The Office of the U.S. Trade Representative announced Sept. 13 final action to increase Section 301 tariffs on imports from China and allow certain tariff exclusions. Unless indicated otherwise in the list below, these increases will be effective for goods entered or withdrawn from warehouse for consumption on or after Sept. 27.
According to USTR, the tariff increases proposed in May were largely adopted, with some modifications. These increases will cover 382 HTSUS subheadings and seven statistical reporting numbers under the following 14 product groups (see Annex A in the USTR notice for full details).
- battery parts (non-lithium-ion batteries) – from 7.5 percent to 25 percent
- electric vehicles – from 25 percent to 100 percent
- face masks/respirators – from 0-7.5 percent to 25 percent as of Sept. 27 and 50 percent as of Jan. 1, 2026
- lithium-ion electrical vehicle batteries – from 7.5 percent to 25 percent
- lithium-ion non-electrical vehicle batteries – from 7.5 percent to 25 percent on Jan. 1, 2026
- medical gloves – from 7.5 percent to 50 percent as of Jan. 1, 2025, and 100 percent as of Jan. 1, 2026
- natural graphite – from 0 to 25 percent on Jan. 1, 2026
- other critical minerals – from 0 to 25 percent
- permanent magnets – from 0 to 25 percent on Jan. 1, 2026
- semiconductors – from 25 percent to 50 percent on Jan. 1, 2025
- ship-to-shore cranes – from 0 to 25 percent
- solar cells (whether or not assembled into modules) – from 25 percent to 50 percent
- steel and aluminum products – from 0-7.5 percent to 25 percent
- syringes and needles – from 0 to 100 percent
USTR expects to publish soon procedures by which interested parties may request that specific machinery used in domestic manufacturing and classified under 312 subheadings within Chapters 84 and 85 be temporarily excluded from the Section 301 tariffs.
Further, USTR has granted 14 tariff exclusions for specific solar manufacturing equipment, effective from Jan. 1, 2024, through May 31, 2025 (see Annex B). Five proposed exclusions for solar manufacturing equipment for modules have been omitted.
USTR states that the following changes have been made to its May proposal.
- new timing and tariff rates for face masks, medical gloves, and syringes and needles (see list above)
- an exclusion for enteral syringes through Jan. 1, 2026
- a proposal to increase tariffs on tungsten, wafers, and polysilicon (an official notice with comment period is expected soon)
- an exclusion for ship-to-shore cranes that were ordered prior to May 14, 2024, and are entered prior to May 14, 2026 (which must be accompanied by a new importer certification; see Annex D)
- an expansion of the scope of the machinery exclusions process to include five additional tariff lines (see Annex E)
Importers of goods subject to the tariff increases should contact ST&R to discuss options for avoiding or ameliorating these higher costs. ST&R can also help importers of machinery that may be eligible for new tariff exclusions to navigate that process. For more information on these or other topics related to the Section 301 tariffs, please contact your ST&R professional or via this email.
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