On October 24, 2019, the Office of the United States Trade Representative (“USTR”) granted exclusions for 83 specific HTS numbers which are currently subject to 25 percent Section 301 tariffs under List 3. The product exclusions apply retroactively effective September 24, 2018 until August 7, 2020. To see a full list of the excluded products, click here.  The announcement relating to the List 3 exclusions comes surprisingly soon after the closure of the exclusion deadline for List 3 on September 30, 2019.  Typically, the exclusion processes have been taking 6 months or more for List 1 and List 2.

Starting September 24, 2018, the U.S. imposed additional 10 percent duties on goods from China with an annual trade value of approximately $200 billion as part of the action in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation.  These duties were increased to 25 percent on May 10, 2019.  Any goods on List 3 which are not specifically excluded are still subject to these additional 25% tariffs, until further notice.

This new set of product exclusions comes just days after the USTR issued a statement on the starting date for the Section 301 List 4 Exclusion process, scheduled to open on October 31, 2019 and ending on January 31, 2020.

For more information concerning these new product exclusions and how they may affect your business, please contact Husch Blackwell’s International Trade and Supply Chain team.