Update 12/1/25 — Exclusions have been extended through November 9, 2026.
Update 8/29/25 — Exclusions have been extended through November 29, 2025.
The Office of the United States Trade Representative (USTR) announced the extension of exclusions in the Section 301 Investigation of China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation. This is the original tariff action against China from Trump’s first term in office — the tariffs initially imposed in 2018 and 2019 under the Trade Act of 1974 that covered four tranches of goods and raised duties on hundreds of billions of dollars’ worth of Chinese imports.
The exclusions were previously scheduled to expire on May 31, 2025 and have been extended through August 31, 2025. The Federal Register notice can be viewed here. There is no opportunity to request new exclusions under this process.
What These Exclusions Cover
The extension covers 178 product exclusions — 164 product-specific exclusions and 14 exclusions for solar manufacturing equipment. The 164 product exclusions were originally reinstated and extended in May 2024 through May 31, 2025. The 14 solar manufacturing equipment exclusions were granted in September 2024 and were also set to expire May 31, 2025. Both sets are now running on the same extension track.
The excluded products span a range of industrial and technology categories, including intermediate components, semiconductor parts, telecommunications machinery, aerospace components, hardware, medical device components, and solar manufacturing equipment such as wafer slicers, cell interconnection machinery, module laminators, and balance-of-system production equipment. These are products where importers have argued — and USTR has accepted — that sourcing from outside China remains difficult or unavailable in sufficient quantities.
Importers claiming these exclusions must report HTSUS codes 9903.88.69 or 9903.88.70 on their entry summaries, as applicable. Product eligibility is determined strictly by the detailed product descriptions and HTSUS subheadings in the applicable U.S. notes — general category descriptions are not sufficient. If you are unsure whether your product qualifies, the classification needs to be verified against the specific note language.
The Pattern of Short Extensions
These exclusions have been running on a pattern of short-term, rolling extensions for several years. USTR extended 164 of them in May 2024 through May 2025, then again through August 2025, then through November 2025, and most recently through November 2026. Each extension has required a public comment process, interagency review, and a weighing of whether continued relief is consistent with the administration’s trade policy objectives toward China.
The November 2025 extension to November 2026 followed a public comment period in which 147 of the 178 exclusions received comments supporting further extension, with commenters arguing that products remain available only in limited quantities outside China and that more time is needed to shift sourcing. Ten exclusions also received opposition comments arguing that alternatives outside China are available. USTR considered all of this alongside the November 2025 U.S.-China trade deal announcement in making the extension decision.
The practical takeaway for importers: these exclusions remain in force through November 9, 2026, but given their history, a further extension decision will need to be made before that date. Importers relying on these exclusions for products where China remains the only viable source should monitor USTR’s comment process and consider participating when the next evaluation period opens. For a broader look at the Section 301 tariff landscape, see our Section 301 Tariff Exclusions page.