China Section 301 List 4A Renewal 2026: USTR Review Outcomes and What Importers Should Do

USTR completed the four-year review of Section 301 China tariffs in May 2024 with the headline conclusion that the tariffs remain appropriate. List 4A specifically held at 7.5 percent ad valorem, the rate that has been stable since the February 2020 Phase One agreement reduction. 2026 has brought additional exclusion windows and clarifying modifications but no fundamental rate change.

This guide covers the current status of List 4A, the 2024 review outcomes, the active exclusion windows including the February 2026 grant batch, and the operational implications for importers buying Chinese goods on List 4A subheadings.

What List 4A covers

List 4A imposes 7.5 percent ad valorem on approximately 3,200 HTS 8-digit subheadings of Chinese-origin product. Categories include:

• Chapter 61 to 62 apparel (knit and woven)
• Chapter 63 made-up textile articles
• Chapter 64 footwear
• Chapter 84 specific machinery sub-lines (handheld tools, vacuum cleaners, some kitchen appliances)
• Chapter 85 consumer electronics (TVs, monitors, headphones, smart-home)
• Chapter 90 specific medical and optical instruments
• Chapter 95 toys, games, sporting goods

Imposed September 1 2019 at 15 percent, reduced to 7.5 percent February 14 2020 under Phase One. Stable since.

The 2024 four-year review

USTR's four-year statutory review under section 307(c) of the Trade Act concluded in May 2024 with USTR maintaining the existing tariff structure across List 1, 2, 3, 4A. Key findings:

1. China's acts, policies, and practices identified in the original 2018 Section 301 investigation continue to burden US commerce. USTR found no material change in China's technology transfer requirements, IP enforcement, or state-directed industrial policy targeting strategic sectors.

2. The tariffs have achieved measurable effect on supply chain diversification. US imports from China declined as a share of total imports from approximately 22 percent (pre-tariff) to roughly 14 percent (2023 to 2024). The shift went largely to Vietnam, India, Mexico.

3. Specific modifications were proposed and ultimately implemented in late 2024:

   • Section 301 tariff increase on Chinese EVs (specific HTS 8703 lines) to 100 percent.
   • Solar cell tariffs (HTS 8541) to 50 percent.
   • Semiconductor (HTS 8541, 8542 specific lines) to 50 percent.
   • Battery (HTS 8507) to 25 percent.
   • Critical minerals tariffs targeted at specific Chinese-dominated supply chains.

4. List 4A specifically was held at 7.5 percent with no rate adjustment. The administration cited the consumer-facing nature of List 4A and the pass-through risk to inflation as the reason for stability.

The February 2026 exclusion grant

USTR announced the February 2026 exclusion batch covering approximately 400 product-specific descriptions across List 1, 2, 3, 4A. Notable categories:

• Medical devices and PPE that came in scope during COVID and were extended through 2026.
• Specific industrial inputs with no US producer (some chemistry intermediates, specific electronic component categories).
• Solar manufacturing equipment for US fab build-out (limited categories).
• Renewable energy components with no domestic equivalent.

Granted exclusions are retroactive to the original tariff imposition date for the specific product description matching the exclusion grant. Importers who paid List 4A duty on a product that matches a granted exclusion can file a protest within 180 days of liquidation (or PSC if unliquidated) for refund.

The grant rate in the February 2026 batch was approximately 9 percent of submitted requests. Average review time was 11 months from filing.

Post-SCOTUS V.O.S. Selections context

The February 2026 SCOTUS ruling in V.O.S. Selections v. United States invalidated the IEEPA-based reciprocal tariff program. Section 301 was NOT affected because it has independent statutory authority under 19 USC 2411 (Trade Act of 1974). The Court's reasoning distinguished IEEPA (an emergency authority not designed for ad valorem tariff action) from Section 301 (a specifically tariff-action authority enacted by Congress).

Practical implication: List 4A duty continues unchanged. The 15 percent flat Section 122 rate that replaced IEEPA effective February 24 2026 stacks on top of List 4A. Chinese consumer electronics on List 4A in 2026 pay 7.5 percent List 4A plus 15 percent Section 122 = 22.5 percent before MFN.

What importers should do

1. Check every Chinese-origin shipment against the active exclusion list. The USTR exclusion database is updated as grants are issued. Match by HTS subheading AND product description (exclusions are often narrower than the HTS line).

2. File exclusion requests in the next window. USTR is expected to open another exclusion window in late 2026 or early 2027. Typical request cost 5,000 to 25,000 USD per product description. Grant rate ~10 percent. Worth it only for high-volume products with no US producer.

3. Document substantial transformation if routing through Vietnam, Malaysia, Mexico. Anti-circumvention enforcement has tightened. Verify your producer's substrate origin and document the substantial transformation at the third country.

4. Model the full stack landed cost. List 4A + Section 122 + MFN + Section 232 derivative (if applicable) + ADCVD (if applicable). The cumulative rate frequently exceeds 40 percent on Chinese consumer goods.

5. Watch the 2028 four-year review. If the next administration changes the policy, List 4A could expand, contract, or be eliminated. Pre-position sourcing flexibility.

Worked example: Chinese smart-home electronics in 2026

200,000 USD of HTS 8517.62 from China.

Effective rate 24.9 percent. List 4A is the cheaper of the two duty layers in this stack; Section 122 dominates.

Run your List 4A entry now

The LandedFees calculator handles the current List 4A scope, the February 2026 exclusion grants, the Section 122 China stack, and the related layers. Useful for verifying that a Chinese-origin shipment is or is not on a granted exclusion before filing.

Calculate a List 4A entry

Section 122 status as of June 20 2026

The May 7 2026 Court of International Trade ruling in Oregon v. United States (consolidated with Burlap and Barrel v. United States) struck down the Section 122 proclamation. The Federal Circuit issued an administrative stay on May 12 2026, so CBP is still collecting the duty pending appeal. Importers paying now should preserve protest rights and refund claims in case the government loses on the merits. The underlying Section 122 authority sunsets July 24 2026 under the statutory 150-day ceiling, regardless of the appeal outcome, unless Congress extends or a fresh proclamation restarts the clock.

Citations

• USTR Section 301 actions: https://ustr.gov/issue-areas/enforcement/section-301-investigations
• USTR four-year review final report May 2024: https://ustr.gov/about-us/policy-offices/press-office/press-releases/2024/may/ustr-issues-final-report-section-301-review-strategically-targeted-tariffs-china
• USTR exclusion database: https://comments.ustr.gov/s/exclusions
• 19 USC 2411 Section 301 statutory basis: https://www.law.cornell.edu/uscode/text/19/2411
• V.O.S. Selections v. United States SCOTUS February 2026