A 2,500 kVA pad-mount transformer entered at Long Beach on September 9, 2026 pays 25% duty whether it was built in Monterrey, Osaka or Mumbai, and 50% if it was built in Jiangsu. A low-voltage panel with the PLC already in it pays 0% from Mexico, 10% from Germany, 12.5% from Japan and 40.2% from China. Those two numbers are the whole story of the 2026 tariff schedule: the metal tariff no longer cares where the box came from, and the country tariff no longer touches the metal. Five legal authorities have carried US tariffs since February 2025 and two of them are dead, so every rate below carries its instrument, its Federal Register or CBP citation, and the HTS revision it was read from (HTS 2026 Revision 18). The Open Factory Tariff Exposure Calculator holds the same 198 HTS-by-origin cells with the citation on every one.
Source: Open Factory Tariff Exposure Calculator (compiled from HTS 2026 Rev. 18, Proclamations 11021 and 11032, CBP CSMS 68855869, 91 FR 47318; as of September 2026)
Nine origins, one 25% bar each, and a 50% bar for China: HTS 8504.22.00 sits in Annex I-B of the April metals proclamation, which puts 25% on the full customs value regardless of who made it, and China adds the 25% List 1 rate it has carried since 2018. This piece covers what died and what replaced it, the Section 232 tiers line by line, the two Section 301 actions and how they stack on China, the HTS-by-origin table with the CSV, the $80 billion of 2025 imports now under this schedule, a $306k machine landed from five countries, and, behind the wall, the January 1, 2028 cliff and the three purchase-order clauses that handle it.
What Died and What Replaced It
Since February 2025 a US equipment buyer has paid under five statutes, and the two that carried the headline rates are gone. The Supreme Court held 6 to 3 on February 20, 2026 in Learning Resources v. Trump that IEEPA does not authorize tariffs, which ended the fentanyl tariffs on Canada, Mexico and China (EOs 14193 to 14195, 90 FR 9113 to 9121) and the reciprocal tariffs of EO 14257 (90 FR 15041). The same day the President signed Proclamation 11012 (91 FR 9339), a Section 122 balance-of-payments surcharge of 10% for the statutory maximum of 150 days, effective February 24, with goods already under Section 232 and USMCA-qualifying goods exempt. It expired at 12:01 a.m. on July 24, 2026.
The Court of International Trade struck the Section 122 surcharge too, on May 7, 2026, in Oregon v. United States, but limited relief to the three plaintiffs and the government appealed the next day, so the other 330,000 importers kept paying until it lapsed (Skadden, May 2026). The replacement was ready to the hour. USTR opened 60 Section 301 investigations on March 12, 2026 into economies that do not enforce a forced-labor import ban (91 FR 12884), found all 60 actionable on June 2, took 1,600 comments and three days of hearings, and imposed tariffs of 10% or 12.5% effective 12:01 a.m. July 24, 2026 (91 FR 47318), the minute Section 122 died.
Source: Federal Register (91 FR 9339, 18201, 34085, 47318), Supreme Court No. 24-1287, CBP CSMS 68253075 and 68855869; Open Factory compilation, September 2026
Fifteen dated instruments, seven of them in 2026 alone, and the three shaded rows that still bill you are Proclamation 11021 (April 6), the Section 301 forced-labor action (July 24) and the sunset already written into the first for January 1, 2028. Meanwhile the refunds for the dead authority are real money: CBP told the Federal Register that IEEPA duties collected from February 3, 2025 to February 24, 2026 total an estimated $166 billion across 53 million entry summaries, all of which the CIT ordered refunded with interest on March 4, 2026 in Atmus Filtration v. United States. Who receives that money, the importer of record or the buyer who paid the surcharge line on the invoice, is the subject of Who Gets the IEEPA Refund; the schedule below is about what you pay from here.
Section 122 is the second refund fight, and a smaller one: 10% for 150 days on non-232, non-USMCA goods, so a Japanese CNC lathe entered in April 2026 paid 10% plus the 4.4% column 1 rate and nothing else. If the Federal Circuit affirms Oregon v. United States for everyone rather than for three plaintiffs, that 10% comes back only to importers who preserved the claim, which for entries liquidating this autumn means a protest under 19 U.S.C. 1514 within 180 days of liquidation (Skadden, May 2026). Nothing on this schedule moves for a buyer who paid a supplier’s DDP price, unless the PO says the refund is theirs.
Section 232 Metals: One Rate for Everyone
Proclamation 11021 of April 2, 2026 rebuilt the metals tariff into four tiers on the full customs value of the product, and it is the only instrument on this schedule that charges Osaka and Jiangsu the same. The tiers, from 91 FR 18201 and CBP CSMS 68253075: 50% for articles of steel, aluminum and copper and the derivatives in Annex I-A (heading 9903.82.02); 25% for the derivatives in Annex I-B (9903.82.09); a transitional tier for Annex III “fixed industrial machinery and power equipment” under which column 1 duty plus Section 232 sums to 15% through December 31, 2027 (9903.82.10); and 10% for any derivative whose metal was melted and poured in the United States (9903.82.06), a threshold Proclamation 11032 cut from 95% to 85% of metal weight on June 8 (91 FR 34085). Articles outside chapters 72 to 76 with less than 15% metal by weight pay nothing under 9903.82.03, but the importer reports the metal weight in kilograms on the entry line.
The surprise for an electrical buyer is which annex each transformer landed in. The CBP Metals HTS List that implements the annexes puts liquid-filled units up to 10,000 kVA (8504.21.00 and 8504.22.00) and dry-type units from 16 to 500 kVA (8504.33.00) in Annex I-B at a flat 25%, while liquid-filled units over 10,000 kVA (8504.23.00) and dry-type units over 500 kVA (8504.34.00) sit in Annex III at the 15% cap. A 2,500 kVA pad-mount for a plant pays 25%; a 50 MVA GSU for a datacenter pays 15% all-in, or 13.4% on top of nothing if it enters under KORUS from Hyundai’s Ulsan works. The Open Factory Lead-Time Monitor shows the 50 MVA unit at 128 to 160 weeks and the pad-mount at 40 to 65 weeks, so the cheaper tariff attaches to the unit you cannot get.
Switchgear is not on the list at all. Neither 8535 nor 8536 nor 8537 appears in any annex; only 8538.10.00 (empty boards and cabinets) and one 8536.90 parts line carry the 25%. MV switchgear assemblies (8537.20.00), motor control centers (8537.10.60) and LV panels and PLC cabinets (8537.10.91) pay no Section 232 at any origin. Gas turbines split at 5 MW: 8411.81.80 is an Annex I-B steel derivative at 25%, 8411.82.80 above 5 MW is uncovered. Diesel gensets (8502.11 to 8502.13) are uncovered; spark-ignition gensets (8502.20.00) pay 25%. Chillers (8418.69.01) are uncovered; household refrigeration is not. Of the machine-tool headings 8456 to 8466 only machining centers (8457.10.00) appear, in Annex III, and of the robot lines only 8428.70.00 lifting-and-handling robots, also Annex III; industrial robots under 8479.50.00 pay nothing under 232. Cable is the messiest: LV cable with connectors (8544.42.90, 8544.42.10, 8544.42.20) and 8544.49.10 are copper articles at 25% and now need country of smelt and cast reported (CSMS 68855869), the aluminum lines 8544.49.20, 8544.49.90, 8544.60.20 and 8544.60.60 are Annex I-B at 25%, and MV copper cable over 1 kV (8544.60.40) is on no list. The copper side of that is in Copper at $6.77 and priced weekly in the Copper and Wire Price Sheet.
Two clauses matter for anyone signing a PO this quarter. Clause 6 of Proclamation 11021 lets Commerce and USTR revoke the Annex III 15% tier for any single trading partner whose shipments “increased in a manner that undermines the objectives” of the action, by Federal Register notice, effective on the day of the finding. And clause 7 ends the tier for everyone at 11:59 p.m. on December 31, 2027, after which Annex III articles pay the Annex I-B 25%. Proclamation 11032 added a parallel Annex I-C for mobile industrial equipment (forklifts, dozers, mobile cranes) at 25%, or 15% for products of Japan, Korea, Taiwan, the UK, Switzerland and the EU, or 25% on non-US content with a 15% floor for USMCA goods from Mexico and Canada, with the same December 31, 2027 end date. The 232 cost of a full lineup, transformer plus switchgear plus UPS plus genset, is built SKU by SKU in Tariff Bill of Materials.
The paperwork is now part of the price. Every entry under 9903.82.03, the under-15%-metal exemption, reports the aggregate metal weight in kilograms as a second quantity on the line, which means the importer needs the bill of materials and a weight calculation on file before the container lands (CSMS 68253075). Steel derivatives still report country of melt and pour and aluminum derivatives country of smelt and cast, and CBP switched on copper smelt-and-cast reporting for the four 8544.42 and 8544.49 cable lines on July 30, 2026 (CSMS 69252300). The 10% US-melted tier needs a mill certificate showing 85% of the metal by weight was melted and poured in the United States, and Proclamation 11032 tells CBP to impose penalties “to the extent permitted by law” where an importer misstates US content. Goods under the metals proclamation entering a foreign trade zone must take privileged foreign status, so the zone freezes the classification but not the rate that applies on the withdrawal date, and manufacturing drawback under 19 U.S.C. 1313(a) and (b) remains available for 232 duties on goods that are re-exported after processing. A vendor quoting DDP has to carry all of this; a vendor quoting DAP hands it to your broker, and the OEM Disclosure Scorecard now records which OEMs publish the HTS line and metal content on their submittals.
Section 301, Twice: The China Stack and the July Tier
The July 24 action has four rate treatments, and the one that matters most for machinery buyers is an exemption: any article already subject to Section 232 pays none of it. From 91 FR 47318 and the presidential memorandum at 91 FR 47717: a flat 10% additive on goods of Canada, Mexico, India, the UK and 13 others that have or have promised a forced-labor import ban; a cap for the EU and Taiwan under which column 1 plus Section 301 equals 10%, with zero added where the MFN rate is already 10% or more; the same cap at 12.5% for Japan, Korea and Switzerland; and a flat 12.5% additive on the other 38 economies including China and Vietnam. Goods that enter free under USMCA are exempt, as are the Annex I product exemptions and, in the notice’s own words carried from the June proposal, “all articles and parts of articles subject to tariffs under Section 232” (Brownstein, July 2026 and Honigman, July 24, 2026 both read the final Annex I the same way).
That exemption inverts the schedule. A Japanese machining center (Annex III) pays 15% all-in and nothing under the new action; a Japanese CNC lathe (8458.11.00, no 232) pays MFN 4.4% plus 8.1% to reach the 12.5% cap. A German MV lineup pays 10% total; a German 2,500 kVA transformer pays 25% and is untouched by the 301 tier. Japan’s 15% all-in deal of September 2025 (EO 14345, 90 FR 43535) was an IEEPA instrument and died with it; the 15% number survives only inside Section 232 Annex I-C for mobile equipment. The “Taiwan 32%” that machine-tool buyers were quoted in spring 2025 was the April 2025 reciprocal rate and is gone; Taiwan now pays the EU treatment, 10% all-in, and the Taiwan trade and security agreement of May 28, 2026 caps Taiwan’s 232 exposure on auto parts and lumber at 15%. What that does to a Taiwanese 5-axis landed in Ohio is in Japan Is Eating the US Capex Boom.
China is the line where the secondary sources appeared to disagree, so we went back to the instruments. Honigman reads the new 12.5% as stacking on the existing 25% List 1 to 3 rates for an aggregate Section 301 of 37.5%. Holland & Knight’s country table shows China at “13%” (H&K, July 30, 2026). The table rounds every 12.5% economy to 13%, Vietnam and Algeria included, so the 13% is the new action alone, not a claim that the 2018 lists were lifted. The primary record: 91 FR 47318 imposes 12.5% on products of China “except as provided in Annex I and Annex II, Part A,” and contains no offset against the 2018 action; the 2018 action is still in the HTS at headings 9903.88.01 to 9903.88.04, “the duty provided in the applicable subheading plus 25%” (HTS 2026 Rev. 18, chapter 99), and every one of our 22 HTS lines sits on List 1 or List 3 per U.S. note 20 (Lists 1 and 3 at 83 FR 28710 and 83 FR 47974). Two instruments, neither cancelling the other, is a stack. We print China’s non-232 lines at MFN plus 25% plus 12.5%, and we flag one gap per rule 48: we could not locate a CBP CSMS message confirming the combined 37.5% collection by September 9, 2026, so the calculator carries the stack as the default reading of the notice with that caveat on the cell.
Source: Open Factory Tariff Exposure Calculator
Nine origins for HTS 8537.10.91 and nine different bills: 0% for USMCA-qualifying Mexico and Canada, 9.8% for Korea (the 12.5% cap less the 2.7% column 1 rate KORUS already waives), 10% for the EU and Taiwan, 12.5% for Japan, 12.7% for India, 15.2% for Vietnam and 40.2% for China. Rockwell told analysts on August 4, 2026 that 100 basis points of its 250 basis point price target is tariff pass-through (Q3 FY2026 call); on a panel built in Monterrey that pass-through is recovering a duty that does not exist, which is the argument of Rockwell’s 250 Basis Points and the reason Quote Check asks for country of origin before it asks for price.
The Schedule, HTS by HTS
Twenty-two HTS lines by nine origins gives 198 cells, and 108 of them are either 25% or 15% because the metal tariff does not read the country-of-origin field. The table below is the condensed view; data/tariff-schedule.csv carries every cell with the column 1 rate, the 232 tier and chapter 99 heading, the 2018 list, the July 2026 tier, the total, the caveat and the source string. Mexico, Canada and Korea are shown as FTA-qualifying, which removes the column 1 duty and, for USMCA, the July 2026 tier; a non-qualifying Mexican panel pays 12.7%, not 0%.
Source: Open Factory Tariff Exposure Calculator (HTS 2026 Rev. 18; 91 FR 18201; 91 FR 34085; 91 FR 47318; 83 FR 28710; 83 FR 47974; CSMS 68855869)
CSV: data/tariff-schedule-condensed.csv
Read down the China column and the range is 37.5% (chillers, MFN free, no 232) to 52.6% (LV cable with connectors, 2.6% plus 25% plus 25%); read down Mexico and it is 0% on everything without metal and 25% on everything with it. Three rows carry a KORUS footnote: for Annex III articles the 232 add-on is 15% minus the column 1 rate, so a Korean machining center that enters free under KORUS pays 10.8%, not 15%, and the same arithmetic gives 13.4% on a Korean or Mexican LPT. The notice does not say how CBP nets the 12.5% cap against a preferential entry, so the Korea column is the one place the calculator asks you to confirm with your broker. Two things are deliberately not in the table: antidumping and countervailing duties (Korean large power transformers have carried an AD order since 2012 and it stacks on all of this), and Section 338, whose 50% Canadian tariffs of August 19, 2026 cover dairy, alcohol and motor vehicles only (91 FR 46663), with the alcohol tranche suspended on August 18 (91 FR 54789).
The robotics and industrial machinery investigation is the open item. Commerce opened it on September 2, 2025 with a scope that names CNC machining centers, turning and grinding machines, presses, tool changers, EDM and laser cutters (90 FR 46382); comments closed October 17, 2025; the 270-day statutory clock ran out around May 30, 2026. A Federal Register search on September 9, 2026 returns no proclamation, and Business Sweden’s August 20 tracker still lists it as pending (Business Sweden). Until it lands, a lathe, a press brake and a six-axis robot pay the July 2026 country tier and nothing else; the Factory Automation Roadmap tracks the docket.
What $80 Billion of Imports Now Pays
The nine HTS groups on this schedule covered $80.2 billion of US imports in 2025, and Mexico shipped $31.7 billion of it against China’s $6.4 billion. The figures are US-reported imports at customs value from UN Comtrade, calendar 2025, cut at HS6 where the line allows us to drop power supplies and household refrigerators; the CSV is data/import-value-2025.csv.
Source: UN Comtrade (US-reported imports, 2025) via Open Factory Tariff Exposure Calculator
Cable is $36.9 billion with $17.9 billion from Mexico; LV panels and PLCs are $20.2 billion with $8.6 billion from Mexico and $1.2 billion from China; liquid transformers are $7.7 billion, of which Mexico $2.2 billion, Korea $1.7 billion, the EU $1.3 billion and China $277 million. The line that pays the most is not the one with the highest rate: the 25% metal tier on $7.7 billion of liquid transformers and roughly the copper and aluminum share of $36.9 billion of cable dwarfs the 40.2% on $1.2 billion of Chinese panels. Machine tools are the mirror image, $5.1 billion with $2.1 billion from the EU and $1.2 billion from Japan, almost all of it outside 232 and inside the 10% and 12.5% caps. The transaction prices behind these customs values, by kVA and by section, are the job of the Public Bid-Tab Price Book, and the Equipment Price Benchmark is collecting the machine-tool quotes.
A $306k Machine From Five Countries
AMT’s USMTO series put the average US machine-tool order at about $306,000 in the first half of 2026 ($3.44 billion over 11,243 units), so that is the invoice we landed. Two machines, same price, two HTS lines: a machining center (8457.10.00, Annex III) and a horizontal CNC lathe (8458.11.00, no 232). The order data is from American Machinist’s June 2026 USMTO report; the record half-year with fewer units is The $306k Machine.
Source: Open Factory Tariff Exposure Calculator; invoice from AMT USMTO via American Machinist (July 2026)
The machining center owes $45,900 from Japan, Germany or Taiwan, $33,000 from Korea under KORUS and $122,400 from China; the lathe owes $38,200 from Japan, $30,600 from Germany or Taiwan, $24,800 from Korea and $128,200 from China. Against a Haas VF-2 built in Oxnard that owes nothing, the Japanese machining center’s duty is about 15% of the gap the buyer is weighing, which is the arithmetic in What a Haas VF-2 Really Costs. Duty is assessed on the customs value at entry, not the quote, so the freight, rigging and installation lines that Tariff Bill of Materials adds on top are outside the percentage; the calculator takes the invoice and the Incoterm and returns the entered value.
What to Do Monday
Ask for the HTS line and the country of origin on every quote, because the schedule no longer maps to the brand’s headquarters. A Siemens transformer from Guanajuato pays the same 25% as one from Nuremberg; a Fanuc robot from Oshino pays 12.5% and a Fanuc robot from the Rochester Hills integrator pays nothing; a Mazak from Florence, Kentucky pays nothing and a Mazak from Inabe pays 15% now and 29.2% in 2028. Write the HTS number, the origin and the rate you were quoted against into the PO the way How to Write an RFQ for Capital Equipment lays out, and run the line through the Tariff Exposure Calculator before you sign, not after the broker’s bill arrives.
Second, split the metal from the box. A prefabricated e-house with the transformer inside is one entry line at the classification of the whole; the transformer alone is 8504.22.00 at 25% and the switchgear alone is 8537.20.00 at 0% from Mexico. Whether the skid saves money after the tariff is the subject of Modular Is Not Cheaper, and the answer moved in April. Third, if you paid an IEEPA surcharge on a 2025 delivery, confirm today that your supplier has registered for ACH refunds with CBP: as of May 11, 2026, 1,880 approved consolidated refunds were sitting untransmitted because the importer of record had not supplied bank details, and CBP will not reissue a failed transmission or pay interest on the delay (Western Overseas CAPE FAQ, May 28, 2026).
Fourth, price the schedule into the lead time. A 2,500 kVA pad-mount ordered this month at the Monitor’s 40 to 65 weeks lands in 2027 under the 25% tier; a 50 MVA unit at 128 to 160 weeks lands in 2028 or 2029, after the Annex III tier is gone, at 25% plus MFN instead of 15%. The Lead-Time-Adjusted Schedule now carries the entry-date tariff on every PO line for exactly that reason, and the slot deposits buyers are paying to hold 2027 delivery positions are, among other things, a bet on which side of December 31, 2027 the truck arrives. Behind the paywall: the eight article classes whose duty rises 10 to 14.2 points on January 1, 2028, the mechanism that lets Commerce pull the 15% tier from one country early, and the three clauses, tariff adjustment, refund allocation and entry timing, that we would not sign a capital-equipment PO without, with the language mapped to the Tariff Exposure Calculator’s citation fields.