Section 232 vs 301 vs 122 vs AD CVD. A Cabinet Tariff Decoder For Multifamily Developers

A single container of imported wooden cabinets entering the Port of Long Beach in May 2026 can pass through four separate federal tariff mechanisms, administered by three different agencies, citing four different statutory authorities, with rates that stack rather than substitute. Section 232 of the Trade Expansion Act of 1962, Section 301 of the Trade Act of 1974, Section 122 of the same Trade Act, and the anti dumping and countervailing duty regime under the Tariff Act of 1930 each impose duties for different statutory reasons, on different timetables, with different procedural triggers. A general contractor or developer who treats the cabinet duty as a single number on a customs invoice is reading a sum that is hiding the four moving parts underneath it.

Wirko Building Solutions writes this decoder for the procurement audience that has to model cabinet landed cost across a 2026 to 2027 project pipeline. The plain English breakdown of each authority, the current rates relevant to wooden cabinets and vanities, the stacking behavior on a real worked example, and the Mexico USMCA position that lets a USMCA qualifying supply program sit cleanly outside three of the four layers.

The four authorities, in plain English

Each authority answers a different statutory question. The question matters because it determines who triggers the tariff, what evidentiary process is required, what the time horizon looks like, and which products are covered.

Section 232. National security tariff

Statutory basis. Section 232 of the Trade Expansion Act of 1962, codified at 19 USC 1862. The statute authorizes the President to impose tariffs on imports the Department of Commerce has investigated and found to threaten US national security. The investigation is conducted by Commerce. The tariff is set by Presidential proclamation. There is no fixed rate cap and no fixed duration in the statute.

Trigger. A Commerce investigation, opened either at the President's direction, the petition of an interested party, or the application of an industry. Commerce has 270 days to report findings. The President has 90 days from the report to act.

Scope on cabinets. The wood furniture Section 232 investigation concluded with a Presidential proclamation imposing a 25 percent tariff on imported wood furniture, including wooden cabinets and vanities, effective October 14, 2025 (CBP implementation guidance, bulletin 3f69699). The same proclamation originally scheduled a step up on January 1, 2026, with cabinets and vanities to 50 percent and upholstered wooden furniture to 30 percent. The step up has been delayed indefinitely. The 25 percent rate remains in effect on cabinets and vanities at minimum until January 1, 2027. The proclamation contains no USMCA exemption. Canadian and Mexican wooden cabinets and vanities pay the same 25 percent Section 232 rate as cabinets from any other origin.

Time horizon. Indefinite. Section 232 tariffs remain in place until repealed by a subsequent Presidential proclamation, which the political process makes infrequent.

Section 301. Trade enforcement tariff (China specific in current usage)

Statutory basis. Section 301 of the Trade Act of 1974, codified at 19 USC 2411. Authorizes the United States Trade Representative to impose tariffs on countries whose acts, policies, or practices are unjustifiable, unreasonable, or discriminatory and burden US commerce.

Trigger. A USTR investigation initiated by petition or USTR self initiation. USTR makes determinations and the tariffs are imposed by USTR action subject to interagency review.

Scope on cabinets. The Section 301 actions against China imposed during the 2018 to 2019 sequence include wooden furniture and cabinets. The current Section 301 List 3 rate on wooden cabinets and vanities of Chinese origin is 7.5 percent. The List 3 rate began at 10 percent, escalated to 25 percent during the trade dispute, and was cut to 7.5 percent under the Phase One agreement, where it has remained. Section 301 is country specific in current usage and applies only to Chinese origin merchandise on the listed HTS subheadings. On March 11, 2026, USTR initiated multiple new Section 301 investigations following the Supreme Court IEEPA decision; outcomes are pending and the bidder list packet carries the current List 3 rate against any modification announced in the Federal Register.

Time horizon. Subject to USTR statutory four year reviews. The first four year review concluded with continuation. Future modifications are possible at each review window.

Section 122. Balance of payments surcharge

Statutory basis. Section 122 of the Trade Act of 1974, codified at 19 USC 2132. Authorizes the President to impose import surcharges of up to 15 percent ad valorem for up to 150 days in response to a fundamental international payments problem.

Trigger. Presidential proclamation. The statute requires findings tied to balance of payments conditions but does not require a Commerce investigation or USTR determination. The 150 day clock starts on the date the surcharge takes effect. Extension beyond 150 days requires Congressional action.

Scope on cabinets. As of May 2026, Section 122 is the operative replacement mechanism for the broader Reciprocal Tariff regime that the Supreme Court struck down in Learning Resources, Inc. v. Trump on February 20, 2026. The Administration imposed a Section 122 surcharge effective February 24, 2026 at 12:01 a.m. EST across a broad range of imported goods. The surcharge began at 10 percent and was raised to 15 percent on February 22, 2026 (taking effect with the February 24 imposition). It runs for the statutory maximum 150 days, expiring July 24, 2026 unless Congress extends. The proclamation excludes goods already subject to Section 232, which means wooden cabinets and vanities (covered by the October 14, 2025 Section 232 wood furniture proclamation) are NOT subject to the Section 122 surcharge regardless of country of origin. Steel, aluminium, copper, lumber, and other wood products are similarly excluded. The de-minimis suspension continues for goods that would otherwise be in scope.

Time horizon. 150 days from imposition. Statutorily capped. Renewal would require either a fresh Presidential proclamation citing a new balance of payments determination or Congressional action.

Anti dumping and countervailing duty (AD CVD)

Statutory basis. The Tariff Act of 1930 as amended, primarily Title VII (19 USC 1671 and following). Anti dumping duties offset sales of imported merchandise at less than fair value. Countervailing duties offset foreign government subsidies on the merchandise.

Trigger. A petition filed by a US industry or an investigation self initiated by Commerce. The Department of Commerce calculates the dumping margin and countervailing rate. The International Trade Commission determines material injury. Both must affirm for an order to take effect.

Scope on cabinets. The 2020 wooden cabinets and vanities order from the People's Republic of China is the principal AD CVD action governing cabinet imports. Anti dumping cash deposit rates range from 4.37 percent to 262.18 percent depending on producer. Countervailing rates range from 13.33 percent to 293.45 percent. A 2023 circumvention finding extends the order to Vietnamese cabinets produced from Chinese components. A Malaysian circumvention inquiry is active. The Wirko Building Solutions companion article on anti dumping investigations covers the order and the certification regime in detail.

Time horizon. Indefinite, subject to five year sunset reviews. The 2020 order is in its first sunset review window in 2025 and 2026 with industry expectation of continuation through 2030.

Comparison table

How the layers stack on the same shipment

The four authorities are cumulative, not substitutive. A container of cabinets subject to two of them owes both. A container subject to all four owes all four. The math is mechanical.

Worked example one. A container of $100,000 declared customs value of wooden cabinets manufactured in China, shipped by a Chinese exporter that is not a mandatory respondent on the 2020 AD CVD order and therefore receives the China wide rate.

A $100,000 commercial value declaration triggers $588,130 in duty deposits. The Chinese country wide rate is the math that removed Chinese cabinets from credible multifamily supply.

Worked example two. A container of $100,000 declared customs value of wooden cabinets manufactured in Vietnam, certified clean of the 2023 circumvention finding by the importer.

A 25 percent effective duty stack on certified Vietnamese cabinets. The certification documentation is what keeps this container off the Chinese rate. Without it, the Section 232 stack of 25 percent could become a stack of 580.63 percent.

Worked example three. A container of $100,000 declared customs value of wooden cabinets manufactured in Mexico, USMCA qualifying.

USMCA qualifying Mexican cabinets clear at the same 25 percent Section 232 rate as certified clean Vietnamese cabinets. The Mexican advantage in 2026 is not a Section 232 carve out; it is the absence of any AD CVD order, the absence of Section 301 exposure, and the absence of certification chain risk. The duty math is parity with certified Vietnamese on a clean container, but the Vietnamese number depends on the certification holding through every entry across the project's full delivery window. The Mexican number does not. The Wirko Building Solutions read is that on a 2026 multifamily program of any meaningful scale, the duty stability is what justifies the WBS supply structure through the Cabo Cabinet Group distribution arm.

How a developer should read the stack

The four authorities answer four different procurement questions.

Section 232 is the question of which countries are inside or outside the wood furniture proclamation. The answer in 2026 is that all origins, including Canada and Mexico, are subject to the 25 percent rate. The proclamation contains no USMCA exemption. The originally scheduled January 1, 2026 step up (cabinets to 50 percent) was delayed indefinitely; the 25 percent rate holds at minimum until January 1, 2027.

Section 301 is the question of whether the cabinets are Chinese origin. If yes, add 7.5 percent under List 3. If no, this layer is zero. New USTR Section 301 investigations were initiated March 11, 2026 following the Supreme Court IEEPA decision; outcomes are pending.

Section 122 is the question of whether the merchandise is currently subject to the 15 percent balance of payments surcharge. As of May 2026, the surcharge excludes goods already subject to Section 232, which means wooden cabinets and vanities are not in scope of the surcharge regardless of origin. The surcharge is on a 150 day clock running from February 24, 2026 and expiring July 24, 2026.

AD CVD is the question of producer and country. The 2020 China order plus 2023 Vietnam circumvention finding plus pending Malaysian inquiry covers most realistic Asian sourcing scenarios. Mexican wooden cabinets are currently free of any AD CVD order.

The decoder logic for any specific bid is. Identify origin. Identify producer. Identify USMCA qualification status. Apply the four layers individually. Sum the result. Compare across origin scenarios. The lowest landed cost almost always belongs to the supply chain that minimizes the number of layers in scope, not the supply chain that has the lowest unit price before duty.

What this means for the spec lock

A developer locking a multifamily cabinet spec in May 2026 should write the spec around two things. The supply origin and producer combination that minimizes exposure across all four authorities. And the contract language that pass through any layer that changes between contract signing and container clearance. A USMCA qualifying production stack with a tariff and AD CVD pass through clause is the bidder list standard in 2026. The Wirko Building Solutions supply chain through Cabo Cabinet Group is structured for the first. The pre qualification packet documents the second.

The four authority stack is not going away. The Section 232 step up on cabinets is delayed but on the table for any time after January 1, 2027. The Section 122 surcharge expires July 24, 2026 and will either be renewed in some form or replaced by a new mechanism if the underlying balance of payments condition does not change. The AD CVD orders are in continuation posture through 2030 at minimum. A multifamily program built on the assumption that the duty environment will simplify is built on the wrong assumption. A program built on the assumption that the four authority stack is the new baseline and the supply structure has to be designed accordingly is built on the right one.

Schema FAQ block

Q. What is the difference between Section 232, Section 301, Section 122, and AD CVD on cabinets?

A. Section 232 is a national security tariff under the Trade Expansion Act of 1962 currently imposing a 25 percent rate on imported wood furniture, cabinets, and vanities effective October 14, 2025, with no USMCA exemption (all origins pay). The originally scheduled January 1, 2026 step up to 50 percent has been delayed indefinitely; the 25 percent rate holds at minimum until January 1, 2027. Section 301 is a trade enforcement tariff under the Trade Act of 1974 imposing 7.5 percent on Chinese origin wooden cabinets under List 3. Section 122 is a balance of payments surcharge under the same statute, imposing 15 percent for 150 days from February 24, 2026 to July 24, 2026, but excluding goods already subject to Section 232 (which means wooden cabinets are not in the surcharge). AD CVD is anti dumping and countervailing duty under the Tariff Act of 1930, imposing rates from 4.37 to 262.18 percent (anti dumping) and 13.33 to 293.45 percent (countervailing) on Chinese wooden cabinets and on Vietnamese cabinets covered by the 2024 final scope determination, refined by the April 23, 2026 final results of the 2023-2024 administrative review.

Q. Which tariff authority applies to multifamily cabinet imports?

A. Up to three apply simultaneously on cabinets, depending on origin and producer (Section 122 does not apply to cabinets because the surcharge excludes goods already subject to Section 232). A USMCA qualifying Mexican cabinet pays the 25 percent Section 232 rate but carries no Section 301, no Section 122, and no AD CVD exposure. A Chinese cabinet from a non cooperating producer owes Section 232 plus Section 301 plus AD CVD simultaneously, stacking to a combined rate near 590 percent on the country wide rate. The decoder logic for any specific bid is to identify origin, identify producer, identify whether AD CVD scope or circumvention findings apply, and apply the layers individually.

Q. How do these tariff mechanisms stack on the same shipment?

A. The mechanisms are cumulative within each authority's scope, but Section 122 expressly excludes goods already subject to Section 232, so cabinets stack across at most three authorities, not four. On a $100,000 commercial value of Chinese cabinets from a non cooperating producer, the duty stack is approximately $588,130. On a $100,000 commercial value of certified clean Vietnamese cabinets, the stack is approximately $25,000. On a $100,000 commercial value of USMCA qualifying Mexican cabinets, the stack is also approximately $25,000 (Section 232 only). The differential between certified Asian and Mexican supply on duty alone is parity, but the certification chain risk on Asian supply across a multi quarter project schedule is what determines which supply chain a serious multifamily program builds on.

Q. Is USMCA Mexico cabinet supply truly outside all four authorities in 2026?

A. No. The Section 232 wood furniture proclamation contains no USMCA exemption, so Mexican wooden cabinets pay the 25 percent Section 232 rate alongside other origins. Section 301 does not apply (China specific). Section 122 does not apply to cabinets (the surcharge excludes goods already subject to Section 232). There is no AD CVD order on Mexican wooden cabinets. Net exposure on a USMCA qualifying Mexican cabinet is the 25 percent Section 232 rate only, which is parity with certified clean Vietnamese supply on duty alone. The Mexican advantage is the absence of AD CVD scope risk, the absence of Section 301 exposure, and the absence of certification chain administrative burden across a multi quarter delivery window. A multifamily developer should verify Section 232 implementation guidance before each spec lock and write tariff and AD CVD pass through language into the supply contract regardless.

Q. When does the next Section 232 cabinet tariff increase take effect?

A. The Presidential proclamation imposing the 25 percent Section 232 tariff on imported wood furniture, cabinets, and vanities effective October 14, 2025 originally scheduled a step up on January 1, 2026 (cabinets and vanities to 50 percent, upholstered wooden furniture to 30 percent). The step up has been delayed indefinitely and the 25 percent rate holds at minimum until January 1, 2027. A multifamily project with a spec lock and shipment schedule extending past that date should run two scenarios at 25 percent and 50 percent. The proclamation contains no USMCA exemption, so Canadian and Mexican origin cabinets pay the same Section 232 rate as cabinets from any other origin.

Related reading on the four authority stack.

The 2026 Cabinet Tariff Map. What Multifamily Developers Need Before Spec Lock

Anti Dumping Investigations On Cabinets. The Developer Guide To Factory Risk

Supreme Court Strikes IEEPA Tariffs. A Section 122 Cabinet Surcharge Field Guide

The Container To Cabinet Lifecycle. Eighteen Steps From Mill To Punch List

The Multifamily Cabinet Supply Chain. A Developer Reference Guide

If your 2026 or 2027 multifamily project has a cabinet package to release and you want a stacked landed cost model across multiple origin scenarios, add Wirko Building Solutions to your bidder list.

Last reviewed. 2026-05-02. Wirko Building Solutions reviews this article quarterly against new Federal Register notices, USTR review determinations, Presidential proclamations, and ITC sunset review publications.