US tariffs on Vietnam-made EDC parts in 2026
What a US buyer pays on CNC EDC parts made in Vietnam as of October 2026: the 12.5% Section 301 duty, how it stacks, metals exceptions, origin rules and what is pending.

As of October 2026, most CNC EDC parts of Vietnamese origin entering the United States pay the normal tariff for their HTS line plus an additional 12.5% Section 301 duty, in force since July 24, 2026, unless the part is on an exemption list or is a metals article covered by Section 232 instead. This is a volatile area. The rate, the exceptions and the status of trade talks have each changed within the past year, so treat this page as a dated snapshot and confirm with a customs broker before you price a drop.
What changed, in order
- IEEPA tariffs ended. The Supreme Court ruled 6-3 in February 2026 that the tariffs imposed under the emergency-powers law exceeded the executive’s statutory authority.
- A temporary replacement. The administration used Section 122 of the Trade Act of 1974 for a global surcharge, which by law lasts only 150 days without Congress acting.
- Section 301 forced-labor duties. USTR’s final action in 60 investigations took effect at 12:01 a.m. Eastern on July 24, 2026, with additional duties of 10% or 12.5% on products of the investigated economies, subject to exemptions in annexes.
USTR puts a group of economies that have, or have committed to, a forced-labor import ban at 10%, and sets 12.5% for “all other” investigated economies. Vietnam is not named in the 10% list. CBP’s guidance gives each economy its own heading and lists Vietnam under 9903.05.84 at 12.5%. Some third-party trackers still show Vietnam at 10%, so use the CBP guidance and your broker, not a summary table.
How the 12.5% sits on the normal duty
CBP’s filing guidance reports the Section 301 line first, then Sections 122, 232 and 201 lines where they apply, then the normal commodity classification. For Vietnam the 12.5% is an additional rate, charged on top of the general rate for the HTS line. A ten-thousand-dollar customs value on three plausible EDC lines looks like this, using the general rates in the USITC HTS database (October 2026) and ignoring the cents-per-piece element:
| Product | HTS line | General rate | Additional | Duty on $10,000 |
|---|---|---|---|---|
| Folding knife parts | 8211.93.00 | 5.4% + 3 cents each | 12.5% | about $1,790 + cents |
| Pen parts (not balls) | 9608.99.40 | Free | 12.5% | $1,250 |
| Flashlight parts | 8513.90.20 | 12.5% | 12.5% | $2,500 |
Add the customs fees and freight shown in landed cost of CNC EDC parts. Your broker decides the HTS line for your actual part, and a titanium scale, a pen barrel and a flashlight head each land in a different place on this table.
Metals: Section 232 can replace the Section 301 line
CBP’s guidance excludes certain articles from the Section 301 heading, including articles of aluminum, steel or copper and their derivatives. Those goods are covered by Section 232 instead. A 2026 restructuring of the Section 232 metals duties applies them to the full customs value of covered goods for entries on or after April 6, 2026, with a 50% rate for goods in one annex, 25% in another and a reduced top-up regime for certain derivatives. For some products outside the metal chapters, the duty applies only if the applicable metal is at least 15% of the article’s weight. Which annex a given HTS line sits in cannot be read off a summary, so ask the broker.
What this means for EDC parts:
- Titanium and zirconium parts contain none of the three listed metals, so the Section 232 metals regime is unlikely to apply and the Section 301 line is the one to plan for.
- Aluminium, steel and brass or copper parts (6061 and 7075 scales, 17-4 clips, 440C hardware, brass pivots) may fall under Section 232 rather than Section 301, with a different rate. Do not assume either way.
- Mixed assemblies, such as a knife with a steel blade and titanium scales, need a classification decision for the whole article.
Origin is not the shop’s address
Tariffs follow the country of origin, which US rules decide by substantial transformation: a new article with a different name, character and use has to be created. CBP states that this is decided case by case and that an importer may request a binding ruling. For machined parts the usual question is whether the metal came into the country as bar or plate and left as a finished part. That generally changes name, character and use, but confirm it for your product, and keep the mill certificates showing where the metal was made.
Ask each shop for the origin of the material and for the country of origin to be stated on the commercial invoice. Sourcing EDC parts from Vietnam vs China covers the other differences between the two routes. Note that the new forced-labor duty applies to China as well, in addition to the Section 301 duties China already carries, so the gap between the two countries depends on the HTS line and should be calculated, not assumed.
What is still pending
- A separate Section 301 investigation of Vietnam’s intellectual property practices. USTR initiated it on May 29, 2026, after naming Vietnam a Priority Foreign Country in its April 30, 2026 Special 301 report. A determination is due by November 29, 2026, after which USTR may recommend tariffs or other measures.
- Trade talks. Whether a reciprocal trade agreement is reached, and what it would do to the rate, is not known. This article does not assume one.
- Further changes. Rates, annexes and exemptions have been revised more than once in the past year, so expect more.
What to do before you price a launch
- Put the HTS line, the additional duty line and the fees in a landed-cost sheet, and refresh it before each purchase order.
- Have the broker confirm the HTS line, whether Section 301 or Section 232 applies, and the country of origin.
- Quote retail prices with room for a duty change between order and entry, or state that the price is subject to import duty.
- Ask shops for itemised pricing on FCA terms, so duty uncertainty stays with the importer who controls it. See the delivery-term table in the landed-cost guide.
- For a crowdfunding drop, put the duty assumption in the budget; Kickstarter’s guidance names import duties and VAT as a cost to research (see EDC Kickstarter manufacturing: prototype to shipped batch).
For markets outside the US and for the rest of the route to your dock, see our guide to importing EDC parts from Vietnam.
We are a sourcing desk, not a factory. We match your drawing to shops in the network that run small EDC batches and return itemised quotes with the delivery term stated; the duty is for your broker to confirm. Send the drawing and we reply within 24 business hours. For cost structure see what buyers compare in an EDC quote.
FAQ
What is the US tariff on Vietnam-made CNC parts in October 2026? Most goods of Vietnamese origin pay the normal rate for their HTS line plus an additional 12.5% Section 301 duty in force since July 24, 2026, with exemption lists and metals carve-outs. Confirm the rate for your HTS line with a customs broker, because it has changed several times this year.
Is the 12.5% charged on top of the normal duty? CBP’s guidance lists the Section 301 heading as an additional duty reported alongside the commodity classification, so it is charged on top of the general rate. Only for the EU, Taiwan, Japan, Korea and Switzerland does the action net against the normal rate.
Do titanium parts pay Section 232 metals tariffs? Section 232 covers steel, aluminium and copper articles and derivatives. A titanium part contains none of those metals, so the Section 301 duty is the one to plan for unless an exemption applies. Aluminium, steel and brass parts may fall under Section 232 instead.
Does the shop’s location decide the origin? No. Origin is decided by where the article was made or substantially transformed, case by case. A binding ruling from CBP settles it for a specific product. Keep material certificates and ask the shop to state origin on the invoice.
Will a trade deal lower the rate? No one can say yet, and nothing here assumes it. A separate Section 301 investigation of Vietnam’s IP practices has a determination due by November 29, 2026 and could add measures. Price with the rate in force today and review before each order.
Sources
- U.S. CBP CSMS 69326983: Guidance, Section 301 forced labor import duties
- USTR: Takes action in forced labor Section 301 investigations (July 2026)
- U.S. International Trade Commission: Harmonized Tariff Schedule
- U.S. CBP: Marking of country of origin on U.S. imports (substantial transformation)
- Global Trade Alert: Forced-labour Section 301 tariffs take effect, overview
- BDO: Section 232 metals tariffs expanded and recalibrated
- BDO: Section 301 developments involving Vietnam
- Clyde & Co: Supreme Court invalidates IEEPA tariffs (February 2026)