Section 301: US launches second four-year review of China tariffs
The U.S. Trade Representative (USTR) has initiated the second statutory four-year review of two Section 301 trade actions against China, effective July 6, 2018, and August 23, 2018. These actions, which imposed additional duties on Chinese products in response to China's technology-transfer and intellectual-property practices, are now subject to renewal or termination. Domestic industries benefiting from the tariffs have 60 days to request continuation: May 7–July 5, 2026, for the first action, and June 24–August 22, 2026, for the second. If requests are received, USTR will proceed to phase two, which will open public comment on whether the actions should remain in place.
Photo: Leeloo The First / PexelsThe U.S. Trade Representative (USTR) announced on May 6, 2026, the commencement of the second four-year review of two Section 301 trade actions against China, both stemming from the investigation into China's acts, policies, and practices related to technology transfer, intellectual property, and innovation.
Background
The two actions became effective on July 6, 2018, and August 23, 2018, respectively. Over time, they have been modified through the imposition of additional duties on supplemental product lists, temporary removal of duties via product exclusions, and a first four-year review cycle. Section 301 of the Trade Act of 1974, as amended, requires periodic statutory reviews to determine whether the underlying trade actions should continue.
Timeline for Industry Requests
The USTR is now notifying representatives of domestic industries that benefit from these tariffs of the review and the opportunity to request continuation. The critical 60-day windows for submission are:
- May 7, 2026 to July 5, 2026 — for the July 6, 2018 action
- June 24, 2026 to August 22, 2026 — for the August 23, 2018 action
As the USTR stated in the notice:
The first step in the four-year review process is notifying representatives of domestic industries which benefit from the actions of the possible termination of the actions and of the opportunity for these representatives to request continuation of the actions.
Next Steps
If one or more requests for continuation are received from domestic-industry representatives, USTR will proceed to the second phase of the review. That phase will be announced through one or more subsequent Federal Register notices and will provide opportunities for public comment from all interested parties—including importers, exporters, retailers, and industry groups—before a final determination.
The USTR is accepting submissions through its official website portal.
What this means for shippers
Importers sourcing from China must track the outcome of this review: tariff rates on affected products could be eliminated, continued, or modified by August 2026 and October 2026. If your supply chain includes goods covered by either Section 301 list, file a landed-cost estimate now to confirm current duty exposure, then monitor USTR notices for phase-two comment periods and the final determination. Failure to update duty assumptions could underestimate landed cost or overestimate cost savings if tariffs are extended.
