USTR Releases Additional Product Exclusions, Request Comment on Certain List 4A Products

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The Office of the United States Trade Representative (USTR) released an additional set of product exclusions for Section 301 List 4A products from China.

This set of tariff exclusions contains 1 HTS subheading completely excluded and 9 HTS subheadings partially excluded from the 7.5% tariffs, covering 25 separate exclusion requests.

Exclusions are available for any product that meets the description in the Annex, regardless of whether the importer filed an exclusion request, and will retroactively apply to all List 4A products meeting the specified criteria effective September 1, 2019 through September 1, 2020.

USTR simultaneously announced they are seeking public comment regarding the extension of exclusions granted on the above List 4A products. As mentioned, the above set of product exclusions is set to expire on September 1, 2020.

Comments can be submitted through an online portal ( between August 5 – 20, 2020.

Commenters should address the following:

  • 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 with respect 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.

In addition, USTR will consider whether the imposition of additional duties will result in severe economic harm to the commenter or other U.S. interests.

The full notice announcing new List 4A product exclusions can be found here.

The full notice requesting public comment on the recently excluded List 4A products can be found here.

Trans-Border will continue to monitor the situation. If you have any questions, please reach out to Bill Carey, Import Compliance Manager, at or (800) 493-9444.

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