The short version
Sourcing packaging from Thailand instead of China is still a legitimate way to reduce your U.S. duty exposure. What changed in 2026 is that Thailand is no longer a zero-tariff answer.
On July 24, 2026, a new U.S. Section 301 action took effect covering 60 trading partners, including Thailand. Most non-exempt goods now carry an additional duty of 10% or 12.5%. Thailand falls in the 12.5% tier.
So the honest comparison is no longer “25% versus 0%”. It is two different duty stacks, and the right choice depends on your product’s tariff classification, not on the country name alone.
This guide lays out how each stack is built, how to compare them on a landed-cost basis, and what to verify before you commit to a supplier.
What actually changed on July 24, 2026
The U.S. Trade Representative concluded 60 investigations under Section 301 of the Trade Act of 1974 concerning whether each economy prohibits imports made with forced labor. The final action imposed tariffs on all products of the investigated economies, subject to exemptions:
| Group | Additional duty | Examples named by USTR |
|---|---|---|
| Economies treated as having qualifying or partially qualifying controls | 10% | Canada, Ecuador, EU, Indonesia, Mexico, Pakistan; plus Cambodia, Guatemala, Honduras, India, Sri Lanka, Trinidad and Tobago, Jordan |
| All other investigated economies | 12.5% | Thailand and the remaining economies |
| Five economies under “top-up” treatment | Tops up to the 10% / 12.5% threshold | EU, Taiwan, Japan, South Korea, Switzerland |
Thailand is not on the 10% list. That is the key fact for anyone currently sourcing from Thailand, or planning to.
Two mechanics matter as much as the rate:
The entry date controls, not the order date. The duty applies to goods entered for consumption at or after 12:01 a.m. Eastern on July 24, 2026. Your purchase order date, invoice date, production date and ship date do not determine liability. A narrow transit rule covered goods already loaded and in transit by that time, entered before July 28, 2026.
Product-level exemptions exist — and there is no way to request one. USTR exempted a substantial list of products, including 471 added in the final notice, aimed at goods with inadequate domestic or alternative supply. But USTR declined to create an exclusion-request process. If your product is not on the published list, you cannot petition to add it.
The 12.5% is flat — it is not reduced by your existing duty rate. A separate “net of MFN” treatment was reserved for a short list of economies: the EU and Taiwan (capped at 10% total) and Japan, Korea and Switzerland (capped at 12.5% total). For those economies only, the Section 301 rate equals the cap minus the Column 1 rate, and is zero where Column 1 already meets the cap. Thailand is not in that group. The 12.5% is added on top of your normal Column 1 rate and any AD/CVD already owed.
Thailand receives no economy-specific relief. USTR granted additional country-specific product exemptions to a limited set of economies — Argentina, Bangladesh, Cambodia, Ecuador, El Salvador, the EU, Guatemala, Indonesia, Jordan, Malaysia, Switzerland, Taiwan and the United Kingdom — reflecting forced-labor commitments. Thailand is not among them. For Thai-origin goods, only the general product exemptions in Annexes I and II can apply.
There is narrow in-transit relief, and it is vessel-only. Goods loaded onto and in transit on the final vessel before 12:01 a.m. ET on July 24, 2026, and entered for consumption before 12:01 a.m. ET on July 28, 2026, are excluded. Air, rail and truck shipments do not qualify.
Why “China versus Thailand” is the wrong question
Buyers often frame the decision as a single number. The reality is that a shipment’s duty is built from several layers, and moving origin changes only some of them:
- Column 1 (MFN) duty — the ordinary U.S. tariff for the product’s HTSUS classification. Applies regardless of origin (absent a trade preference).
- Section 301 duty — varies by origin and by HTSUS subheading. Chinese-origin goods have been subject to Section 301 duties since 2018 across multiple lists at rates that depend on the specific subheading; the applicable rate must be confirmed for your code, not assumed from the headline number.
- The new country-based Section 301 duty — the July 2026 action described above. Thailand sits at 12.5%, subject to exemptions.
- Antidumping and countervailing duties (AD/CVD) — product- and country-specific, and entirely separate from Section 301. Thailand-origin goods are not automatically free of AD/CVD.
- Section 232 duties — where they apply to a listed article, USTR excluded that merchandise from the new country-based Section 301 duty.
The practical consequence: origin changes items 2 and 3, and possibly 4. It does not make duty disappear. Some origin markets carry their own trade-remedy exposure, and Thailand is not exempt from that risk by virtue of being Thailand.
How to compare origin options properly
Compare to a unit landed cost at the same specification — not to a duty rate in isolation. The calculation is mechanical:
“`
Landed cost per unit =
(FOB unit price
- freight + insurance per unit
- duty: (Column 1 + Section 301 + new country 301 + AD/CVD) × customs value
- customs fees and brokerage
- handling)
× (1 + defect / breakage rate)
“`
Three points where buyers get this wrong:
Duty applies to customs value, not to your FOB price. Freight and insurance are generally included in the customs value of imported goods, so the duty base is larger than most buyers assume.
A lower FOB price can still lose. If one origin carries a 25% Section 301 exposure and another carries 12.5% plus higher freight, the gap narrows far more than a rate comparison suggests.
Compliance cost is real and belongs in the model. If a sourcing claim cannot be documented at entry, the cost of fixing it later is not a rounding error.
Illustrative example — assumptions, not a quotation.
Take a shipment with a $10,000 customs value and a Column 1 rate of 6.5%.
Origin A: full 25% Section 301 duty → combined rate 31.5%.
Origin B: the new country-based duty 12.5% → combined rate 19%.
Difference: $1,250 on that shipment.
The rates here are stand-ins to show the method. Your actual rate depends on your HTSUS classification, exemption status, and any AD/CVD order. Confirm all three before using this arithmetic on a real order.
What Thailand still offers
The duty picture is one variable. The rest of the comparison has not changed:
Manufacturing depth. Thailand has an established paper and molded-fiber packaging ecosystem with export experience into North America, which shortens the path from sample to repeat order.
Trade-remedy position. Thailand-origin goods sit outside the scope of trade actions aimed specifically at Chinese-origin paper products — the subject of the current anti-dumping activity. That is a supply-continuity argument, not a zero-duty argument.
Supply-chain stability. Diversifying out of a single origin market reduces concentration risk, which matters more than a two-point duty difference for buyers placing repeat programs.
The right framing is: Thailand reduces specific risks and changes your duty stack — it does not eliminate duty.
The questions to ask any supplier before you commit
- What is the HTSUS classification you ship under? Get the 10-digit code, not a general category.
- Is that code on the July 2026 exemption list? Ask for the specific provision relied on.
- What is the applicable Column 1 rate for that code?
- Is there any AD/CVD order covering this product from this origin?
- Who files the entry, and who carries duty liability under your Incoterms? DDP and DAP shift very different risk.
- What documentation proves origin, and will it survive a CBP query?
- How has the landed cost changed since July 2026 — ask for a before/after calculation, not an assurance.
A supplier who can answer all seven is a supplier you can model against. A supplier who answers “no duty, don’t worry” is telling you they have not checked.
Where Max Green Pack fits
We manufacture in Thailand and ship to North America, so the July 2026 change affects us as directly as it affects you. We would rather give you the arithmetic than a slogan.
Our documentation and test reports are available for your review before you commit. Tell us your product, destination and volume, and we will work through a landed-cost comparison with your actual classification — including the questions above.
Request a landed-cost comparison →
Related pages
- About Max Green Pack — 泰国生产基地与产能
- Certifications — 可提供的资质文件
