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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