Column 2 Duty Rate
The Column 2 duty rate applies to goods from countries that do not have Normal Trade Relations status with the United States — currently Cuba and North Korea for most goods, and Russia for a substantial range of products following the revocation of Russia's NTR status in 2022. Column 2 rates derive from the Smoot-Hawley Tariff Act of 1930 and are substantially higher than MFN rates — often by multiples.
In Detail
Column 2 rates appear in the third rate column of the HTSUS (Column 1 General, Column 1 Special, Column 2). They represent the pre-GATT tariff levels that the United States maintained before multilateral trade liberalization began in the late 1940s. Because these rates were never reduced through trade negotiations with non-NTR countries, they reflect Smoot-Hawley era protectionism — rates of 35% to 65% or higher for many manufactured goods, compared to MFN rates of 0–7% for the same goods.
The United States has extended NTR status to nearly all countries through a combination of permanent NTR legislation and annual renewals under the Jackson-Vanik Amendment for certain countries. Cuba and North Korea have never received NTR status under modern trade law and remain Column 2 countries. Russia's NTR status was revoked in April 2022 through the Suspending Normal Trade Relations with Russia and Belarus Act, making Column 2 rates applicable to a wide range of Russian-origin goods — a significant change for importers of Russian metals, energy products, and other commodities.
Column 2 is not additive to the MFN rate — it replaces it. For non-NTR country goods, Column 2 is the base duty rate, and any applicable trade remedy tariffs (Section 301, 232, IEEPA) are assessed on top of the Column 2 rate. This creates the possibility of very high combined duty burdens for goods from non-NTR countries that are also subject to trade remedy actions.
Classification Significance
Column 2 applicability is determined jointly by the HTS code (which shows the Column 2 rate) and the country of origin (which determines whether the non-NTR rate applies). Applying Column 1 MFN rates to Column 2 goods produces substantial duty underpayment — potentially by an order of magnitude for goods with very low MFN rates and very high Column 2 rates. CBP reviews entries from Cuba, North Korea, and Russia with heightened attention to duty rate column selection.
How Kanon Handles This
Kanon identifies the applicable duty column — Column 1 General, Column 1 Special, or Column 2 — based on the classified HTS code and the declared country of origin, documenting the correct rate and duty column in the Classification Support Package so the importer's total duty calculation reflects the legally applicable rate.