The USTR is conducting its mandatory four-year review of the Section 301 tariff actions against China — the tariffs that have been in place since 2018 on goods across hundreds of HTS subheadings at rates of 7.5% and 25%. The review is required by statute, and the first step is giving domestic industries that benefit from the tariffs the opportunity to request that they continue. If you want the tariffs to stay in place, now is the time to say so.
Here is what USTR published in the Federal Register:
The first step in the four-year review process is notifying representatives of domestic industries which benefit from the trade actions, as modified, of the possible termination of the actions, and of the opportunity for these representatives to request continuation of the actions. Requests for continuation must be received in the 60-day window prior to the four-year anniversary of the respective action: Between May 7, 2022, and July 5, 2022, for the July 6, 2018 action, and between June 24, 2022, and August 22, 2022, for the August 23, 2018, action. If the actions continue as a result of one or more requests from representatives of domestic industries which benefit from the trade actions, USTR will proceed with the next phase of the review. The second phase of the review will be announced in one or more subsequent notices, and will provide opportunities for public comments from all interested parties.
The full notice with submission guidelines is available from the Federal Register.
What the Four-Year Review Actually Is
Section 307 of the Trade Act of 1974 requires USTR to review Section 301 actions at four-year intervals and to terminate them unless domestic industries request continuation. The review is not discretionary — it is built into the statute. The four-year clock runs from the date each action was originally imposed, which is why there are two separate comment windows: one for the July 6, 2018 action (List 1, covering $34 billion in goods) and one for the August 23, 2018 action (List 2, covering $16 billion in goods). Later lists — List 3 and List 4 — will reach their four-year anniversaries on their own separate schedules.
The review is structured in two phases. In the first phase, only domestic industries that benefit from the tariffs can participate — they are the ones who can request continuation. If at least one domestic industry requests continuation, USTR moves to the second phase, which opens the process to all interested parties including importers, foreign manufacturers, and others who have been affected by the tariffs. The second-phase comment opportunity — for those who want to argue the tariffs should be modified or terminated — has not yet been announced as of this writing.
How the Review Actually Played Out
This post was written in May 2022 when the review was just getting underway. Here is what happened. Domestic industries did request continuation, USTR proceeded to the second phase, and in September 2022 USTR announced it would continue the Section 301 actions. The review then led to a broader modification process that culminated in May 2024, when USTR finalized significant rate increases on a range of products — electric vehicles, EV batteries, solar cells, ship-to-shore cranes, steel and aluminum products, semiconductors, syringes and needles, and critical minerals — with rates ranging from 25% to 100% and phased increases scheduled through 2025 and 2026.
The four-year review also produced a new exclusion process. 164 product-specific exclusions and 14 solar manufacturing equipment exclusions survived the review and have been extended multiple times, currently through November 10, 2026 as part of the U.S.-China trade agreement reached in November 2025. No new exclusion request process is currently open. See our Section 301 exclusions page for the full current status.
What This Means for Importers Today
The four-year review process confirmed what most importers already suspected: Section 301 tariffs on Chinese goods are not going away. The review that was supposed to provide a mechanism for terminating the tariffs instead produced higher rates on more products. The February 2026 Supreme Court ruling striking down IEEPA-based tariffs does not affect Section 301 — those tariffs remain fully in force and the administration has signaled it intends to expand their use beyond China through new investigations targeting additional countries.
For importers carrying Chinese-origin goods, the strategic questions are now longer-term ones: whether sourcing shifts are viable, whether classification reviews could reduce exposure, whether any of the 178 active exclusions apply to your products, and whether entries from prior periods may be eligible for duty refunds through protest. Great Lakes Customs Law has filed protests across thousands of entries for Section 301 duty refunds and can evaluate whether your entries qualify.
Questions About Section 301 Tariffs?
Whether you have questions about current Section 301 rates, active exclusions, protest filings, or how the tariffs interact with Section 232 and the post-IEEPA tariff landscape, we are happy to discuss. Call us at (734) 855-4999, send a text message, or reach us on WhatsApp. You can also contact us online.