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March 25, 2022

USTR Reinstates 352 Section 301 China Tariff Exclusions

by Angela Chiang

Update: Dec. 21, 2022

On Dec. 21, 2022, the Office of the U.S. Trade Representative announced the extension of 352 Section 301 tariff exclusions that were previously granted and set to expire on Dec. 31, 2022.

The exclusions are effective as of Jan. 1, 2023 and will extend through Sept. 30, 2023. The reinstated exclusions apply to all imports from China that meet the description within the scope of the ten-digit Harmonized Tariff Schedule (HTSUS).

More Information

On Mar. 23, 2022, the United States Trade Representative (USTR) announced the reinstatement of 352 tariff exclusions under the Section 301 investigation on imports from China. The reinstated product exclusions will apply as of Oct. 12, 2021 and extend through Dec. 31, 2022.

The tariff exclusions span across Lists 1-4 and are available for any products that meet the description and scope of the Harmonized Tariff Schedule (HTSUS) subheading within the product exclusion notice.

Some notable auto parts-related exclusions that have been reinstated include:
  • 8413.30.9090 – Cooling medium pumps for internal combustion piston engines of the vehicles used to transport people (8703) or goods (8704)
  • 8511.40.000 – Starter motors for internal combustion gasoline engines designed for use in automotive and certain other industries
  • 8536.50.9065 – Modular light switches, for a voltage not exceeding 1,000 V, presented in polyethylene terephthalate (PET) housings, designed for use with a backplate
  • 8543.70.4500 – Position or speed sensors for motor vehicle transmission systems, each valued not over $12
  • 8708.50.8500 – Constant velocity axles (half shafts)
  • 8708.99.6890 – Front output shafts of SAE 1045 carbon steel suitable for use in automatic transmission systems for passenger motor vehicles
This is not an exhaustive list. Please review the USTR notice for your specific products.

On Oct. 8, 2021, USTR invited public comments on whether to reinstate 549 previously granted and extended exclusions. The exclusion requests were reviewed based on the following factors:
  • 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 since September 2018 with respect to the particular product or any other relevant industry developments.
  • The efforts, if any, the importers or U.S. purchasers have undertaken since September 2018 to source the product from the United States or third countries.
  • Domestic capacity for producing the product in the United States.
  • Whether or not reinstating the exclusion would impact or result in severe economic harm to the commenter or other U.S. interests and overall impact of the exclusions on the goal of obtaining the elimination of China’s acts, policies, and practices covered in the Section 301 investigation.
If you have any questions, please contact Angela Chiang at angela.chiang@autocare.org.

Tariff Impact Member Survey

The Auto Care Association is interested in hearing from you and how your business continues to be affected by the U.S.-China trade relationship and the Section 301 tariffs.

Please take this brief survey so we can better understand the challenges you are facing.

Your feedback will play a valuable role in our efforts to continuously strengthen our advocacy efforts and facilitate discussion to show the importance of the U.S.-China trade relationship and the impact Section 301 tariffs have on our industry.

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Angela Chiang, Director, International Affairs

Doing business across borders can be tough, especially now. My work centers around helping you explore new and emerging markets, finding new business partners and navigating trade policy. More About Me



As trade policies are updated and supply chain challenges continue, this section provides the latest information on how your business can navigate the changes.

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