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Section 301 Tariffs on China
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Section 301 Investigation of France

Section 232 Tariffs on Steel & Aluminum

Section 232 Investigation of Automobiles & Auto Parts

Section 232 Investigation of Uranium

Tariffs on the EU - Airbus Dispute

Tariffs on Mexico

U.S. Legislation that Could Affect Section 232 & Section 301 Tariffs

Retaliatory Actions

Contact

Nicole Bivens Collinson
President, International Trade & Government Relations
nbc@strtrade.com
202.730.4956

Kristen Smith
Trade Remedies Practice Leader
ksmith@strtrade.com
202.730.4965

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Tariff Actions Resource Page

Updated September 19, 2019

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This page features information, deadlines and resource documents on the various U.S. tariff actions and the responses by the rest of the world.  

The "U.S. Actions" section includes information on the Section 232 investigations of steel and aluminum, automobiles and auto parts, and uranium. It also includes information on the Section 301 investigations of China and the EU, as well as the tariffs on Mexico under the International Emergency Economic Powers Act.  In the "Retaliatory Actions" section, find lists of all affected products. 

If you'd like an ST&R professional to narrow down the information to what's relevant and actionable for your company, don't hesitate to contact us.

U.S. Actions: Section 301 Tariffs, Section 232 Tariffs

Section 301 Tariffs on China

A Section 301 investigation determined that China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation are unreasonable and discriminatory. 

Product Lists

Please note these lists use the 2018 HTS. They are in the process of being updated to the most current 2019 HTS.

Every attempt has been made to ensure the accuracy of these lists. However, we recommend that you contact us with issues or questions and that you refer to the original Federal Register notices or CSMS messages for official information.

Section 301 Tariff: List 4A & List 4B 
Goods on List 4A and 4B will face a tariff of 15%, not 10% as previously indicated, effective Sept. 1, 2019, for List 4A products and Dec. 15, 2019, for List 4B products. 25 products have been removed from List 4 due to health, safety, national security, and other reasons and will not face any additional tariffs.

The combined list 4 covers essentially all products not already subject to Section 301 additional tariffs.  It includes all apparel, footwear, and manufactured textile products, among others, but excludes pharmaceuticals, certain pharmaceutical inputs, select medical goods, rare earth materials, and critical minerals.

ST&R has extensive experience helping companies respond to Section 301 tariff increases. Contact us for assistance.

Section 301 Tariff: List 3
List 3 products, with a total import value of $200 billion, were subject to an additional 10 percent tariff as of Sept. 24, 2018, and a tariff increase to 25% in May 2019.

Tariffs on List 3 goods were due to increase from 25% to 30% on October 1, 2019. Per a presidential tweet on September 11, 2019, the increase will be delayed until October 15, 2019, pending official notice. Comments on this proposal are due by Sept. 20. 

The exclusion process for List 3 products opened on June 30, 2019. Requests for exclusions may be submitted until Sept. 30, 2019.  Requests for exclusion from List 3 require much more information than has been required for List 1 and List 2 goods and must be submitted via an online portal.  

New! USTR granted 10 HTS exclusions in August 2019, and 38 HTS exclusions in September 2019, all of which are product specific. All exclusions granted will be retroactive to Sept. 24, 2018, and will expire August 7, 2020. 

ST&R has extensive experience assisting companies with requesting exclusions as well as mitigating the impact of this tariff increase through tariff classification, tariff engineering, first sale, and other methods. Contact us for assistance.

Section 301 Tariff: List 2
List 2 products, with a total import value of $16 billion, were subject to an additional 25% tariff as of Aug. 23, 2018.

Tariffs on List 2 goods were due to increase from 25% to 30% on October 1, 2019. Per a presidential tweet on September 11, 2019, the increase will be delayed until October 15, 2019, pending official notice. Comments on this proposal are due by Sept. 20. 

New! USTR granted 69 HTS exclusions in July 2019, and 89 HTS exclusions in September 2019, all of which are product-specific. 1048 exclusion requests are still undergoing review as of the latest update (Sept. 13, 2019). All exclusions granted are retroactive to Aug. 23, 2018, and remain in place for one year after the exclusion determination is published in the Federal Register. The deadline for requesting exclusions from this increase was Dec. 18, 2018.

Section 301 Tariff: List 1
List 1 products, with a total import value of $34 billion, were subject to an additional 25% tariff as of July 19, 2018. 

Tariffs on List 1 goods were due to increase from 25% to 30% on October 1, 2019. Per a presidential tweet on September 11, 2019, the increase will be delayed until October 15, 2019, pending official notice. Comments on this proposal are due by Sept. 20. 

New! USTR has granted 324 HTS exclusions from December 2018 - July 2019, and 310 HTS exclusions in September 2018, some of which are product-specific and others that cover entire subheadings. 1,129 exclusion requests are still undergoing review as of the latest update (Sept. 13, 2019). All exclusions granted are retroactive to July 6, 2018, and remain in place for one year after the exclusion determination is published in the Federal Register. The deadline for requesting exclusions from this increase was Oct. 9, 2018.

Latest News

Exclusion Requests 

Official Documents

List 4 

List 3 

List 2 

List 1 

Other

Dates & Deadlines

List 1 

Date

25% duty effective on List 1 items July 6, 2018
Deadline to request exclusions October 9. 2018
Duty raised to 30%, pending official notice

October 15, 2019
(previously October 1, 2019)



List 2

Date

Comments on specific subheadings due July 23, 2018
Deadline to request to appear at hearing June 29, 2018
Pre-hearing submissions due June 29, 2018
Hearing on List 2 products July 24, 2018
Post-hearing rebuttal comments due

July 31, 2018

25% duty effective on List 2 products

August 23, 2018

Deadline to request exclusions

December 18, 2018

Duty raised to 30%, pending official notice

October 15, 2019
(previously October 1, 2019)



List 3

Date

Deadline for filing requests to appear at hearing and summary of expected testimony

August 13, 2018
(previously July 27, 2018)

Hearing on List 3 products August 20 - 27, 2018
(extended from August 20 - 23)
Post-hearing rebuttal comments due September 6, 2018
(previously August 30, 2018)
Due date for submission of written comments

September 6, 2018
(previously August 17, 2018)

10% additional duty effective on List 3 products

September 24, 2018

USTR reports the nature & timing of exclusion process to Congress

March 17, 2019
(USTR did not meet deadline)

25% additional duty effective on List 3 products

May 10, 2019
(previously January 1, 2019 & March 2, 2019)

Exclusion process details released

June 20, 2019

Web portal for submitting exclusions opens

June 30, 2019, noon EDT

Deadline to request exclusions

September 30, 2019

Duty raised to 30%, pending official notice

October 15, 2019
(previously October 1, 2019)



List 4

Date
Deadline for requests to appear at the public hearing June 10, 2019
Public hearing on List 4 products June 17, 2019 - June 25, 2019
Written comments due, including input on the specific tariff levels that should be imposed and requests to exclude specific subheadings June 17, 2019
Post-hearing rebuttal comments July 2, 2019 

15% additional duty effective on List 4A products

Note duty was originally 10% 

September 1, 2019

15% additional duty effective on List 4B products

Note duty was originally 10% 

December 15, 2019

Section 301 Investigation of France's Digital Services Tax

On July 10, 2019, USTR initiated an investigation with respect to the Digital Services Tax (DST) under consideration by France. This investigation could take up to 12 months, and could result in tariffs or other restrictions on imports from France if the two sides are not able to reach a settlement. Watch this space for updates on this investigation. 

Latest News

Official Documents

Dates & Deadlines

USTR initiates the investigation July 10. 2019
Deadline for filing requests to appear at the public hearing August 12, 2019, noon EDT
Public hearing August 19, 2019
Deadline for filing post-hearing submissions August 26, 2019


Section 232 Tariffs on Steel & Aluminum

Effective June 1, 2018, additional tariffs of 25 percent and 10 percent on steel and aluminum imports were imposed for almost all countries. As of May 20, 2019, steel and aluminum products from Canada and Mexico are not subject to the additional tariffs. The following products are covered by these proclamations. 

Countries and/or companies negatively impacted by these additional tariffs can petition for an exclusion. In June 2019, the BIS announced a new online portal to facilitate the submission and management of Section 232 exclusion requests, objections to exclusion requests, rebuttals, and surrebuttals. All new Section 232 exclusion requests must be submitted through this portal beginning June 14.

Latest News

Exclusion Request Forms

Official Documents

Section 232 Investigation of Automobiles & Auto Parts

The Department of Commerce announced May 23, 2018 its self-initiation of an investigation under section 232 of the Trade Expansion Act of 1962 to determine whether imports of automobiles (including SUVs, vans, and light trucks) and auto parts are harming U.S. national security.  The results of the investigation were submitted to President Trump on February 17, 2019.

On May 17, 2019, President Trump announced that he is delaying a decision for 180 days. During that time the U.S. plans to hold talks with the European Union, Japan, and possibly others that will likely seek to reduce imports from those countries. According to the proclamation, the DOC determined that U.S.-owned auto producers’ share of the domestic and global markets has fallen sharply in recent decades, which decreases the sales revenues that enable the research and development expenditures necessary for long-term automotive technological superiority, which in turn is essential for national defense. 

Latest News

Section 232 Investigation of Uranium

President Trump will not impose tariffs or quotas on uranium imports.

The Department of Commerce announced July 18, 2018 its self-initiation of an investigation under section 232 of the Trade Expansion Act of 1962 to determine whether the present quantity and circumstances of uranium ore and product imports threaten to impair U.S. national security. In April 2019, the department determined that imports of uranium are threatening U.S. national security. 

However, a July 12, 2019 presidential memorandum states that while the report's findings "raise significant concerns...a fuller analysis of national security considerations with respect to the entire nuclear fuel supply chain is necessary at this time." To that end, the memorandum establishes the United States Nuclear Fuel Working Group, but declines to adjust imports through tariffs and quotas.

Latest News

Official documents

Tariffs on the EU - Aircraft Dispute

In May 2019, the World Trade Organization ruled that European Union subsidies to Airbus have caused adverse affects to the United States. On April 8, 2019, USTR identified a preliminary list of EU products to which additional duties may be applied. The estimated import value of the goods on the preliminary list was approximately $21 billion in 2018. On July 5, 2019, USTR identified a second list of EU products, with a value of approximately $4 billion, that may be subject to additional duty. The products can be found here.

USTR estimates the harm from the EU subsidies at $11 billion in trade each year, but the EU has challenged that figure. A final decision from a WTO arbiter is expected this summer, and the final list subject to additional duty will reflect only the amount of trade found to be adversely affected in the arbitrator's decision.

Importers with goods on these lists should consider taking proactive measures to mitigate the impact of any potential tariff increase, such as working to have their products omitted from the final list or considering alternative sourcing locations. For assistance in this effort, please contact Kristen Smith at (202) 730-4965.

The EU has published their own preliminary list of U.S. products on which the EU could impose additional tariffs of up to 100 percent as part of this dispute, which you can find here and in the Retaliatory Actions section below.

Latest News

Product List

Official Documents


Dates & Deadlines

Item

Date

Due date for submission of requests to appear at the public hearing and summary of testimony
(Products on April 2019 notice)

May 6, 2019

Section 301 Committee Public Hearing 
(Products on April 2019 notice)
May 15, 2019
Due date for submission of written comments, including post-hearing rebuttal comments
(Products on April 2019 notice)
May 28, 2019
Due date for submission of requests to appear at the public hearing and summary of testimony
(Products on July 2019 notice)
July 24, 2019
Due date for submission of written comments, including post-hearing rebuttal comments
(Products on July 2019 notice)
August 5, 2019
Section 301 Committee Public Hearing 
(Products on July 2019 notice)
August 5, 2019
Due date for post-hearing rebuttal comments
(Products on July 2019 notice)
August 12, 2019

Tariffs on Mexico (indefinitely suspended)

No additional tariffs related to border security are in effect or are currently scheduled to go into effect.

On the evening of May 30, 2019 in an effort to push Mexico to address immigration issues, the White House announced that a 5% tariff would be imposed on goods from Mexico effective June 10, with the rate increasing by 5% each month, up to 25%.  On Friday, June 7th, President Trump announced that the tariff was "indefinitely suspended" in light of a bilateral agreement to work toward a "durable solution" on "irregular migration" from Mexico to the U.S. 

Latest News

U.S. Legislation that Could Affect Section 232 & Section 301 Tariffs

Companies interested in supporting any or all of the below legislation should contact Nicole Bivens Collinson by email or at (202) 730-4956.  

Name Description Senate House

Global Trade Accountability Act of 2019

To provide for congressional review of the imposition of duties and other trade measures by the executive branch, and for other purposes.  S.1284 H.R.273

Import Tax Relief Act of 2019

To require the establishment of a process for excluding articles imported from the People’s Republic of China from certain duties imposed under section 301 of the Trade Act of 1974, and for other purposes. S.577   H.R.1452

Bicameral Congressional Trade Authority Act of 2019

To amend the Trade Expansion Act of 1962 (Section 232) to impose limitations on the authority of the President to adjust imports that are determined to threaten to impair national security, and for other purposes. S.287 H.R.940

Trade Security Act of 2019

To amend section 232 of the Trade Expansion Act of 1962 to require the Secretary of Defense to initiate investigations and to provide for congressional disapproval of certain actions, and for other purposes. S.365 H.R.1008

Reclaiming Congressional Trade Authority Act 2019

To limit the authority of the President to modify duty rates for national security reasons (Section 232) and to limit the authority of the United States Trade Representative to impose certain duties or import restrictions, and for other purposes. S.899 H.R.3477

To prohibit the imposition of duties on the importation of goods under the International Emergency Economic Powers Act

Legislation has been introduced in the House to limit the President's ability to impose duties under the IEEPA. The IEEPA was the act invoked for the proposed tariffs on Mexico in June 2019. No Senate Bill H.R.3557

Promoting Responsible and Free Trade Act of 2019

To require congressional approval of certain trade remedies, and for other purposes. No Senate Bill H.R.3673

Trade Certainty Act of 2019

To exclude the imposition of duties and import quotas from the authorities provided to the President under the International Emergency Economic Powers Act. S___ No House Bill

Establishing exclusions from section 301 & section 232 duties

To establish a process for United States businesses to obtain exclusions from certain duties imposed under section 301 of the Trade Act of 1974 and section 232 of the Trade Expansion Act of 1962, and for other purposes S.2362 No House Bill Yet


Retaliatory Actions

The U.S. faces retaliatory actions from China, the EU, India, Turkey and Russia. Find affected products by viewing our Mega Matrix. The Mega Matrix now contains products on the 301 Airbus retaliation list proposed by the EU in April 2019.

New! On September 11, 2019, China released two lists of products to be excluded from from 301 tariffs. The exclusions will start on Sept. 17, 2019 and be valid for one year.  

Prior to May 20, 2019, the U.S. faced retaliatory actions from Canada and Mexico in addition the countries named above. However, all retaliatory tariffs from Canada and Mexico have now been eliminated.

There is an exclusion process for China's tariffs. Contact us for more information.

Click the list name below to view products by country along with tariff rates.

Latest News

Country / Region

Product List

Effective Date

China

232 Retaliation List

April 2, 2018

China

301 Retaliation List One
Released June 16, 2018

July 6, 2018
Exclusion requests accepted between June 3, 2019 - July 5, 2019

China

301 Retaliation List Two, Version 1
Released June 16, 2018

301 Retaliation List Two, Version 2
Released August 8, 2018

August 23, 2018
Exclusion requests accepted between June 3, 2019 - July 5, 2019

China

301 Retaliation List 3.1 - 10% & 25% Tariff

301 Retaliation List 3.2 - 10% & 20% Tariff

301 Retaliation List 3.3 - 5% & 10% Tariff

301 Retaliation List 3.4 - 5% & 5% Tariff (no rate change)


Released August 3, 2018
Finalized September 17, 2018
Amended May 13, 2019

September 24, 2018 at lower tariff rate specified

June 1, 2019 at higher tariff rate specified

Exclusion requests accepted between September 2, 2019 - October 18, 2019

EU

232 Retaliation List One

June 22, 2018

EU

232 Retaliation List Two

March 23, 2021

EU

301 Airbus Retaliation

Released April 17, 2019

TBD - level of damages depends on WTO arbitration verdict expected in late 2019 or early 2020.

India

232 Retaliation List

June 16, 2019
(previously 6/21/2018, 9/18/2018, 11/2/2018, 12/17/2018, 3/2/2019 & 4/1/2019)

Turkey

232 Retaliation List
Certain Duties Doubled as of August 15, 2018

June 21, 2018

Russia

232 Retaliation List

August 5, 2018

Customs & International Headlines