On September 16, 2025, the Office of the U.S. Trade Representative (USTR) issued a notice and request for public comments on the possible extension of the remaining 178 product exclusions in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The USTR has extended these exclusions several times, including a recent 90-day extension through November 29, 2025. See Thompson Hine Update of September 2, 2025. The USTR will accept public comment until October 16, 2025, on whether any of the remaining 178 product exclusions warrant an extension beyond November 29, 2025.
Set forth below is a summary of the information to be entered on the exclusion comment form:
- Contact information, including the full legal name of the organization making the comment, whether the commenter is a third party.
- The exclusion covered by the comment.
- Whether the exclusion warrants further extension.
- The availability of products covered by the exclusion from sources outside of China.
- Efforts undertaken to source the product from the United States or third countries.
- Why additional time is needed to shift sourcing from China and whether further extending the exclusion will likely contribute to a shift in sourcing of the product outside of China.
- Whether further extending the exclusion is consistent with the Trump administration’s priorities and U.S. interests.
All comments musts be submitted through USTR’s online portal at https://comments.ustr.gov.
