Starting Nov. 15, importers and others can plead their case for changes to the Section 301 tariffs on imports from China as part of a review being conducted by the Office of the U.S. Trade Representative.

The Section 301 tariffs would have expired this past summer but USTR announced in September that it had received numerous requests to continue them. USTR will next solicit, for a period beginning Nov. 15 and ending Jan. 17, 2023, comments on the following issues.

- the effectiveness of the tariffs in obtaining the elimination of, or counteracting, China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation

- other actions or modifications that would be more effective in achieving these objectives

- the effects of the tariffs on (1) the U.S. economy, including U.S. consumers, (2) domestic manufacturing, including in terms of capital investments, domestic capacity and production levels, industry concentrations, and profits, (3) U.S. technology, including in terms of U.S. technological leadership and development, (4) U.S. workers, including with respect to employment and wages, (5) U.S. small businesses, (6) U.S. supply chain resilience, and (7) the goals of U.S. critical supply chains outlined in Executive Order 14017 and in subsequent reports and findings

- whether the tariffs have resulted in higher additional duties on inputs used for manufacturing in the U.S. than the additional duties on particular downstream product(s) or finished good(s) incorporating those inputs

USTR has released a list of specific questions designed to elicit further information on these topics. Of note, USTR is seeking input on whether there are goods not currently subject to the tariffs that should be.

ST&R can assist in preparing and submitting comments to USTR. For more information please contact Ned Steiner at (202) 730-4970 or via email.

In the meantime, efforts to ameliorate the impact of the tariffs are continuing.

- ST&R is advocating for the renewal of all previously approved exclusions and the creation of a process allowing for new exclusion requests (for more information, please contact

- There are a number of proven and legitimate ways to effectively avoid the tariffs or limit their impact (click here for more information).

- Importers of List 3 and 4A goods from China can still preserve their rights to possible refunds of tariffs paid on such goods by joining an ongoing court case (for more information, or assistance filing a claim, please contact us at

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