U.S. importers have two more months to use 178 exclusions from Section 301 tariffs on qualifying goods from China. The Office of the U.S. Trade Representative extended the exclusions through Jan. 9, 2027, after they had been due to expire Nov. 9. The extension covers both a group of 164 previously excluded products and 14 exclusions for specified solar manufacturing equipment.
The Federal Register public-inspection notice, scheduled for publication Nov. 10, sets the new window for goods entered for consumption or withdrawn from a customs warehouse for consumption. It starts at 12:01 a.m. Eastern on Nov. 10 and runs until the cutoff at 11:59 p.m. Eastern on Jan. 9. In Pacific time, those two points are 9:01 p.m. on Nov. 9 and 8:59 p.m. on Jan. 9.
Which goods qualify for the extension
The notice keeps two existing tariff headings in use. Heading 9903.88.69 covers the 164 exclusions referenced in the May 2024 notice. Heading 9903.88.70 covers the 14 solar manufacturing equipment exclusions referenced in the September 2024 notice. The two headings are separate because the products qualify under different notes in the tariff schedule. The new notice changes the end date for both groups and directs filers to the existing product descriptions.
An importer does not have to be the company that originally requested an exclusion. The notice says any product that meets the description can qualify. It also says the scope depends on the applicable 10-digit U.S. tariff reporting number and the written product description, rather than the wording of any individual exclusion request. That makes a short category label an unreliable way to tell whether a shipment qualifies.
The USTR exclusion directory provides the earlier product lists. For example, one automotive air-conditioning compressor exclusion applies to non-screw compressors in a specified reporting category valued above $88 and no more than $92 per unit. A $90 unit could satisfy the value condition, while a $93 unit would not. The importer would still need to match the rest of the description. The solar list likewise identifies particular machines used to make solar products. It does not establish an exemption for all finished solar panels.
Why the customs entry date matters
The dates refer to the customs event named in the notice, rather than the day an importer orders or pays for goods. A shipment can leave its supplier well within the window and still enter for consumption after the exclusion ends. Goods placed in a customs warehouse can also have a separate withdrawal date. For orders close to the January deadline, those distinctions matter more than the date on a supplier invoice.
Businesses that used one of the exclusions on previous shipments can compare the item description and reporting number on those entries with the next shipment. A part with the same catalog name can differ in dimensions, materials or value, and the listed description may turn on one of those details. Keeping the product specification and entry documents together gives an importer and its broker a record of which exclusion was used and why.
Which duties still apply
The extension addresses the additional duty imposed under the specified Section 301 action. The notice does not remove ordinary customs duties or duties imposed under other authorities. Two shipments can therefore qualify for the same Section 301 exclusion and still have different total charges because their classifications or other applicable measures differ.
USTR cited ongoing talks with China in extending the exclusions. The notice sets a January cutoff, so a purchase budget that assumes the same relief for entries later that month depends on a further official action. For shipments that straddle the deadline, ask the broker to price both outcomes before committing to a delivery date.
