The United States Trade Representative (USTR) has announced the expiration of 233 exclusions to the 301 tariffs on Chinese imports. The exclusions expired on May 31, but a grace period will be in place until June 14, at which point products in these categories imported from China will be subject to tariffs.
- To read the USTR’s notice on the expirations, click here (the full list of exclusions that have expired can be found in Annex D)
- In late 2023, PPAI called for an extension of exclusions to these tariffs allowing promo companies to continue to import from China.
“Who’s really punished by tariffs?” commented Ben Zhang, president and CEO of Greater Pacific, PPAI 100’s No. 68 supplier. “American companies, not Chinese manufacturers.”
In 2023, the U.S. imported more than $427 billion in goods from China and exported nearly $148 billion to the world’s second largest economy, according to the U.S. Census Bureau.
Why Did These Exclusions Expire?
In 2017, the USTR conducted an investigation concerning China’s trade practices, concluding that the country was guilty of several practices deemed suspicious or unfairly burden the U.S. This type of investigation and subsequent action is allowed under Section 301 of the Trade Act of 1974.
- As a result, tariffs were placed on products imported into the U.S. from China. The move raised the costs for U.S. businesses to bring these products into the country.
When the Section 301 tariffs were placed, businesses had a window in which they could request specific products be excluded from the tariffs. Assuming valid evidence was provided, those product categories were exempt from the tariffs. Regardless of evidence, such exclusions are not meant to be permanent.
“The pattern of making last-minute announcements regarding the tariff exclusions exacerbates uncertainty for U.S. companies who need to make business decisions months in advance,” a letter by Americans for Free Trade said at the end of 2023.
Exclusions have officially expired on 233 of 429 of the products with Chinese import tariffs with no extension granted.
- Of those 233 expired exclusions, 102 of them expired due to nobody requesting an extension.
- The rest have expired because importers did not indicate intent or did not show sufficient effort to ship out of China or because of evidence of domestic or third country production of such products.
- For exclusions that were granted an extension, the extension will run through May 31, 2025.
Promo Perspective
The grace period before the tariffs kick in on the expired exclusions is a short window, so it is imperative that promo companies examine the USTR’s notice before June 14 to determine if it affects products they are currently importing from China.
The list of products that will now be subject to Chinese tariffs is long and diverse, but a few expired exclusions that may be relevant to promo companies include:
- Certain styles of bags
- Backpacks with hydration systems
- Specific types of robes
- Styles of blankets
- Grills composed of steel wire at certain dimensions
