China+1 for Amazon Brands After July 24, 2026: Duty Layers by Origin and the Lead Time to a US Dock

By Bernardo Campelo, Forbes Business Council E-Commerce Leader, Amazon SPN Certified provider, Amazon SP-API authorized partner, and Founder of PrepVia.

As of October 29, 2026, moving production out of China no longer escapes the newest U.S. duty layer by default. Since 12:01 a.m. Eastern on July 24, 2026, a Section 301 action published by USTR at 91 FR 47318 has added a duty on products of 60 economies, set by origin. China pays an extra 12.5%. So do Colombia, Peru, Chile, Costa Rica, the Dominican Republic and Nicaragua. Mexico, Guatemala, El Salvador, Honduras, Argentina and Ecuador pay 10%.

That changes what a China+1 plan saves. A Colombian factory carries the same 12.5% forced-labor layer as a Chinese one, so the saving on that move comes from the 2018 Section 301 lists on Chinese goods and from the general rate, not from this layer. A Mexican good can take the layer to zero, but only when it enters free of duty under the USMCA or a general exemption applies. In Central America, the trade agreement removes it for textile and apparel goods and for little else.

The second half of the decision is physical. Mexican freight crosses mostly by truck, and mostly through Texas. Goods from Central America, the Caribbean and South America largely arrive by container ship, and that region accounts for nearly half of the trade at the Port of Miami. The duty math picks the country. The route decides where the container lands and how long the units take to reach Amazon.

Every date and name below was checked on October 29, 2026 against the Federal Register, the Harmonized Tariff Schedule (Revision 21 of 2026, reread in Revision 22 on October 30, 2026), CBP guidance, the eCFR, the Court of International Trade, PortMiami, the Bureau of Transportation Statistics and Amazon Seller Central Help, linked where they first appear. Tariff notices change often: confirm each rate with your customs broker on the day of entry.

What Changed on July 24, 2026

The forced-labor action replaced a broad layer that ended the same minute. The Section 122 surcharge in Proclamation 11012 ran "through 12:01 a.m. eastern daylight time on July 24, 2026." From that minute, USTR's notice imposed tariffs "on all products of the investigated economy, with certain exemptions," in each of 60 investigations. Our piece on the three tariff regimes of 2026 covers that sequence and the rate for every group of origins.

The rate follows a rule stated in the notice. Economies that ban forced-labor imports, committed to a ban in an Agreement on Reciprocal Trade, or run a partial regime got 10%. "For every other economy," the notice says, the rate is 12.5%. The notice sets no end date.

Two points decide every China+1 model. First, the duty follows the country of origin, not the port the goods ship from. CBP's FAQ on the China Section 301 duties states the rule: "Section 301 duties are based on country of origin, not country of export." Under 19 CFR 134.1, work done in a second country changes the origin only if it is a substantial transformation, and for goods of a USMCA country the Part 102 marking rules decide.

Second, CBP is watching the shortcut. In a CTPAT alert on illegal transshipping, last updated December 18, 2025, CBP names relabeling Chinese-origin products and false free trade agreement claims "under USMCA or CAFTA-DR" through "fraudulent certificates of origin or minimal processing." A China+1 plan moves the factory, not the label. Our guide to a CBP Form 28 request about origin covers what CBP asks when it doubts one.

The Layers by Origin

The table below comes from CBP's guidance CSMS # 69326983, sent July 23, 2026, checked against Chapter 99 of the Harmonized Tariff Schedule. Every origin also gets the general exemptions in headings 9903.05.85 to 9903.05.92, which cover, among others, Section 232 articles, civil aircraft, pharmaceutical articles and the product lists in the notice's annexes.

The layers add up. U.S. note 52(a) to Chapter 99 says covered products "shall also be subject to the general rates of duty" in Chapters 1 to 97 and to "any additional duty provided for in this subchapter or in subchapter IV of chapter 99." It also says products eligible for special tariff treatment under general note 3(c)(i), the list of preference programs, stay subject to the forced-labor duty "except as otherwise provided in this note." That sentence is why a free trade agreement claim does not switch the layer off unless the note names that agreement.

China carries more than this layer. The 2018 Section 301 actions on technology transfer still apply by HTS code: the schedule lists 25% on headings 9903.88.01 to 9903.88.04, 7.5% on 9903.88.15 and, under headings 9903.91.01 to 9903.91.14, added duties of up to 100% on certain products, the first of them effective September 27, 2024. On October 7, 2026, USTR published a continuation notice saying both 2018 actions "did not terminate" and "will remain in effect, subject to possible further modifications." Not every product is on those lists, and some carry exclusions that end November 9, 2026. For a Chinese SKU on a 2018 list, the comparison is the 2018 layer plus 12.5%, against what the new origin pays.

Some origins sit outside the action. The notice lists 54 economies that failed to impose and enforce a ban and six that failed to enforce the one they have. Panama, Jamaica and Haiti are not on either list, so the forced-labor duty does not apply to their products. That is not duty-free: the general rate and other actions still apply.

Mexico: The USMCA Claim Carries Ten Points

For Mexico, the exemption turns on one condition. U.S. note 52(h) says the duty in heading 9903.05.55 "shall not apply to any products of Mexico entered free of duty under the United States-Mexico-Canada Agreement." A Mexican good entered without USMCA treatment falls back to the 10% heading, unless a general exemption applies. On an entry that qualifies, the claim removes the 10% layer and the general duty on the same line.

The claim is made at entry, and the rules sit in 19 CFR Part 182. Under 19 CFR 182.11, the importer puts "the letters "S" or "S+" as a prefix" to the HTS subheading of each originating good on the entry summary. The claim rests on a certification of origin, and 19 CFR 182.12 sets its terms:

• No prescribed form. It "need not be in a prescribed format," but it must be written or electronic and include the listed data elements. CBP's USMCA page sums them up as nine minimum data elements set out in Annex 5-A of the agreement.
• In hand at the claim. It "must be in the possession of the importer at the time the claim for preferential tariff treatment is made."
• Records. Under 19 CFR 182.15, the importer keeps the records that show the good qualifies "for a minimum of five years from the date of importation."
• Late claims. Under 19 CFR 182.31, a refund claim for an originating good entered without the preference can be filed "within one year after the date of importation." Whether that also recovers the forced-labor layer is for your broker: note 52 says "entered free of duty."

The word that matters is originating. A certification states that the good meets the USMCA rule of origin; it does not make it originate. A Mexican plant assembling Chinese parts may or may not meet the rule for its HTS code, and that answer comes from the bill of materials and your broker.

The agreement itself is under review. A USTR notice of October 5, 2026 (91 FR 63379) says that at the July 1, 2026 joint review "the United States did not agree to extend the Agreement for a new 16-year term," so the parties now meet "to conduct a joint review annually." The current term runs to July 1, 2036. USTR takes written comments and requests to appear until "January 12, 2027, at 11:59 p.m. EST," and the hearing date will be posted on its website.

Central and South America: CAFTA-DR Covers Apparel, and Little Else

CAFTA-DR's carve-out is narrower than many sourcing decks assume. Under note 52(i), heading 9903.05.95 removes the forced-labor duty from "a textile or apparel good as defined in subdivision (d)(v) of general note 29" that is the product of Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras or Nicaragua and is "entered free of duty under" CAFTA-DR. All six partners get it, and it reaches textiles and apparel.

Everything else from the region pays the layer. Goods of El Salvador, Guatemala and Honduras fall under 10% headings, and goods of Costa Rica, the Dominican Republic and Nicaragua under 12.5%. Guatemala and El Salvador also have their own exemption lists, including one for goods "for which entry is claimed under" CAFTA-DR, so a Guatemalan or Salvadoran SKU outside apparel needs its HTS code checked against those lists before the model assumes 10%.

Nicaragua carries a second layer with a date on it. A separate Section 301 action, implemented in 90 FR 60850 under heading 9903.89.01, applies to Nicaraguan goods that do not originate under CAFTA-DR. Its schedule: "0%" for goods entered in 2026, "10%" for goods entered from January 1, 2027, and "15%" from January 1, 2028. The two tests differ. The forced-labor carve-out asks whether a textile or apparel good entered duty-free under CAFTA-DR; the Nicaragua action asks whether any good originates under CAFTA-DR. The 2027 seller calendar carries that date with the rest of the year.

A declared scenario shows why the date matters. Say a brand moves a housewares line to Nicaragua, and the goods do not originate under CAFTA-DR. A container entered on December 30, 2026 carries the 12.5% forced-labor layer and a 0% Nicaragua layer; the same container entered on January 4, 2027 carries the second layer at 10%. The entry date decides, not the sailing date.

The region is also where Miami's port trade sits. In PortMiami's 2025 Latin America and Caribbean statistics, the top import partners by TEUs are the Dominican Republic (40,394), Honduras (29,962), Colombia (29,688) and Guatemala (27,809), and the region accounts for "46.8% of all trade with PortMiami."

South America's free trade agreements get no carve-out. Colombia, Peru and Chile each have one with the United States, and none of them removes the forced-labor layer: their headings, 9903.05.32, 9903.05.63 and 9903.05.30, list only the general exemptions, and all three carry 12.5%. Argentina and Ecuador sit in the 10% group, which the notice ties to each one's commitment in its Agreement on Reciprocal Trade, and each has its own exemption lists by HTS code (9903.06.10 to 9903.06.11 and 9903.06.18 to 9903.06.19).

For a Chinese SKU on a 2018 list, the move to Colombia or Peru drops the 2018 layer and keeps the 12.5%. For a SKU on no 2018 list, the forced-labor layer is 12.5% on both sides, and the duty saving is whatever difference exists in the general rate, which is real for some products and close to nothing for others.

Brazil sits under two Section 301 actions, 12.5% under heading 9903.05.27 and a separate 25% action, which the tariff stack piece covers.

The Route to a US Dock

The rate that applies is set at entry. 19 CFR 141.69 says the rates "shall be the rates in effect at time of entry." For goods moved in bond on an immediate transportation entry from the first U.S. port to another port, the rates are generally those in effect "when the immediate transportation entry was accepted at the port of original importation," with exceptions for quota goods and goods sent to general order; your broker confirms which date applies. When a rate changes, transit time decides which side of the date your goods land on.

Mexico moves mostly by truck, and mostly through Texas. The Bureau of Transportation Statistics publishes CBP's Border Crossing Entry Data, which counts vehicles entering the United States. For 2025 it shows 7,589,315 incoming truck crossings on the U.S.-Mexico border. Of those, 5,419,053 were in Texas, and 2,945,388 were at Laredo alone. These count truck crossings, loaded or empty, not cargo value.

Miami is not the Mexico route. In the same PortMiami report, Mexico ranks ninth among the port's Latin American and Caribbean import partners, with 4,451 TEUs. Mexican freight bound for Amazon usually crosses at the Texas border and moves on by road.

For Central America, the Caribbean and South America, the port is part of the decision. PortMiami describes itself as the "Cargo Gateway of the Americas®," reports "20 Direct Services to the Region" in its 2025 regional statistics, and shows 1,115,058 TEUs for 2025 in the historical snapshot on its cargo page. Transit days by lane come from the carrier's schedule or your forwarder; add the days from port release to the warehouse and from there to Amazon check-in.

I put the trade-off this way in a Forbes panel in January:

"Market fragmentation actually creates opportunity. When regions diverge, costs, talent and competitiveness shift, letting us build more while spending and exposing less. I adapt fast and place each part of the operation where it performs best. Controlled geographic distribution maintains global consistency while using local strengths."

Bernardo Campelo, in a Forbes Business Council expert panel, January 12, 2026

The Amazon side changes too. Amazon's help page Delivering imports to Amazon says Amazon "will not act as an IOR for any shipment of FBA inventory," and that "it's your responsibility to identify and indicate the correct country of origin for each product listing." A SKU that moves from a Chinese factory to a Guatemalan one needs that field updated when the new inventory goes live.

What Moves Next

Several dates fall inside the window when a factory move would land.

Importers have challenged the forced-labor action at the Court of International Trade, in a consolidated case our tariff stack piece follows, and as of October 29, 2026 the court's list of 2026 slip opinions showed no opinion on it. A ruling could change the layer for many origins at once; what it means for past entries is a question for counsel.

The Origin Decision, Step by Step

A China+1 decision for an Amazon catalog runs SKU by SKU, not country by country:

• Price the layers per HTS code. For each SKU, list the general rate, the 2018 China layer if any, and the forced-labor heading for each candidate origin.
• Test the origin rule before the plant. For Mexico, the USMCA rule for the classification; for CAFTA-DR, whether the good is a textile or apparel good under general note 29, or on a Guatemala or El Salvador list. Get the bill of materials into that test.
• Write the claim into the supplier contract. Who issues the certification of origin, who keeps the records for five years, and who answers CBP if it asks.
• Date the first entry. If a rate changes inside your ramp, as Nicaragua's does on January 1, 2027, the entry date decides which rate the first lots carry.
• Update Amazon. Change the country of origin on each listing when the new inventory goes live, and keep the old lots traceable by entry.

This is a framework, not customs or legal advice. Classification, origin and the claim belong to your customs broker, and the contract terms to your counsel.

Where a Prep Center Fits

Nothing a prep center does changes the duty. The rate attaches at entry, and origin is decided at the factory, so receiving, relabeling or splitting cartons after clearance has no effect on it. What a prep center adds sits after the port: it receives the freight that has cleared, checks it against the packing list, preps it to Amazon's requirements and ships it into FBA.

PrepVia receives imported freight at 8507 NW 72nd St, Miami, FL 33166 and routes it into Amazon FBA, with receiving and inspection included. Container unloading is quoted per account; floor-loaded containers by carton count. Discrepancies are reported within 24 hours of arrival, with photos.

From there, the prep window is 24-36 hours, with labeling, kitting and case pack work, and inventory moves to Amazon by small parcel or on Amazon partnered LTL and FTL. The customs side stays with its owners: your broker files the entry and the claim, and your forwarder moves the freight. Our notes on who does what between broker, forwarder and 3PL and on drayage from the Port of Miami cover those handoffs.

Frequently Asked Questions

Does moving production from China to Latin America remove the Section 301 forced-labor duty?

Not by itself. Since July 24, 2026, the layer applies to 60 economies, including Mexico, Colombia, Peru, Chile and all six CAFTA-DR partners, at 10% or 12.5%. The trade agreement carve-outs cover Mexican goods entered free of duty under the USMCA and CAFTA-DR textile and apparel goods entered duty-free under that agreement; Guatemala, El Salvador, Argentina and Ecuador also have product lists of their own.

Is a Mexican product exempt from the 10% forced-labor duty?

Only if it enters free of duty under the USMCA. That normally takes a good that meets the USMCA rule of origin and a claim at entry with "S" or "S+" before the HTS number, backed by a certification of origin the importer holds when the claim is made. Without that treatment, the good falls under the 10% heading unless another exemption applies.

Does CAFTA-DR exempt goods from Central America and the Dominican Republic?

Only textile and apparel goods entered duty-free under CAFTA-DR, and that carve-out covers all six partners. Other goods pay 10% from El Salvador, Guatemala and Honduras, or 12.5% from Costa Rica, the Dominican Republic and Nicaragua, unless a general exemption or, for Guatemala and El Salvador, their own product lists apply.

Do goods from Colombia, Peru or Chile get a free trade agreement exemption?

No. Their headings list only the general exemptions, and all three carry 12.5%. Note 52 keeps goods eligible for preference programs subject to the layer unless the note itself says otherwise.

What changes for Nicaraguan goods on January 1, 2027?

A separate Section 301 action on Nicaragua, heading 9903.89.01, goes from 0% to 10% for goods entered from January 1, 2027 that do not originate under CAFTA-DR, and to 15% from January 1, 2028. It sits alongside the 12.5% forced-labor layer.

Is Miami a good entry point for goods made in Mexico?

Usually not. Most Mexican freight crosses by land, and truck crossings concentrate in Texas: in 2025, 5,419,053 of the 7,589,315 incoming truck crossings on the U.S.-Mexico border were in Texas. In PortMiami's 2025 figures, Mexico ranks ninth among its Latin American and Caribbean import partners. Miami fits goods from Central America, the Caribbean and South America that arrive by container ship.

Final Take

After July 24, 2026, China+1 is a decision about origin rules as much as about factories. Mexico can take the forced-labor layer to zero with a real USMCA claim, CAFTA-DR helps apparel and little else, and Colombia, Peru and Chile pay the same 12.5% as China on that layer. The saving against China is the 2018 lists and the general rate, and it has to be priced SKU by SKU.

Then the route decides the clock. Mexico moves mostly by truck through Texas; Central America, the Caribbean and South America largely arrive by container ship, and that region is close to half of the Port of Miami's trade. Put the entry date, the claim and the route in the same model, and the next notice only changes a row.