Background

In response to the additional ten percent tariff the U.S. imposed on virtually all goods imported from China as of Feb. 4, China has announced the retaliatory measures outlined below.

For more information on these measures and how they may affect your business, please contact Xiaofeng Xu via email.

Tariffs

Effective Feb. 10 China plans to impose the following tariffs on certain goods imported from the U.S. that will be in addition to normal tariff rates.

- 15 percent on coal and liquefied natural gas

- 10 percent on crude oil, agricultural machinery, automobiles (>2,500cc), and pickup trucks

More tariffs may be imposed if the U.S. increases its ten percent tariff to a higher rate.

Unreliable Entity List

Effective Feb. 4 China added two U.S. entities in the apparel and biotech industries to its unreliable entity list. This is the first time China has added non-military companies to this 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. In addition, management of these entities are prohibited from entering China, new visa applications will not be approved, and existing visas will be canceled.

Export Controls

Effective Feb. 4 China has imposed new restrictions on exports of the following critical materials and technology used in the semiconductor, defense, and manufacturing industries. 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 covered items from China.

Product/Technology description

Sample China HS code

China ECCN

Certain tungsten materials

2841.80.1000, 2825.90.1200, 2825.90.1910, 2825.90.1920, 2849.90.2000

1C117.d

Certain solid tungsten

8101.94.0001, 8101.99.1001, 8101.99.9001, 7106.91.9001, 7106.92.9001

1C117.c

Certain tungsten nickel iron alloy and tungsten nickel copper alloy

8101.94.0001, 8101.99.1001, 8101.99.9001

1C004

Technology to produce the above tungsten materials

NA

1E004, 1E101.b

Tellurium metal

2804.50.0001

6C002.a

Certain tellurium compound single crystal or polycrystalline products

2842.90.2000, 3818.00.9021, 3842.90.9025, 2852.10.0010

6C002.b

Technology to produce the above tellurium materials

NA

6E002

Certain bismuth metal and its products

8106.10.1091, 8106.10.1092, 8106.10.1099, 8106.10.9090, 8106.90.1019, 8106.90.1029, 8106.90.1099, 8106.90.9090

6C001.a

Bismuth germanate

2841.90.0041

6C001.b

Triphenylbismuth

2931.90.0032

6C001.c

Tris(p-ethoxyphenyl)bismuth

2931.90.0032

6C001.d

Technology to produce the above bismuth materials

NA

6E001

Certain molybdenum powder

8102.10.0001

1C117.b

Technology to produce the above molybdenum materials

NA

1E101.b

Indium phosphide

2853.90.4051

3C004.a

Trimethylindium

2931.90.0032

3C004.b

Triethylindium

2931.90.0032

3C004.c

Technology to produce the above indium materials

NA

3E004

China previously imposed export controls on gallium, germanium, antimony, graphite, and superhard materials and tightened controls on exports of dual-use items to the U.S. in December 2024. This includes a prohibition on exports of dual-use items to U.S. military end-users or end-uses, a general ban on exports to the U.S. of dual-use items related to the minerals, and a stricter policy of end-use and end-user review for exports of dual-use items of graphite to the U.S.

Recommendations

The new Chinese measures pose increased risks for U.S. companies and investors in China, including higher duty costs for selling goods to China and risks of audits by Chinese authorities. 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;

- conduct internal risk assessments;

- respond to audits by Chinese authorities, including China Customs, Tax Bureau, and Ministry of Commerce;

- negotiate with authorities on case settlement; and

- restructure supply chains.

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