Section 301 Tariffs on China
The information provided below is for guidance only and not to be considered legal advice. If you have any questions or require assistance, please contact your ST&R professional or via this email.
Information on other tariffs on China under the International Emergency Economic Powers Act can be found on our IEEPA Tariffs page or our Reciprocal Import Tariffs page.
Background on Section 301 China Tariffs
A Section 301 investigation in 2018 determined that China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation are unreasonable and discriminatory. As a result, in 2019 the U.S. imposed additional tariffs ranging from 7.5% to 25% on approximately $370 billion worth of imports from China across four lists (lists 1-4A).
A review of those tariffs after they had been in place for four years resulted in further tariff increases of up to 100% on certain products. The four-year review also provided for some exclusions from the tariffs for certain solar panel machinery and the possibility of an exclusion for some machinery classified in Chapters 84 and 85 of the Harmonized Tariff Schedule. Additional products are being considered for further tariff increases.
A second four-year review of these tariffs is underway as of May 2026.
- List 1: 25% additional tariff on $34 billion of imports, effective July 19, 2018
- List 2: 25% additional tariff on $16 billion of imports, effective August 23, 2018
- List 3: 25% additional tariff on $200 billion of imports (increased from 10%), effective May 10, 2019
- List 4A: 7.5% additional tariff on $120 billion of imports, effective February 14, 2020 (there is no additional tariff on goods on list 4B)
- Four-Year Review: additional tariffs ranging from 25% – 100% effective September 27, 2024, January 1, 2025, and January 1, 2026, variously.
Latest Actions
Comment Period for Continued Tariff Exclusions: June – July 2026
Importers have until July 10 to submit comments that could yield new or continued reductions in tariffs on imports from China.
The Office of the U.S. Trade Representative opened June 2 a comment period on which non-sensitive products should be eligible for reductions in non-MFN (e.g., Section 301 and Section 232) tariffs when traded between the U.S. and China. Importers already benefiting from any of the relatively few remaining exclusions from the longstanding Section 301 tariffs on imports from China should use this opportunity to seek to make those exclusions permanent.
In addition, importers who requested but have not received such an exclusion previously, and who still source from China or have been unable to find alternative sources, should use this opportunity to seek a permanent modification to the applicable non-MFN tariffs.
Second Four-Year Review: May 2026
In May 2026, USTR formally kicked off its second four-year review of the Section 301 tariffs that are currently in place on a broad range of products from China.
Any representative of a domestic industry that benefits from the Section 301 action taken on July 6, 2018, may submit a request to continue such action between May 7 and July 5, while any representative of a domestic industry that benefits from the Section 301 action taken on Aug. 23, 2018, may submit a request to continue such action between June 24 and Aug. 22. USTR states that any such requests should identify the specific industry concerned and how the domestic industry benefits from the Section 301 action.
USTR will announce in subsequent notices whether it has received a request for continuation of the July 6, 2018, action and/or the Aug. 23, 2018, action, as modified, from a domestic industry representative that benefits from the action. If any such requests are received, USTR will then announce the continuation of the action and will undertake a review as described in Section 307(c)(3) of the Trade Act. As part of any such review, USTR intends to invite through a separate portal interested parties to comment on the effectiveness of the action in achieving the objectives of Section 301, other actions that could be taken, and the effects of such actions on the U.S. economy, including consumers.
Official Documents
New Section 301 Investigation: October 2025
The Office of the U.S. Trade Representative announced October 28, 2025 its initiation of a Section 301 investigation of China’s implementation of the Phase I trade agreement it reached with the U.S. in December 2019. Read more details in the ST&R Trade Report.
USTR will hold a hearing in connection with this investigation on Dec. 16. Written comments and requests to appear at the hearing may be submitted starting Oct. 31 and are due no later than Dec. 1.
Official Documents
Exclusion Extensions: May, August & November 2025
On November 26, 2025, USTR further extended certain exclusions from the China Section 301 tariffs through November 10, 2026. USTR has previously extended these exclusions several times.
Products that will continue to be excluded from the tariffs under this action include (1) those listed in Annex C to this notice and (2) the solar manufacturing equipment listed in Annex B to this notice. These exclusions are available for any product that meets the specified HTSUS numbers and product descriptions, regardless of whether the importer filed an exclusion request.
Four-Year Review: September 2024
On May 14, 2024, USTR released its mandatory four-year review of these tariffs. This led to increased tariffs on goods entered or withdrawn from warehouse for consumption on or after September 27, 2024. Read more in Trade Report and listen in our TMIT podcast.
In December 2024, USTR announced additional Section 301 tariff increases on certain tungsten products, solar wafers, and polysilicon. See more details here.
Exclusion Extensions & New Exclusions: May – September 2024
Previous Exclusions: On May 30, 2024, USTR issued a Federal Register notice extending 429 product-specific exclusions through June 14, 2024. However, USTR only continued the exclusions for 164 of those products beyond that date and through May 31, 2025.
On August 6, 2024, USTR issued a Federal Register notice amending the HTSUS of two extended exclusions due to changes to HTSUS statistical reporting categories.
- Click here for an ST&R Trade Report article with more details
- Click here for access to an ST&R spreadsheet listing the extended and expiring exclusions.
New Exclusion Process: On May 31, 2024, USTR issued a Federal Register notice setting out the proposed information it will seek in a new exclusion process for machinery classified in HTS Chapters 84 and 85 that is imported from China for manufacturing in the U.S. On August 15, 2024, USTR issued an updated Federal Register notice about this information. Comments were due September 16, 2024.
On September 13, 2024, USTR announced it expected to soon publish procedures by which interested parties may request that this machinery be temporarily excluded from the Section 301 tariffs.
Solar Manufacturing Equipment Exclusions: On September 13, 2024, USTR announced it had granted 14 tariff exclusions for specific solar manufacturing equipment, effective from Jan. 1, 2024, through May 31, 2025. Five proposed exclusions for solar manufacturing equipment for modules were omitted.
Additional Resources
- ST&R spreadsheets listing all tariffed and excluded items are no longer available. Visit USITC’s tariff page for an HTS search and tariff database.
- Read all ST&R Trade Report articles about the China Section 301 tariffs here.
- Listen to all Two Minutes in Trade podcast episodes about the China Section 301 tariffs here.
- Archive of official documents
ST&R has extensive experience assisting companies with seeking exclusions as well as mitigating the impact of the Section 301 tariffs through tariff classification, tariff engineering, first sale, and other methods. Contact us for assistance.