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Section 301 Tariffs on China
New!

Section 301 Investigation of France

Section 232 Tariffs on Steel & Aluminum
New!

Section 232 Investigation of Automobiles & Auto Parts

Section 232 Investigation of Uranium

Section 232 Investigation of Titanium Sponge
New!

Tariffs on the EU - Airbus Dispute
New!

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

ST&R Trade Report

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Read our article: The Art of the Trade Deal 2.0 – Update on Top Strategies to Avoid or Reduce Section 232 and 301 Duty Increases

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Tariff Actions Resource Page

Updated March 27, 2020

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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  France, the tariffs on the EU related to the Airbus dispute, and the threatened tariffs on Mexico.  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. 

On January 15, 2020, the United States and China signed a Phase One Economic and Trade Agreement. Under the Phase One deal, the U.S. has suspended some tariff increases (List 4B) and will roll back others (List 4A) in return for what the White House calls "structural reforms and other changes to China's economic and trade regime." According to information from the Office of the U.S. Trade Representative, the agreement includes provisions on intellectual property, technology transfer, agriculture, currency and expanding trade. It also establishes a dispute resolution system. Find full details of the Phase One Agreement on USTR's website.

Product Lists

Please note we are unable to provide the below lists in Excel.

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.

Please note we are unable to provide the above lists in Excel.

Section 301 Tariff: List 4A & List 4B 
On January 15, 2020, USTR issued a Federal Register notice reducing the rate of additional tariffs on List 4A products to 7.5%, effective February 14, 2020. Goods on List 4A were previously subject to a 15% additional tariff effective Sept. 1, 2019. List 4 goods have a cumulative import value of $300 billion.

The 15% tariffs on List 4B are suspended, per a Federal Register notice issued 12/13/19.

New! The exclusion process for items on List 4A is now closed. USTR granted 39 HTS exclusions in March 2020, some of which are product specific and others that cover entire subheadings.

ST&R has extensive experience assisting companies with 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 3
List 3 products, with a total import value of $200 billion, are subject to an additional 25% tariff as of 5/10/19. List 3 products originally faced a 10% tariff which was effective from 9/24/18 until they were increased to 25%. The additional tariff on List 3 products is not affected by the Phase 1 deal and will remain at 25%. 

New! The exclusion process for List 3 products is now closed. USTR granted 664 HTS exclusions from August 2019 - March 2020. Some of these are product specific and others cover entire subheadings. Additional exclusions may be granted. All exclusions granted will be retroactive to Sept. 24, 2018, and expire August 7, 2020. 

ST&R has extensive experience assisting companies with 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, are subject to an additional 25% tariff as of Aug. 23, 2018. The additional tariff on List 2 products is not affected by the Phase 1 deal and will remain at 25%. 

All exclusion requests from List 2 have been reviewed as of October 3, 2019, and 269 HTS exclusions were granted, covering 1,074 individual exclusion requests. 1,795 individual exclusion requests were denied. All granted exclusions are product specific and retroactive to Aug. 23, 2018. They will remain in place for one year after the exclusion determination is published in the Federal Register.

New! In March 2020, a Federal Register notice was released requesting public comment on possible further modifications to remove duties from medical care products needed to address the COVID-19 outbreak. Comments will be accepted at least until June 25, 2020. 

ST&R has extensive experience assisting companies with 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 1
List 1 products, with a total import value of $34 billion, were subject to an additional 25% tariff as of July 19, 2018. The additional tariff on List 1 products is not affected by the Phase 1 deal and will remain at 25%. 

All exclusion requests from List 1 have been reviewed and 730 HTS exclusions were granted, covering 3,653 individual exclusion requests. 7,161 individual exclusion requests were denied.  Some granted exclusions are product specific and others cover entire subheadings. 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.

New! In March 2020, a Federal Register notice was released requesting public comment on possible further modifications to remove duties from medical care products needed to address the COVID-19 outbreak. Comments will be accepted at least until June 25, 2020. 

Some exclusions have been extended for the first (Dec 2018 - Dec 2019) and second (March 2019 - March 2020) sets of exclusions released. The third set of exclusions is set to expire April 18, 2020. USTR accepted public comment between February 16 and March 16 on extending those exclusions for another year and is currently reviewing extensions.

The fourth set of exclusions is set to expire May 14, 2020. USTR is accepting public comment between March 12 and April 12 on extending those exclusions for another year.

The fifth set of exclusions is set to expire June 4, 2020. USTR is accepting public comment between April 1 and April 30 on extending those exclusions for another year.

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

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
Public comment opens on extending the December 2018 exclusions November 1, 2019
Public comment closes on extending the December 2018 exclusions November 30, 2019
Public comment opens on extending the March 2019 exclusions January 15, 2020
Public comment closes on extending the March 2019 exclusions February 15, 2020
Public comment opens on extending the April 2019 exclusions February 16, 2020
Public comment closes on extending the April 2019 exclusions March 16, 2020
Public comment opens on extending the May 2019 exclusions March 12, 2020
Public comment closes on extending the May 2019 exclusions April 12, 2020
Public comment opens on extending the June 2019 exclusions April 1, 2020
Public comment closes on extending the June 2019 exclusions April 30, 2020
Public comment may close on reducing duty on additional medical-care products needed to address the COVID-19 outbreak. June 25, 2020
(may be extended)



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

Public comment may close on reducing duty on additional medical-care products needed to address the COVID-19 outbreak.

June 25, 2020
(may be extended)



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



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

Web portal for submitting exclusions opens

October 31, 2019

15% additional duty effective on List 4B products

Note duty was originally 10% 

Will not go into effect

(previously December 15, 2019)

Deadline to request exclusions for List 4A

January 31, 2020

Additional duty on List 4A products reduced to 7.5%

February 14, 2020

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. On December 2, 2019, USTR completed the first segment of its investigation and produced a report concluding that France's Digital Services Tax is unreasonable, discriminatory, and burdens U.S. commerce.

USTR is proposing additional duties of up to 100 percent on certain French products, and the option of imposing fees or restrictions on French services. It is unclear when these measures may take effect. They have issued a Federal Register notice soliciting comments on the proposed action. The products subject to potential duties are listed in the Annex to the Federal Register notice and on the below product list.

Press reports in January 2020 are citing French officials as saying the U.S. has agreed to postpone these tariffs until at least the end of the year. However, as of February 18, 2020, there has been no official confirmation from the White House. 

Product List

Please note we are unable to provide this list in Excel.

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

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
Deadline for requests to appear at the public hearing and a summary of testimony December 30, 2019
Due date for written comments January 6, 2020
Public hearing re: Section 301 action January 7, 2020
Due date for submission of post-hearing rebuttal comments January 14, 2020
Additional duty effective on tariffed products TBD


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. 

New! According to a January 24, 2020 Presidential Proclamation, the tariffs imposed on steel and aluminum will now also apply to the derivatives of aluminum articles and steel articles described in Annex I and Annex II. The additional tariff will be effective February 8, 2020. It will apply to aluminum derivatives from all countries except Argentina, Australia, Canada, and Mexico and steel derivatives from all countries except Argentina, Australia, Brazil, Canada, Mexico and South Korea. The following products are covered by this proclamation.

Countries and/or companies negatively impacted by these additional tariffs can petition for an exclusion. For assistance in this effort, please contact Kristen Smith at (202) 730-4965. 

Latest News

Exclusion Request Forms

Official Documents

Section 232 Investigation of Automobiles & Auto Parts

There are currently no tariffs on automobiles or auto parts, and no plans to implement them.

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 would delay a decision for 180 days, making the new deadline November 13, 2019. The Trump Administration missed the November deadline.  

The US has been holding talks with the European Union, Japan, and possibly others that will likely seek to reduce imports from those countries. According to the May 17 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

Section 232 Investigation of Titanium Sponge

New! President Trump will not impose tariffs or quotas on titanium sponge imports.

The Department of Commerce announced March 4, 2019 its initiation of an investigation under section 232 of the Trade Expansion Act of 1962 into whether the quantity or circumstances of titanium sponge imports into the U.S. threaten to impair national security. This investigation was launched in response to a petition filed by domestic producer Titanium Metals Corporation. In November 2019, the department determined that imports of titanium sponge are threatening to impair national security. 

However, a February 27, 2020 presidential memorandum states that actions to adjust imports will not be taken at this time. Instead, a working group will be formed to agree upon measures to ensure US access to titanium sponge for use for national defense or in the event of an emergency. Additionally, the Secretary of Defense will take appropriate action to increase access to titanium sponge and support domestic production capacity of same. 

Latest News

Official documents

Tariffs on the EU - Aircraft Dispute 

On October 2, 2019, the U.S. announced that it will impose additional tariffs of 25 percent on more than 150 products imported from European Union countries, as well as an additional 10 percent tariff on new aircraft from France, Germany, Spain and the United Kingdom, effective October 18, 2019.

New! In February 2020, the U.S. modified the tariffs. Additional products were added to the tariffed list, effective March 5, 2020. Also, the tariff on new aircraft from France, Germany, Spain and the United Kingdom was increased to 15 percent beginning March 18, 2020. The final list of products affected can be found here.

The additional tariffs come after a World Trade Organization arbitrator determined that the U.S. may impose up to $7.5 billion annually in countermeasures against the EU due to its failure to fully comply with a previous WTO ruling against subsidies it provided to aircraft manufacturer Airbus.

Importers with goods on this list should consider taking proactive measures to mitigate the impact of the tariff increase. 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 Lists

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
WTO rules that U.S. can impose an up to $7.5 billion in annual countermeasures October 2, 2019
Additional tariffs go into effect October 18, 2019
Due date for submissions of comments on increasing duty rates and expanding list of tariffed goods. January 13, 2020
Changes to the products subject to additional 25% duties take effect March 5, 2020
Tariff on specified aircraft increase to an additional 15% March 18, 2020

Tariffs on Mexico (indefinitely suspended)

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

On 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 June 7, 2019,  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.

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

On December 19, 2019, China released another list of products to be excluded from 301 tariffs. These exclusions will start on December 26, 2019 and be effective for one year.  Contact us for more information about China's exclusion process.

As part of the Phase 1 deal in December 2019, China agreed to remove retaliatory tariffs of duties on the list released August 3, 2018 and on auto parts spread over several lists. The suspension of those duties took effect December 15, 2019.

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.

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

Latest News

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 official notices.

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

Duties on autos and auto parts on this list suspended as of December 15, 2019 as part of Phase 1 deal

Exclusion requests accepted June 3, 2019 - July 5, 2019

China


301 Retaliation List Two, Version 2
Originally Released June 16, 2019.
Amended August 8, 2018

August 23, 2018

Duties on autos and auto parts on this list suspended as of December 15, 2019 as part of Phase 1 deal

Exclusion requests accepted June 3, 2019 - July 5, 2019

China

301 Retaliation List 3.1


301 Retaliation List 3.2


301 Retaliation List 3.3


301 Retaliation List 3.4


Released August 3, 2018
Finalized Sept. 17, 2018
Amended May 13, 2019

September 24, 2018

February 14, 2020 tariffs halved

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

China

301 Retaliation List In Response to US List 4A

301 Retaliation List In Response to List 4B

Released August 23, 2019

Duties on autos and auto parts on these lists suspended as of December 15, 2019 as part of Phase 1 deal

September 1, 2019

December 15, 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