Extensive Section 301 China Modifications for U.S. Importers

On September 13, 2024, the U.S. Trade Representative modified the Section 301 China tariffs. The core additional tariffs importers have been experiencing will remain the same. However, certain strategic sector products will face tariff increases. Solar manufacturing equipment and specific ship-to-shore cranes will be eligible for temporary exclusions. The announcement also made note of a modified list of machines used for domestic manufacturing that would be eligible for consideration of temporary exclusion.  

Importers should review the published Annex A for tariff increases, noting the implementation ‘Timing’ year, Annex B for solar manufacturing equipment, D for info on ship-to-shore cranes, and E for machines eligible for exclusion consideration, in the Federal Register notice.

Summary of Changes

• Tariff increases for 382 ‘strategic sector’ subheadings and seven statistical reporting numbers, effective dates range from September 27, 2024, to January 1, 2026.
  • Battery Parts
  • Electric Vehicles
  • Facemasks
  • Lithium-ion Electrical Vehicle Batteries
  • Lithium-ion Non-electrical Vehicle Batteries
  • Medical Gloves
  • Natural Graphite
  • Other Critical Minerals
  • Permanent Magnets
  • Semiconductors
  • Ship-to-Shore Cranes
  • Solar Cells
  • Steel and Aluminum Products
  • Syringes and Needles

• 14 temporary exclusions for solar manufacturing equipment, retroactive to January 1, 2024 – May 31, 2025 (Annex B)

• Ship-to-shore cranes exclusion and Importer Certification (Annex D)
• HTSUS subheadings that are eligible for consideration of temporary exclusion under the machinery exclusion process [TBA] (Annex E)

Timing Year (Annex A)

• 2024 – Enters into effect on September 27, 2024

• 2025 – Enters into effect on January 1, 2025

• 2026 – Enters into effect on January 1, 2026