The US administration is rebuilding its global tariff program under Section 301, the trade law mechanism that has shaped apparel and footwear sourcing costs since 2018, according to an analysis by the law firm Morgan Lewis. For an industry that still sources a substantial share of its goods from China, the news is less a headline than a homework assignment.

Section 301 is the statute the Office of the US Trade Representative used to impose the original rounds of punitive duties on Chinese goods. What is now under way, per the Morgan Lewis assessment, is a restructuring of that program — a rebuild rather than a routine review. The distinction matters for anyone holding a costing sheet.

What does this change for sourcing teams?

The practical question is straightforward: what does this change for buyers with open orders and 2025 cost plans? The honest answer, on the evidence available, is that the architecture is moving and the exposure map needs redrawing. Any rebuild of the 301 program touches:

• Which Harmonized Tariff Schedule lines carry additional duties;
• Whether exclusions and exceptions survive the restructuring;
• How country-of-origin strategy — China plus Vietnam, India, Bangladesh — shifts in response.

Morgan Lewis's framing — a rebuilt global tariff program — suggests the changes reach beyond the original China-only scope. Trade lawyers do not use the word "global" casually. If additional jurisdictions or transshipment enforcement enter the frame, the compliance burden lands on vendors and importers of record, which is to say on the same people who already absorb the freight.

Intentions versus settled law

A note of discipline is required here. A law firm analysis of an administration's program is a reading of policy in motion, not a statute on the books. Confirmed tariff lines and confirmed exclusions remain the only numbers a CFO will sign off on. Everything else — scope, sequencing, effective dates — should be treated as announced intention until published in the Federal Register with an implementation date attached.

That said, sourcing professionals have learned the cost of waiting. The 2018–19 301 rounds moved faster than most seasonal calendars, and retroactive application was not off the table then. Lead times, not just landed cost, are the exposure: a rebuilt tariff program announced mid-season can strand goods on the water.

The compliance ledger

The burden-sharing question — who pays — remains the perennial one. Vendors in China and transshipment hubs will face renewed documentation scrutiny; brands will face renewed duty-valuation questions. Customs brokers and trade counsel will bill either way.

For now, the defensible moves are unglamorous: audit HTS classifications against the current 301 lists, model duty scenarios into 2026 costings, and identify which exclusions the current program still carries. The indefensible move is assuming the old map still holds.

Morgan Lewis's analysis signals that Washington intends the Section 301 framework to remain a live instrument, now with a wider geographic reach. Sourcing teams would be wise to read it the same way customs will: as a program being rebuilt while they are standing in it.