GDLSK: Grunfeld Desiderio Lebowitz Silverman & Klestadt LLP
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On July 16, 2020, the Office of the U.S. Trade Representative (“USTR”) has issued a notice requesting comments on whether certain additional expiring China 301 List 4 tariff exclusions should be extended.

To date, the USTR has issued six notices of List 4 product exclusions, all of which are scheduled to expire on September 1, 2020.  Comments have already been requested as to whether exclusions covered by the first five notices should be extended (more details at:

The USTR is now seeking comments as to whether extensions of up to twelve months should be granted for items covered by the sixth notice of List 4 exclusions (accessible at: Exclusions Granted July 7, 2020) and a forthcoming seventh notice of product exclusions.

The USTR will evaluate the potential extensions on a case-by-case basis. The focus will be on whether the particular product remains available only from China.  Factors to be considered include:

  • Whether the particular product and/or a comparable product is available from sources in the United States and/or in third countries.
  • Any changes in the global supply chain with respect to the particular product or any other relevant industry developments.
  • The efforts, if any, the importers or U.S. purchasers have undertaken to source the product from the United States or third countries.
  • Whether the imposition of additional duties on the products covered by the exclusion will result in severe economic harm to the commenter or other U.S. interests.

Any comments must be submitted in a specified format on the UTRS’s 301 web portal and address particular data points solicited by the portal.  A separate comment must be submitted for each exclusion.  A docket for the above action will remain open from July 15, 2020 to August 14, 2020.

Should you have any questions or would like assistance in preparing comments in support of extensions for the above China 301 exclusions, please do not hesitate to contact our office.


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