The Office of the U.S. Trade Representative has released a 4th list of approximately $300 billion worth of Chinese goods for which additional Section 301 tariffs will be imposed. The USTR announced that the tariffs could reach as high as 25% and will cover essentially all products not currently covered by the first 3 lists of tariffs. The tariff hike could be implemented any time after June 24 and will be applied in addition to any existing customs duties and antidumping and countervailing duties.
The extensive list of 3,805 full and partial HTSUS subheadings, which can be seen here, includes apparel, footwear, manufactured textile products, appliances, electronics, tools, household goods, jewelry, personal hygiene products, and recreational equipment. The list excludes pharmaceuticals, certain pharmaceutical inputs, select medical goods, critical minerals, and rare earth materials.
Numerous HTS subheadings that were removed during the comment and hearing process for List 1 ($34 billion), List 2 ($16 billion) and List 3 ($200 billion) are included in List 4. Goods that were previously excluded during the formal exclusion process for List 1 and List 2 will not be affected; however, we recommend you review the list to ensure that the product was not inadvertently included on List 4.
The USTR will hold a notice and comment period for the Section 301 List 4 goods, with the following key dates:
| June 10 | Due date for filing requests to appear at the public hearing along with a summary of expected testimony
|
| June 17 | Due date for submission of written comments, including requests to exclude specific subheadings from the proposed tariff increase as well as input on the specific tariff levels that should be imposed
|
| June 17 | The USTR will hold a public hearing at 9:30 at the U.S. International Trade Commission, 500 E Street SW, Washington, DC |
China Fires Back
On Monday, China announced it will impose retaliatory tariffs on $60 billion worth of U.S. goods starting on June 1. The additional tariffs will be applied to the four separate lists of American goods already in place as follows:
| Tariff Line | Tariff Rate |
| 595 | The tariff will remain at 5% |
| 974 | The tariff will increase from 5% to 10% |
| 1,078 | The tariff will increase from 10% to 20% |
| 2,493 | The tariff will increase from 10% to 25% |
China also announced that it will accept requests for tariff exclusions. Each request will be limited to one product at the 8-digit tariff level and will be evaluated based upon the difficulty of obtaining the product from non-U.S. sources, material injury the requester would endure due to the tariff, or any structural impact faced by relevant industries.
