Trade Update re: Extension of Section 301 China Product Exclusions
On August 29, 2025, the U.S. Trade Representative (“USTR”) further extended 164 product-specific exclusions and 14 exclusions for certain solar manufacturing equipment from Section 301 duties for three months through November 29, 2025. CBP issued its guidance (CSMS #66077997) providing entry information for exclusions granted by USTR.
Products covered by these extended exclusions are under two different subheadings of the Harmonized Tariff Schedule of the United States (“HTSUS”):
- Annex A lists exclusions under subheading 9903.88.69 and U.S. notes 20(vvv)(i)-(iv) to subchapter II of chapter 99 of the HTSUS. This list includes the 164 products extended in previous rounds and encompasses a wide range of products, including industrial components, machine parts, and electrical equipment.
- Annex B covers exclusions under subheading 9903.88.70 and U.S. note 20(www) to subchapter III of chapter 99 of the HTSUS. This list covers 14 product exclusions for solar manufacturing equipment, including wafer slicers and processing equipment.
For products covered by this extension, eligible Chinese-origin goods will continue to be exempt from additional Section 301 duties through November 29, 2025. USTR will continue to accept public comments and may extend or modify these exclusions in the future.
On September 16, 2025, the USTR issued a notice of a new public comment period on whether any of the 178 effective exclusions warrant further extension beyond November 29, 2025. Interested parties are encouraged to submit comments on whether particular exclusions warrant further extension by October 16, 2025.
If you are an importer that is the beneficiary of one of the 178 effective exclusions and wish to post comments supporting the extension of these exclusions, our firm is ready to assist.
Please stay tuned for future updates.
