China announced April 4 the following retaliatory measures in response to an additional 34 percent “reciprocal” tariff imposed by the U.S. on imports from China.
Tariffs
Effective at 12:01 a.m. on April 10, all goods from the U.S. will be subject to an additional 34 percent tariff except those that depart from the port of loading before that time and are imported between April 10 and May 13. Current policies on bonded goods and duty deductions and exemptions will remain the same, but the 34 percent tariff will not be subject to any duty deductions or exemptions.
Export Controls
Effective April 4, China imposed new restrictions on exports of the following rare earth elements used in the semiconductor, defense, and manufacturing industries: samarium, gadolinium, terbium, dysprosium, lutetium, scandium, and yttrium, as well as their compounds and alloys. Many of these exports currently go to the U.S. and the restrictions could therefore present difficulties for U.S. companies that rely on importing them from China.
Since December 2004 China has prohibited exports of dual-use items to U.S. military end-users or end-uses, imposed a general ban on exports to the U.S. of dual-use items related to certain minerals, and followed a stricter policy of end-use and end-user review for exports of dual-use items of graphite to the U.S.
Import Bans
Effective April 4, China’s General Administration of Customs is prohibiting imports of poultry from two U.S. exporters, poultry bone meal from three U.S. exporters, and sorghum from one U.S. exporter.
Unreliable Entity List
Effective April 4, China added 11 U.S. entities to its unreliable entity list. Entities on this list are prohibited from engaging in import and export activities related to China as well as making new investments in China.
Dual-Use Export Control List
Effective April 4, China’s Ministry of Commerce added 16 U.S. entities to its dual-use export control list. As a result, exports of dual-use items to these entities are prohibited and all relevant export activities currently being carried out must be halted immediately. If such exports are necessary under special circumstances the exporter must apply for a dual-use export license from MOFCOM.
Antidumping Investigation
On April 4, MOFCOM initiated an antidumping investigation of certain X-ray tube assemblies and tubes thereof for medical CT devices from the U.S. Subject goods are classified under HS 9022.30.00 in China. U.S. stakeholders have 20 days to register with MOFCOM to participate in this investigation or submit comments.
Recommendations
To mitigate these risks, ST&R’s Asia-based trade professionals can help companies:
- monitor regulatory updates;
- understand Chinese regulations and Chinese authorities’ enforcement priorities;
- apply for dual-use export control licenses;
- conduct internal risk assessments;
- respond to audits by Chinese authorities, including China Customs, Tax Bureau, and MOFCOM;
- negotiate with authorities on case settlements; and
- restructure supply chains.
Copyright © 2025 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.