US Tariffs on Cambodian Coffee 2026: Section 301 Exemption Explained
As of 30 September 2026, Cambodian-origin goods face a 10% Section 301 tariff in the US, but coffee is named as an example of a generally exempt product type. What importers should verify before pricing a Fine...
Quick answer: As of 30 September 2026, most Cambodian-origin goods entering the United States pay their normal duty plus a 10% Section 301 tariff that took effect on 24 July 2026. However, the US Trade Representative's determination names coffee as an example of a product type that is exempt from these tariffs, because it cannot be grown or produced in sufficient quantity in the United States. The general duty rate for both green and roasted coffee lines in the US tariff schedule is also listed as Free. Importers should still confirm the exact HTS line, the entry date and the current exemption annexes with a licensed customs broker before fixing a landed price.
Why US importers are asking about Cambodian coffee tariffs
Cambodian specialty coffee is a small-volume origin, and most US roasters meet it first through samples and a first pallet rather than a full container. That makes tariff surprises expensive: a duty that looks minor on paper can change the economics of a small lot. US trade rules affecting Southeast Asian goods have also changed several times in twelve months, so information that was correct in early 2026 may no longer apply.
This article summarises what changed, what applies today, and what a buyer of Cambodian Fine Robusta should verify. It is a research summary, not customs or legal advice.
Timeline: how the rules changed
| Date | Development |
|---|---|
| 7 August 2025 | Cambodia's IEEPA reciprocal tariff rate was set at 19%. |
| 26 October 2025 | The US and Cambodia signed an Agreement on Reciprocal Trade. Cambodia eliminated tariffs on US goods, and the US committed to keep the 19% rate with a zero rate for products identified in an annex. |
| 14 November 2025 | Coffee, tea, tropical fruit and other agricultural products (237 tariff classifications) were exempted from the reciprocal tariffs. |
| 20 February 2026 | The Supreme Court held in Learning Resources v. Trump that IEEPA does not authorize tariffs. |
| 24 February 2026 | CBP stopped collecting IEEPA duties. A temporary 10% Section 122 surcharge began the same day. |
| 24 July 2026 | The Section 122 surcharge expired. Section 301 'forced-labor enforcement' tariffs of 10% to 12.5% took effect on 60 economies, with Cambodia in the 10% tier. |
What applies now
Under the July 2026 Section 301 action, Cambodia sits in the lower 10% tier. The tariff is additive: it is paid on top of the normal duty for the product's HTS line, and it can stack with antidumping and countervailing duties. USTR gave the lower tier to economies that impose a forced-labor import prohibition, have committed to one in a trade agreement, or run a partial regime. According to Airlift USA's summary of the USTR notice, Cambodia committed to a prohibition in its agreement and adopted one after USTR's June 2026 proposal.
The action also contains exemptions. Some apply to any of the 60 economies, including products that cannot be grown or produced in sufficient quantities or at reasonable prices in the United States or obtained from other sources. The Honigman law-firm alert uses coffee as its example of that category. Separate Cambodia-only exemptions exist as well, but Airlift's summary describes them as covering mostly live animals, cut flowers and plants, certain wood lines, rattan and bamboo basketwork, raw silk and silk fabrics, pearls and precious stones, and a few botanicals, not coffee.
On the base duty, the US tariff schedule lists a general rate of Free for green, not-decaffeinated coffee (HTS 0901.11.00) and for roasted, not-decaffeinated coffee (0901.21.00), according to public tariff listings. Together with the generally applicable exemption, that suggests a compliant entry of Cambodian green coffee should not carry a Section 301 charge today. But exemptions are written by HTS line, in annexes running to hundreds of pages, so 'coffee is exempt' is a strong signal and not a substitute for checking the code on your own entry.
Why coffee is treated differently
The determination as summarised by Honigman gives two grounds for the generally applicable exemptions that are relevant here. One is products that cannot be grown or produced in sufficient quantities or at reasonable prices in the United States or obtained from other sources, with coffee named as the example. The other is articles where a Section 301 tariff is unlikely to advance the policy goal, which is eliminating forced-labor practices. Coffee was also part of the November 2025 decision to remove reciprocal tariffs from a large group of food imports, which an industry group welcomed as a step toward affordable food prices.
What a Fine Robusta importer should verify
- HTS classification. Green, unroasted coffee and roasted coffee sit on different tariff lines, and exemptions attach to lines. Confirm the code with your broker rather than assuming.
- Entry date. Rates changed on 24 February and 24 July 2026. Duty is determined at entry, so shipments that straddle a change need attention.
- Country-of-origin records. Duty treatment depends on origin. Keep lot documents that show Cambodian growing and processing, and be cautious with blended or re-exported lots.
- Importer of record. US duties and fees are owed by the importer of record, usually the US buyer rather than the Cambodian exporter. The merchandise processing fee (0.3464% of value on formal entries, within limits) and, for ocean freight, the harbor maintenance fee (0.125% of value) are separate from tariffs.
- Contract wording. State which party bears any tariff change between order and entry.
- Sample shipments. Treat samples as entries too. Ask your broker how they will be classified and documented.
- Past IEEPA duties. If you imported Cambodian goods between 2025 and 24 February 2026, CBP is refunding IEEPA duties to the importer of record through its CAPE process, according to Airlift's summary of CBP guidance. Ask your broker whether any of your entries qualify.
For documents and buyer checks beyond tariffs, see How to Import Cambodian Coffee. For how lots are evaluated once they arrive, see Fine Robusta vs Arabica: What Buyers Should Understand.
What could change
Three uncertainties remain. Honigman expects litigation against the Section 301 action, and separate litigation over the Section 122 tariffs continues at the Federal Circuit. USTR also has other Section 301 investigations under way, including one on excess capacity, so additional duties may be announced later this year. And exemption annexes can be amended. A buyer signing a multi-shipment contract should assume the rules may move.
Frequently asked questions
Is there a US tariff on Cambodian green coffee in September 2026?
Most Cambodian goods pay a 10% Section 301 tariff on top of normal duty, but coffee is named as an example of a generally exempt category. Confirm the HTS line and entry date with a customs broker.
Is there still a 19% reciprocal tariff on Cambodia?
No. The 19% rate was an IEEPA duty. After the Supreme Court's 20 February 2026 ruling, CBP stopped collecting IEEPA duties on 24 February 2026. The 10% now charged on most Cambodian goods is a separate Section 301 duty.
Who pays US tariffs on Cambodian coffee?
The importer of record, which is usually the US buyer.
Does the exemption cover roasted coffee as well as green coffee?
Exemptions are set by tariff line, so roasted and green coffee must be checked separately. We did not confirm the annex listing for roasted coffee.
Limitations
This summary relies on a law-firm alert (Honigman), a freight forwarder's tariff tracker that cites primary USTR, CBP and Federal Register documents (Airlift USA), trade press, and public tariff listings. We did not review the full Federal Register annexes, so we cannot confirm exemption status for every coffee HTS line. Tariff policy is changing quickly; check current USTR and CBP notices before any transaction. This is not legal or customs advice.
Sources
- Honigman LLP, 'Section 122 Tariffs Expire for Many Imports, But New Section 301 Forced-Labor Tariffs on 60 Economies Replace Them' (24 July 2026): https://www.honigman.com/alert-3462
- Airlift USA, 'US tariffs on Cambodia in 2026: what Cambodian goods pay now and what changed' (updated 25 September 2026; cites USTR notice 91 FR 47318, CBP CSMS 67834313 and the Supreme Court opinion): https://airliftusa.com/tariff-updates/cambodia
- USTR notice of actions in Section 301 forced-labor investigations, 91 FR 47318 (28 July 2026), as cited by Airlift: https://www.federalregister.gov/documents/2026/07/28/2026-15181/notice-of-actions-in-section-301-investigations-of-acts-policies-and-practices-of-various-economies
- Supply Chain Dive, 'US exempts 200+ agricultural products from reciprocal tariffs' (14 November 2025): https://www.supplychaindive.com/news/us-exempts-200-agricultural-products-reciprocal-tariffs/805625/
- Khmer Times, 'Cambodia eliminates tariffs on all imports from the US' (29 October 2025): https://www.khmertimeskh.com/501780112/cambodia-eliminates-tariffs-on-all-imports-from-the-us/
- UNIS HTS listing, 0901.11.00 (green coffee) and 0901.21.00 (roasted coffee), general duty rate Free: https://www.unisco.com/hts/09011100
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