On May 6, 2026, the U.S. Trade Representative (USTR) issued a notice initiating its second statutory four-year review of Section 301 tariffs on imports of certain Chinese products initially implemented by the Trump administration in its 2018 investigation of China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation. The first step in the four-year review process is notifying representatives of domestic industries benefiting from these actions of their possible termination and the opportunity to request their continuation.  Specifically, this notice is seeking comments from domestic industries on the two Section 301 tariff actions that became effective July 6, 2018 and August 23, 2018.

Without opposition, these tariff actions are set to expire on their four-year anniversary dates. They involve the assessment of Section 301 tariffs on products with an approximate annual trade value of $34 billion effective July 6, 2018 (List 1), and on products with an approximate annual trade value of $16 billion effective August 23, 2018 (List 2). The USTR subsequently issued notices modifying these actions to impose additional tariffs on various other imports of Chinese products identified in different tranches commonly known as Lists 3 and 4A on September 21, 2018 and August 20, 2019, respectively. To ensure comprehensive coverage of the review, the USTR will consider the List 3 and List 4A modifications as applicable to both the July 6, 2018 action and the August 23, 2018 action.

Domestic industry representatives may submit their requests for the July 6, 2018 action between May 7, 2026 and July 5, 2026.  Requests on the August 23, 2018 action may be submitted between June 24, 2026 and August 22, 2026. Submissions should be made at https://comments.ustr.gov/s/. Representatives of a domestic industry benefiting from both of the trade actions under Section 301 should submit two separate requests for continuation of each action.

If no request is received, these Section 301 trade actions will terminate on July 6, 2026 and August 23, 2026, respectively. If the USTR receives a request to continue, it will announce the continuation of these actions and will undertake a review of the effectiveness of the actions in achieving Section 301 objectives, other actions that could be taken, and the effects of such actions on the U.S. economy, including consumers. The USTR will then open a separate portal for interested persons to submit their comments addressing these issues.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.