GDLSK: Grunfeld Desiderio Lebowitz Silverman & Klestadt LLP


On June 9, 2020, the U.S. Trade Representative (“USTR”) announced that an additional 34 items will be excluded from the Section 301 trade remedies imposed on Chinese-origin products.   The newly announced exclusions all relate to items on China 301 List 4A (which is part of the $300 billion trade action) which, unless excluded, are currently subject to an additional tariff of 7.5% ad valorem.  The list of newly-excluded items (which supplements the exclusions previously granted by the USTR) is provided below. The exclusions will be retroactive to September 1, 2019 (the date when the China 301 List 4A additional tariffs took effect) and are slated to remain in effect through September 1, 2020.

Significantly, China 301 exclusions are product-specific, not company-specific.  Thus, if a product is described by an exclusion, the importer may benefit regardless of who filed for the exclusion.  Information as to previously excluded items can be accessed at the end of this notice.

Separately, the USTR continues to seek comments identifying additional medical-care items that should be excluded from China Section 301 tariffs in light of the ongoing COVID-19 outbreak (even if a prior exclusion request on an item has been denied or is pending).  The comment period will remain open until at least June 25, 2020.  Additional information can be found at:

If your business is interested in seeking a refund of past duties paid under Section 301, and/or discussing Section 301 mitigation strategies, please contact our office and speak with one of our attorneys.

June 9, 2020 – Newly Excluded Items from China 301 List 4 (New U.S. note 20(bbb)(9903.88.49)

1) 5210.11.4040

2) 5210.11.6020

3) Down of ducks or geese, not further worked than cleaned, disinfected or treated for preservation, meeting both test standards 4 and 10.1 of Federal Standard 148a promulgated by the General Services Administration, with a fill power of at least 315 cm3/g but not more than 580 cm3/g (described in statistical reporting number 0505.10.0055)

4) Cyanuric chloride (IUPAC name: 2,4,6-trichloro-1,3,5-triazine) (CAS No. 108-77-0), 99.5 percent or higher in purity (described in statistical reporting number 2933.69.6010)

5) Kneeling pads of plastics (described in statistical reporting number 3924.90.5650)

6) Fittings of plastics, of a kind used to connect mop heads with mop handles (described in statistical reporting number 3926.90.9990)

7) Printed books, in the Chinese language (other than dictionaries and encyclopedias, textbooks, directories, bibles, testaments, prayer books and other religious books, technical, scientific and professional books, art and pictorial books, hardbound books, and rack size paperbound books), containing 49 or more pages each (excluding covers) (described in statistical reporting number 4901.99.0093)

8) Women’s cut and sewn garden gloves, without fourchettes, cut and sewn from preexisting machine knitted fabric of polyester and cotton jersey, containing 50 percent or more by weight of rubber or plastics, clute cut (described in statistical reporting number 6116.10.4400)

9) Gloves cut and sewn of machine knitted fabric, without fourchettes, with applied polyvinyl chloride dots, such gloves containing 50 percent or more by weight of cotton, man-made fibers or wool, or any combination thereof and subject to man-made fiber restraints (described in statistical reporting number 6116.10.5520)

10) Gloves, containing less than 50 percent by weight of textile fibers, coated with rubber or plastics designed for enhanced grip (described in statistical reporting number 6116.10.6500)

11) Gloves, cut and sewn of knitted fabric in chief weight of polyester, not impregnated, coated or covered with plastics or rubber, without fourchettes (described in statistical reporting number 6116.93.8800)

12) Gloves of vegetable fibers, without fourchettes, with applied dots of polyvinyl chloride (described in statistical reporting number 6216.00.1720)

13) Shells for pillows and comforters made from microfiber fabric consisting of filament yarns not more than 1.22 decitex, such fabric with a weight of at least 55 g/m2 but not more than 155 g/m2 (described in statistical reporting number 6307.90.9889)

14) Round wire of nonalloy steel, hot-dipped galvanized with zinc, containing by weight less than 0.25 percent carbon, measuring at least 1.5 mm in diameter (described in statistical reporting number 7217.20.3000)

15) Ring binder mechanisms for loose leaf binders, each measuring at least 132 mm but not more than 134 mm in length and at least 16 mm but not more than 18 mm in width, with 2 prongs seated underneath housing (described in statistical reporting number 8305.10.0010)

16) Three-way hand-operated valve part of brass, suitable for use as an input part on irrigation-grade valves (described in statistical reporting number 8481.90.1000)

17) Lithium-ion batteries of a form other than size designations of the International Electrotechnical Commission (“IEC”) or the American National Standards Institute (“ANSI”), each producing not more than 45 V, with a capacity of at least 6,000 milliamp hours (mAh) but not more than 10 A hours (described in statistical reporting number 8507.60.0020)

18) Optical channel splitters (capable of converting between electrical signals and multiplexed optical signals) (described in statistical reporting number 8517.62.0090)

19) Television liquid crystal display (“LCD”) main board assemblies, each consisting of a printed circuit board containing a television tuner and audio and video components (described in statistical reporting number 8529.90.1300)

20) Safety spectacle frames of plastics conforming to U.S. Occupational Safety and Health Administration standards (described in statistical reporting number 9003.11.0000)

21) Spectacle frames of plastics conforming to U.S. Food and Drug Administration regulations as approved medical devices (described in statistical reporting number 9003.11.0000)

22) Spectacle frames, other than of plastics (described in statistical reporting number 9003.19.0000)

23) Liquid crystal display (“LCD”) modules, not capable of receiving or processing a broadcast television signal, each with a video display diagonal measuring not more than 191 cm (described in statistical reporting number 9013.80.9000)

24) Watch cases of stainless steel and titanium, not gold- or silver-plated, unassembled, each measuring at least 20 mm but not more than 48 mm in diameter and weighing at least 50 g but not more than 250 g (described in statistical reporting number 9111.20.4000)

25) Wristwatch cases of stainless steel, not gold- or silver-plated, including the sapphire crystal, the crown and the case back, each measuring at least 39 mm but not more than 41 mm in diameter and at least 8 mm but not more than 10 mm in thickness, weighing not more than 40 g (described in statistical reporting number 9111.20.4000)

26) Watch dials of brass, each measuring at least 18 mm but not exceeding 50 mm in width and weighing at least 10 g but not more than 20 g (described in statistical reporting number 9114.30.4000)

27) Wristwatch dials of copper, each measuring at least 33 mm but not more than 35 mm in diameter (described in statistical reporting number 9114.30.4000)

28) Wristwatch hands, presented in sets each containing three hands (second, minute and hour) of copper, each hand measuring at least 10 mm but not more than 14 mm in length, faced with lume paint (described in statistical reporting number 9114.90.4000)

29) Parts of child safety seats (described in statistical reporting number 9401.90.1085)

30) Unfinished pads and seats for weight-training exercise machines (described in statistical reporting number 9506.91.0030)

31) Fish hooks, not snelled (described in statistical reporting number 9507.20.8000)

32) Mop heads of polyester and rayon, lint free, disposable (described in statistical reporting number 9603.90.8050)

33) Tufts of swine hair bristles, oriented with the soft feather tipped ends of the hairs facing up and the hard, root ends of the hairs facing down, with the root ends of the hairs glued together to form a round bottom not more than 7 mm in diameter, for incorporation into brushes (described in statistical reporting number 9603.90.8050)

34) Electrical spark lighters (described in statistical reporting number 9613.80.2090)


Links to the prior notices granting China 301 exclusions appears below (please note, some prior exclusions may have expired, been extended, or amended):


Exclusions Granted December 28, 2018

Exclusions Granted March 25, 2019 

Exclusions Granted April 18, 2019

Exclusions Granted May 14, 2019

Exclusions Granted June 4, 2019

Exclusions Granted July 9, 2019

Exclusions Granted September 20, 2019

Exclusions Granted October 2, 2019

Exclusion Granted December 17, 2019 and Amendments to Exclusions Granted July 9, 2019 and September 20, 2019

Exclusions Granted February 11, 2020


Exclusions Granted July 31, 2019

Exclusions Granted September 20, 2019

Exclusions Granted October 2, 2019


Exclusions Granted August 7, 2019

Exclusions Granted September 20, 2019

Exclusions Granted October 28, 2019 

Exclusions Granted November 13, 2019

Exclusions Granted November 29, 2019

Exclusions Granted December 17, 2019

Exclusions Granted January 6, 2020

Exclusions Granted February 5, 2020

Exclusions Granted February 20, 2020

Exclusions Granted March 16, 2020

Exclusions Granted March 26, 2020

Exclusions Granted April 24, 2020

Exclusions Granted May 8, 2020

Exclusions Granted May 21, 2020


Exclusions Granted March 10, 2020

Exclusions Granted March 17, 2020

Exclusions Granted March 31, 2020

Exclusions Granted May 13, 2020

Amendments to Exclusions May 26, 2020

Exclusions Granted June 8, 2020



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