The U.S. Trade Representative announced reinstated product exclusions from Section 301 tariffs on Chinese goods, valid for entries liquidated from October 12, 2021 and continuing through December 31, 2022. The reinstated exclusions are available for any product that meets the description set out in the applicable HTSUS subheadings and product descriptions in the Annex to the Federal Register notice. The notice was published March 28, 2022 and is available here — see pages 3 through 26 for the full product list.
What “Reinstated” Exclusions Mean
These are not new exclusions — they are exclusions that previously expired and have been brought back retroactively. The retroactive effective date of October 12, 2021 means that importers who paid Section 301 duties on covered entries between that date and the date they became aware of the reinstatement may be entitled to refunds. Those refunds do not happen automatically. An importer has to identify the affected entries, confirm the products fall within the applicable exclusion descriptions, and file a protest to recover the overpaid duties.
The 180-day protest deadline runs from the date of liquidation of each entry — not from the date USTR announced the reinstatement. That means the window to recover duties on older entries is already closing, and importers who have been sitting on this need to act.
How This Fits Into the Broader Section 301 Picture
This March 2022 reinstatement was one step in a multi-year exclusion extension process tied to USTR’s mandatory four-year review of the Section 301 actions. That review has since concluded, and the exclusion landscape has changed significantly. Of the 352 exclusions that were reinstated and extended through late 2022, only 178 survived the four-year review process — 164 product-specific exclusions and 14 solar manufacturing equipment exclusions. Those 178 are currently extended through November 10, 2026 as part of the U.S.-China trade agreement reached in November 2025.
The prediction in this post — that USTR would open new exclusion request opportunities ahead of the 2022 midterms — did not materialize in that form. USTR did open a new exclusion process as part of the four-year review in 2024, but it was narrower than a full reopening and focused on manufacturing equipment and specific product categories. No broad new exclusion request process is currently open. See our Section 301 exclusions page for the complete current status.
The IEEPA Refund Opportunity
Beyond Section 301 exclusion refunds, the February 20, 2026 Supreme Court ruling striking down IEEPA-based tariffs has created a separate and significant refund opportunity for importers who paid reciprocal tariffs between April 2025 and the ruling date. The Court of International Trade is working through the mechanics of the refund process. Importers should be identifying and documenting their IEEPA entries now, as the window for filing protests on those entries will be governed by the standard 180-day liquidation deadline. This is a time-sensitive issue that warrants immediate attention for any importer who was paying the IEEPA reciprocal tariffs.
We File Protests for Section 301 and IEEPA Duty Refunds
Great Lakes Customs Law has filed protests across thousands of entries for Section 301 duty refunds and has been successful in recovering overpaid duties for importers through the protest process. If you have entries that may be covered by reinstated or active exclusions, or if you paid IEEPA reciprocal tariffs that may now be refundable, we can evaluate your situation, identify the affected entries, calculate the potential refund amounts, and handle the protest filings. We provide transparent pricing for protest services and are happy to discuss scope and logistics before any engagement.
Call us at (734) 855-4999, send a text message, or reach us on WhatsApp. You can also contact us online to speak with Jason Wapiennik directly.