Trade Compliance

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USTR Considering Another Extension of Tariff Exclusions

Posted February 10, 2020


The Office of the U.S. Trade Representative recently announced that it is considering a one-year extension of exclusions from the administration’s Section 301 (List 1) tariffs.

What is List 1?


List 1 refers to the $34 billion trade action taken June 20, 2018 against Chinese imports; specifically, more than 800 tariff items subject to a 25% punitive duty. The Section 301 tariff exclusions being considered by the USTR for extension are only those which it previously granted to certain products on April 18, 2019.

Comments (i.e., requests for extensions) may be submitted to the USTR between February 16 and March 16, 2020.

Qualifying for Exclusions


The USTR has indicated that its evaluation of exclusions will be made on a case-by-case basis.

The focus of the evaluation will be “whether, despite the first imposition of these additional duties in July 2018, the particular product remains available only from China.” With this in mind, the following should be addressed in submitting any comments:

  • Whether the particular product and/or a comparable product is available from sources in the United States and/or in third countries.
  • Any changes in the global supply chain since July 2018 as to the particular product, or any other relevant industry developments.
  • The efforts, if any, the importers or U.S. purchasers have undertaken since July 2018 to source the product from the United States or third countries.

The USTR notes that it will continue to consider whether the imposition of additional duties on the products covered by the exclusion will result in severe economic harm to the commenter or other U.S. interests.

Need More Information?


If you have any questions regarding submitting comments on extending Section 301 exclusions or need assistance completing the Exclusion Extension Comment Form A, GHY can help!

Contact one of our trade experts today to discuss this or other issues affecting your bottom line.

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