AEM is providing guidance to member companies on the recently proposed USTR China tariff exclusion process. Companies may request exclusion of a particular product from the additional duties by filing a request by Oct. 9, 2018.

Exclusions will be effective for one year upon the publication of the exclusion determination in the Federal Register, and will apply retroactively to July 6, 2018.

Because exclusions will be made on a product basis, a particular exclusion will apply to all imports of the product, regardless of whether the importer filed a request. In making a determination on each request, USTR may consider whether a product is available from a source outside of China, whether the additional duties would cause severe economic harm to the requestor or other U.S. interests, and whether the particular product is strategically important or related to Chinese industrial programs, including “Made in China 2025.”

To learn more about filing a request, click here:

To obtain a China 301 Product Exclusion Form, click here  

To submit a request, click here

To date, USTR has not disclosed how long it will take the agency to make a determination on each request. AEM is engaging the USTR to obtain additional clarification on the product exclusion process and will keep membership updated.

For additional questions, please contact AEM Director of International and Regulatory Affairs Alex Russ (, tel: 202-898-9006). 

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