If PNTR Goes: A Line-Level Map of China’s Exposure to Column 2 Rates

Census figures recomputed October 13, 2026 from the official USITC HTS export dated 2026-10-09 (23,193 ten-digit lines). Every number below is reproducible from that dataset; the measurement caliber is stated where a count depends on one.

In March 2026 the U.S. International Trade Commission opened Investigation 332-609 into a possible revocation of China’s Permanent Normal Trade Relations status, after a Federal Register notice (doc. 2026-04100) requested exactly that analysis. Commentaries since have argued about aggregate simulations. Importers do not ship aggregates — they ship ten-digit lines. This page maps what the statute already prices in: the Column 2 rate printed on every line of the Harmonized Tariff Schedule, waiting behind China’s Column 1 treatment.

The short version

Restricting the census to the 12,705 lines whose General and Column 2 rates both carry an ad valorem percentage that can be compared directly:

• 12,503 of 12,705 (98.4%) are more expensive under Column 2.
• The median gap is +34.7 points; the mean is +39.6 points.
• 9,126 lines rise by 25 points or more; 3,582 lines by 50 points or more.
• The widest gap is +143.0 points on 2921.49.38.00 — psychotherapeutic drugs move from 6.5% to a compound 15.4¢/kg + 149.5%, so the true change is even larger once the per-kilogram component is added.
• Beyond the comparable set, 5,952 duty-free lines carry a positive Column 2 rate: 5,600 purely ad valorem, 352 compound with a per-unit add-on. Duty-free today, taxable at up to 149.5% under the alternative regime.

Where the exposure concentrates

Chapter 62 (woven apparel) is the epicenter: 1,335 comparable lines worsen, with a median increase of 60.0 points. Organic chemicals (chapter 29, 988 lines) and machinery (chapter 84, 947 lines) follow in raw count, with median gaps of +38.5 and +32.0 points — far shallower than apparel’s hit. The chemicals-and-machinery story is breadth, apparel’s is depth.

Universe: lines where both columns parse as ad valorem and Column 2 is higher (12,503 lines); medians computed on each chapter’s subset of that universe. Codes are shown exactly as printed in the schedule: heading-level lines carry eight digits, statistical lines ten.

The Free-to-paid cliff

Average-gap statistics understate what buyers feel most: paying any duty at all on goods that enter free today. 5,952 lines sit on that cliff. Three verbatim rows from the schedule:

On a $10,000 customs value, metal furniture goes from $0 to $4,500 in duty; the auto-parts line accrues $2,750. Those are arithmetic illustrations from measured rates, not forecasts — actual assessments would layer on any Chapter 99 actions in force at the time, which is what our duty calculator tracks.

Anatomy of the widest gap

Chloromethane (2903.11.00) shows how wide the statutory band is even before per-unit components: 5.5% general versus 125% Column 2, a +119.5-point spread. The record holder among comparable lines, 2921.49.38.00, adds the compound twist: the percentage component alone widens by 143.0 points (6.5% → 149.5%) and a 15.4¢/kg charge appears. For a heavy, low-value shipment the per-kilogram term can dominate — which is why single-percentage comparisons systematically understate compound exposure.

Honest exceptions

Three groups soften the picture, and a serious sourcing plan starts from them:

• 1,501 lines are Free in both columns — mostly raw materials and certain minerals; relocation into those categories buys no protection because there is nothing to lose.
• 106 comparable lines price lower under Column 2. Rare, but they exist — wood charcoal (4405.00.00.00) edges from 3.2% down to 3.0% — and the gaps in this group are small fractions of a point.
• Compound lines resist summary. Wherever you see ¢/kg terms, the percentage is only half the story; the unit-of-quantity term scales with weight, not value.

What a buyer should do with this map

1. Find your ten-digit line and read both columns — the exposure is printed in the statute today, no simulation required.
2. Compute the delta against your actual customs value, remembering that Section 301 actions and any future measures stack on top of whichever column applies (how stacking works).
3. Weigh the chapter pattern: apparel and footwear suppliers face deep cuts (median +57 to +60 points), while machinery suppliers face shallow-but-wide increases across thousands of lines.
4. Watch the investigation, not the headlines: outcome timing is political; the rate ceilings are already fixed in the schedule (current Chapter 99 actions by chapter).

For the mechanics of the second rate column itself — who pays it today, and why pharmaceutical lines dominate its extremes — see our Column 2 explainer; for the broader Section 301 overlay on China-origin goods, see the Section 301 guide. If you want these ceilings monitored against your own lines instead of checking manually, sign up free and set alerts.

Frequently asked questions

What is Column 2, and why does it matter for China trade?

Column 2 holds the statutory rates the US tariff schedule assigns to countries that do not receive Normal Trade Relations (NTR). When Congress granted China Permanent Normal Trade Relations in 2000, Chinese-origin goods moved to the much lower Column 1 general rates. The Column 2 rates were never deleted, so the schedule still prices in the contingency of PNTR being revoked for every single one of the 23,193 tariff lines.

How many lines get more expensive if PNTR is revoked?

Among the 12,705 lines where both the general and the Column 2 rate carry an ad valorem percentage we can compare directly, 12,503 (98.4%) are higher under Column 2. The median increase is 34.7 percentage points, 9,126 lines rise by 25 points or more, and 3,582 lines rise by 50 points or more. On top of those, 5,952 lines that are duty-free today carry a positive Column 2 rate.

Which products face the biggest single-line jumps?

The widest ad valorem gap is 143.0 percentage points on 2921.49.38.00 (antidepressants and other psychotherapeutic agents), which moves from 6.5% to a compound 15.4 cents per kilogram plus 149.5%. Chloromethane (2903.11.00) jumps from 5.5% to 125%. Among duty-free lines, metal furniture (9403.20.00) would pay 45%, certain auto parts (8708.99.48) 27.5%, and Vitamin B12 (2936.26.00.00) a compound 15.4 cents per kilogram plus 145.5%.

Would every product cost more under Column 2?

No, and honest planning needs the exceptions. 1,501 lines are Free in both columns, 106 comparable lines actually price lower under Column 2, and many agricultural and chemical lines carry compound rates where the per-unit component matters as much as the percentage. Chapter 62 apparel shows how concentrated the pain is: 1,335 of its comparable lines worsen, with a median increase of 60.0 percentage points.

How do I check the Column 2 exposure of my own HTS line?

Look up your ten-digit line in the current schedule, read the General rate and the Column 2 rate, and multiply the difference against your customs value: a line at 5.5% general versus 125% Column 2 on a $10,000 shipment moves from $550 to $12,500 in duty. Our free calculator computes stacked totals including Chapter 99 actions, and our Column 2 explainer covers how non-NTR rates work in practice.