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China 301 Duty: Update and Exclusion Information

As many of our readers are aware, the U.S. levied additional tariffs on goods made in China. These tariffs have come in waves that began on July 6th, 2018.

The next group, known as List 4b, was scheduled to  become effective on Sunday December 15th at a rate of 15 percent, but has now been suspended as a result of the U.S. and China agreeing to “Phase 1” of a trade deal.

As part of this deal, the tariffs that took effect on September 1st (List 4a) will be reduced from 15 percent to 7.5 percent while the next phase of the trade deal is negotiated.  The date of implementation for the reduction has not been released, however Phase 1 is expected to be signed by the first week of January.  At that time, the date of the rollback should be clear. If you would like to read more about Phase 1 of the deal, an FAQ can be found here.

List 1, List 2, and List 3 will remain at 25 percent pending negotiations on a possible “Phase 2” of the deal.  There are no additional lists or increases in rate for the current lists, scheduled for release at this time.

It is important to note that certain goods are eligible for exclusions from the Section 301 tariffs based on the description and classification.  These exclusions can be applied to both past and future shipments.

China 301 List 1 is currently assessed at a rate of 25 percent.  To date, eight rounds of exclusions have been granted on 12/18, 3/19, 4/19, 5/19, 6/3, 7/8, 9/20, and 10/2.

List 2 is currently assessed at a rate of 25 percent. Three rounds of exclusions have been granted on 7/31, 9/20, and 10/2.

List 3 is currently assessed at a rate of 25 percent. Six rounds of exclusions have been granted on 8/7 , 9/20 , 10/24 , 11/13, 11/29 and 12/17.

List 4a became effective on 9/1/2019 and is currently assessed at a rate of 15 percent. As previously covered, that rate should reduce to 7.5 percent in the new year.  The Office of the U.S. Trade Representative (USTR) announced requests for exclusions from duties for the commodities can be submit until January 31st, 2020.

If your company is impacted by the Section 301 China tariffs, it is worth the time to review the exclusions that have been granted to date.  Exclusions are based on description and classification and are not limited to specific importers.

If your company has goods that are eligible for an exclusion, please contact the U.S. Regulatory Team at for information regarding duty recovery and preparing for future shipments of the products.