanent magnets, including bonded NdFeB).
  • The full duty stack on a sintered NdFeB magnet of Chinese origin is now roughly 27.1%: 2.1% column-1 general MFN duty plus the 25% Section 301. Sintered NdFeB under HTS 8505.11.00.70 was carved out of IEEPA-based 'Executive Tariffs' under Annex II of the US-China framework, so the IEEPA layer does not stack here. Bonded NdFeB under 8505.19 may carry additional layers depending on classification.
  • On a $30/kg FOB Shanghai N42SH motor magnet, the additional 25% Section 301 alone adds roughly $7.50/kg, taking landed cost from approximately $33/kg DDP (pre-2026) to roughly $41/kg DDP (post-2026), excluding ocean freight and brokerage variance.
  • Incoterms determine who writes the duty check at clearance, not who economically absorbs it. Under DDP the seller pays customs but typically reprices upstream; under FOB or EXW the buyer-of-record pays directly. Either way, expect supplier quotes signed in 2025 with 2026 delivery to surface tariff-related repricing requests.
  • Mitigation paths exist but each carries operational cost: Foreign Trade Zone (FTZ) admission defers duty until US entry and eliminates it on re-export, duty drawback recovers up to 99% of paid Section 301 duty on subsequent export within 5 years, and origin diversification (non-Chinese NdFeB from MP Materials, USA Rare Earth, Neo Estonia, Carester) avoids the 25% layer at a 30-60% product-price premium today.
  • Q4 2026 is the next pressure point: MOFCOM's suspension of the 9 October 2025 expanded export controls expires 10 November 2026. If those rules snap back, HREE-bearing grades (H/SH/UH/EH) face tighter export licensing on the Chinese side at the same time the 25% Section 301 layer compounds on the US side.
01

What Changed on 1 January 2026

USTR's 14 May 2024 announcement and 13 September 2024 final modification of the Section 301 China action set staged tariff increases across strategic categories. Permanent magnets sat in the 2026 tranche. The mechanism is straightforward: the existing exemption that had kept HTS 8505.11 (sintered NdFeB, SmCo) and HTS 8505.19 (other permanent magnets, including bonded NdFeB) outside the List 4A 25% duty was removed effective 1 January 2026. Customs entries with country-of-origin China cleared from that date forward carry an additional 25% ad valorem duty on top of the column-1 general MFN rate. The duty applies to magnetized product, not just to the rare earth oxides or metal upstream. There is no de minimis carve-out for low-value samples used in qualification: the duty applies on entered value regardless of shipment size, though merchandise valued under $800 entering by personal use channels may still benefit from informal entry rules in narrow circumstances.

02

Reading the HTSUS: 8505.11 vs 8505.19 vs 8505.20

Three HTSUS lines matter for magnet importers, and getting the classification right protects against both overpayment and CBP penalty exposure. HTS 8505.11 covers permanent magnets and articles intended to become permanent magnets after magnetization, of metal: sintered NdFeB and SmCo land here. HTS 8505.11.00.70 is the specific statistical breakout commonly used for sintered NdFeB. HTS 8505.19 covers other permanent magnets, principally bonded NdFeB, ferrite (ceramic), and AlNiCo. HTS 8505.20 covers electromagnets and electromagnetic couplings, clutches, and brakes, which are not in scope here. Practical implications: a customer importing a finished motor or actuator with an integrated magnet is generally classified under the parent assembly's HTS, not under 8505. A customer importing loose magnets, magnetized blocks, or arc segments for downstream assembly does classify under 8505 and faces the duty stack. Misclassification (intentional or not) carries up to 4x duty penalties under 19 USC 1592, so when in doubt, get a binding ruling from CBP before the first commercial shipment.

03

Worked Example: $30/kg FOB to DDP Landed

Take a representative N42SH sintered NdFeB ring for a humanoid hip actuator, 60 mm OD, with NiCuNi coating, sourced from a Chinese factory at $30/kg FOB Shanghai. Assume a 20-foot container with $4,500 ocean freight allocated across a 2,000-kg net magnet load (approximately $2.25/kg ocean), $0.40/kg insurance and brokerage, and 2.1% MFN duty plus the 25% Section 301 layer applied to the customs entered value. Pre-1 January 2026, the buyer's landed DDP cost worked out to roughly $33/kg: $30 product + $2.25 freight + $0.40 brokerage + $0.63 MFN duty. Post-1 January 2026, that same magnet now carries an additional $7.50/kg in Section 301 duty, taking landed DDP to approximately $40.78/kg. That is a roughly 24% increase in fully landed cost on the same physical product. On a 5,000-unit annual program at 0.4 kg of magnet per unit, the annualized tariff impact is approximately $15,000. On a 50,000-unit program, it is $150,000. These figures are linear in volume and product price, so they scale predictably and should be modeled into 2026 procurement budgets explicitly.

  • Product (FOB Shanghai): $30.00/kg
  • Ocean freight (allocated): $2.25/kg
  • Insurance + brokerage: $0.40/kg
  • MFN duty (2.1% on entered value): $0.63/kg
  • Section 301 duty (25%, post 1 Jan 2026): $7.50/kg
  • Landed cost DDP post-2026: ~$40.78/kg (vs ~$33.28/kg pre-2026)
04

Incoterms and Contract Pass-Through

Incoterms govern who is the importer of record and who pays customs at the border. They do not, by themselves, govern who absorbs the tariff economically. Under FOB or EXW, the US buyer is the importer of record and writes the duty check directly. Under DDP, the Chinese seller (or their forwarder) writes the check, but no rational seller absorbs a 25% line item indefinitely. Expect three patterns in 2026 supplier conversations. First, suppliers on existing DDP terms will request renegotiation to FOB or seek a tariff-pass-through clause, often phrased as a 'Section 301 surcharge' line. Second, suppliers on FOB/EXW terms will leave the duty problem to the buyer entirely, which is cleaner accounting but does not reduce the cost. Third, contract price-lock language signed before September 2024 (when USTR finalized the action) generally did not contemplate the 2026 tariff and is now a renegotiation lever for either side. Procurement teams should review every open PO with 2026 delivery dates, calculate the new DDP-equivalent cost, and decide whether to absorb, pass-through to end-customer pricing, or seek mitigation.

05

Mitigation Paths That Actually Work

Four mechanisms reduce or defer Section 301 exposure, with very different effort-to-savings ratios. Foreign Trade Zones admit imported magnets without paying duty until withdrawal for US consumption; goods re-exported from the FTZ pay no Section 301 at all. This is the right tool for buyers who assemble subassemblies in the US for export markets, since the assembly-then-export path becomes duty-free. Duty drawback under 19 USC 1313 allows recovery of up to 99% of paid Section 301 duty on imported magnets that are subsequently exported, either as-is or incorporated into a finished article, within five years of entry. Drawback claims require careful recordkeeping (manufacturing direct identification or substitution drawback paperwork) but are mature and high-yield for export-heavy programs. USTR product-specific exclusion processes have historically allowed petitions for relief on specific HTS subheadings; as of May 2026, no broad permanent-magnet exclusion has been granted, but the channel remains open and is worth monitoring through industry associations. Origin diversification through non-Chinese NdFeB suppliers (MP Materials in Texas, USA Rare Earth in Oklahoma, Neo Performance in Estonia, Carester Caremag in France from late 2026) avoids the 25% duty entirely but at a current product-price premium of roughly 30-60% over comparable Chinese product, with capacity allocations forming through 2026 and 2027.

  • FTZ admission: zero duty on re-exported magnets, deferred duty on US-consumed product
  • Duty drawback (19 USC 1313): up to 99% Section 301 recovery on subsequent exports within 5 years
  • USTR exclusion petition: open channel but no broad magnet exclusion granted as of May 2026
  • Origin diversification: 30-60% product-price premium on non-Chinese NdFeB, allocations forming now
06

Procurement Takeaways for 2026

Three practical actions belong on the May 2026 procurement to-do list. First, run the landed-cost recalculation on every active SKU with Chinese-origin magnets and a 2026 delivery date. The math is simple and the scale is material. Second, add explicit tariff language to 2026 POs and renewals: specify Incoterms, name the importer of record, decide pass-through behavior on tariff escalations, and require advance notice of any HTS reclassification proposal from the supplier. Third, where program economics allow, qualify a non-Chinese NdFeB source for at least one part number this year. The Western capacity ramp (MP Materials Texas, USA Rare Earth Oklahoma, Neo Estonia, Carester France) is real but small relative to demand, and qualification queues are forming. Engaging now buys allocation priority and a hedge against the November 2026 MOFCOM expiration date, when the Chinese-side export-control suspension lapses and the duty-and-licensing burden could compound. None of this requires panic; it requires a clean spreadsheet, a phone call to your customs broker, and a frank conversation with each supplier about who pays what under which circumstances.

Key Insight: Mainrich provides FOB Shanghai and DDP US quotations on request, and supplies the HTSUS classification, country-of-origin certificate, and harmonized commercial invoice line items that brokers need for clean Section 301 entry. We can also coordinate FTZ admission documentation for buyers operating in zones such as San Diego, Long Beach, Detroit, and Savannah.

FAQ

Frequently Asked Questions

Does the 25% Section 301 tariff apply to NdFeB magnets imported in finished motors or actuators?

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Generally no, when the magnet enters the US as part of a finished motor, actuator, sensor, or other assembly classified under a different HTS heading (for example HTS 8501 for motors), the parent classification governs. The Section 301 duty hits magnets entering as standalone product under HTS 8505.11 or 8505.19. That said, CBP looks at the substantial-transformation test and the principal-use test to determine classification, so a 'kit' that is just a magnet plus minor hardware will likely still be classified under 8505. When in doubt, request a binding ruling before the first commercial shipment.

Is sintered NdFeB also subject to the IEEPA 'Executive Tariffs' on top of Section 301?

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No, sintered NdFeB classified under HTS 8505.11.00.70 was carved out of IEEPA Executive Tariffs under Annex II of the US-China tariff framework. The duty stack for that classification is therefore the column-1 general MFN rate of 2.1% plus the 25% Section 301 layer, totaling roughly 27.1% on entered value. Other 8505.xx classifications (notably bonded NdFeB and ceramic ferrite under 8505.19) may stack additional IEEPA layers depending on the specific subheading and current Annex II status. Confirm the tariff stack with your customs broker for the exact HTS line you are importing under.

Can we avoid the Section 301 duty by importing magnets from a non-Chinese country that uses Chinese-origin material?

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No, country-of-origin for tariff purposes is determined by where the last substantial transformation occurred, not by where the goods shipped from. Magnetization and machining of a Chinese-origin sintered block in a third country generally does not constitute substantial transformation under CBP precedent, so origin remains China and the duty applies. Genuine non-Chinese supply requires non-Chinese sintered material as the starting point, which today means MP Materials, USA Rare Earth, Neo Performance Estonia, or recycled-feedstock magnets from Carester Caremag in France from late 2026. Documentation matters: request mill test certificates, country-of-origin affidavits, and ideally a NAFTA-style CBP Form 434 or successor document for the specific shipment.

How does duty drawback work for NdFeB magnets that we export in finished products?

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Under 19 USC 1313, an importer can recover up to 99% of paid duties (including Section 301) on imported merchandise that is subsequently exported, either as-is (unused merchandise drawback) or after incorporation into a manufactured article (manufacturing drawback). Claims must be filed within five years of import. Drawback is record-intensive: you need to demonstrate the linkage between the imported magnet entry and the export shipment, either by direct identification (lot tracking) or by substitution under the appropriate accounting method. For export-heavy programs (defense, aerospace, certain industrial OEMs), the recovery typically pays the compliance overhead many times over. A licensed drawback broker handles the filing.

Should we expect the Section 301 rate to rise above 25% later in 2026?

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USTR has not announced a further increase on permanent magnets beyond the 25% level that took effect 1 January 2026. The next scheduled inflection point on the China policy track is the 10 November 2026 expiration of MOFCOM's suspension of the 9 October 2025 expanded export controls, which is a Chinese-side export licensing question rather than a US-side import duty question. A separate watch item is the IEEPA Annex II carve-out for HTS 8505.11.00.70 sintered NdFeB: that carve-out was added under the current US-China framework and could be revisited in any future bilateral negotiation. Procurement teams should monitor USTR Federal Register notices and the IEEPA Annex II text for changes.

Does the duty apply to small qualification samples and PPAP shipments?

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Yes, the Section 301 duty applies to entered value regardless of shipment purpose, including qualification samples, PPAP shipments, and small-volume engineering builds. There is no de minimis exemption for commercial entries on the Section 301 list. For very low-value shipments under $800, informal entry rules may simplify the paperwork but the duty still applies. Procurement teams running multiple-supplier qualification programs in 2026 should budget the duty into the cost of qualification and decide whether to recover it via drawback if the qualification batch is later exported as part of a finished assembly.

How do FTZs help, and which US zones are most magnet-relevant?

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Foreign Trade Zones admit imported merchandise without paying duty at the time of entry. Duty is paid only when the goods are withdrawn for US consumption, and is waived entirely if the goods are re-exported from the zone. For magnets, the FTZ play is most useful when a US assembler imports magnets, builds them into a subassembly, and ships the subassembly to an export market: the magnet's Section 301 duty is never paid. Major FTZ-enabled industrial clusters relevant to magnet assembly include FTZ 153 (San Diego), FTZ 50 (Long Beach), FTZ 70 (Detroit), FTZ 26 (Atlanta/Savannah), and FTZ 21 (Charleston). Operating an FTZ adds compliance overhead, so the math works best on annual import volumes above roughly $1 million in entered value.

What documentation should we ask Chinese magnet suppliers to provide for clean Section 301 entry?

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Request the following for every shipment: a commercial invoice with the HTSUS line clearly stated (typically 8505.11.00.70 for sintered NdFeB), country-of-origin marking on packaging consistent with 19 CFR Part 134, mill test certificates showing magnetic properties and grade, a packing list with net and gross weights per carton, and a country-of-origin certificate. For drawback or FTZ-admitted shipments, also request lot or batch traceability so the import entry can be matched to specific export shipments later. A cooperative supplier will also flag any classification ambiguity (for example, if a part number could plausibly fall under either 8505.11 or 8505.19) before the first shipment, since misclassification is the buyer's customs risk, not the supplier's.

Need a clean Section 301-aware quote on N35-N52 NdFeB or H/SH/UH/EH grades, with HTSUS line items and country-of-origin documentation included? Send your spec sheet and we will respond within 1 business day, with a full DDP US landed-cost breakdown within 2 business days.

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