On 7 October 2026, USTR confirmed that the Section 301 actions first taken on 6 July and 23 August 2018 did not terminate on their 2026 anniversary dates. Eligible U.S. domestic-industry representatives requested continuation, so both actions remain in effect and may still be modified through the statutory review. For an importer, the operational conclusion is to keep the current Section 301 control in the landed-cost model while checking each product and entry against controlling records.
Do three things now
Do not zero the Section 301 line because an anniversary passed. Record the product, HTS classification, controlling action list, exclusion claim and entry date. Make the next USTR review notice a formal trigger. Unknown fields need an owner and next action, not a zero.
1. What USTR decided
Under section 307(c) of the Trade Act of 1974, an action can terminate at its four-year anniversary unless a representative of a benefiting U.S. domestic industry requests continuation during the statutory window. USTR received 68 producer and 18 trade-association requests for the July action, and 57 producer and 19 trade-association requests for the August action.
The July action did not terminate on 6 July 2026. The August action did not terminate on 23 August 2026. Both remain in effect, subject to possible further modification.
2. What the notice does not decide
| Question | Resolved here? |
|---|---|
| Did the two actions automatically end at the anniversary? | Yes: they did not end |
| Which Section 301 rate applies to a product? | No; check the product list and HTS classification |
| Is a particular exclusion still valid? | No; check its number, legal description, validity and conditions |
| How will CBP treat an entry? | No; check the entry date and implementation requirements |
| Will the statutory review modify the actions? | Unknown; USTR will announce the process separately |
3. Freeze the merchandise facts and classification owner
The supplier should provide the English product description, construction, materials, principal use, origin, producer and quotation version. The importer and broker should confirm the proposed HTS classification against the actual merchandise. A marketing name or old supplier code is not enough.
If classification is unresolved, record it as unknown or pending with an owner. A complete supplier pack supports review; it does not make the classification correct.
4. Connect the cost line to the controlling action
Keep a separate Section 301 field in the landed-cost model. Record the action, annex or list, HTS classification, rate source and last verification date. Ordinary duty, Section 301, AD/CVD, merchandise-processing fees, freight and other costs need separate source trails.
The continuation notice does not provide one new rate that can be copied across all goods from China.
5. Verify an exclusion on its own terms
When a quote depends on a product exclusion, capture the exclusion number, legal product description, HTS reference, validity period, entry conditions and primary source. An exclusion description can be narrower than the ordinary product name or tariff heading.
Continuation of the actions does not, by itself, establish that every exclusion has been extended. If exclusion status is unknown, the model should show the unresolved exposure rather than assume zero.
6. Join quotation and entry records in one review card
| Owner | Inputs | Output |
|---|---|---|
| China supplier | Specifications, material, use, origin, producer and quote version | Product fact pack for classification and list review |
| U.S. importer or broker | Proposed HTS, entry date, action list, exclusion and CBP requirements | Product-level cost assumption and open questions |
| Cost owner | Ordinary duty, Section 301, AD/CVD, fees, freight and Incoterm | Versioned landed cost with sources and review dates |
The card does not provide legal advice or guarantee entry treatment. It prevents an anniversary date from silently removing a cost and keeps unknowns visible.
7. Define the next recalculation trigger
USTR says it will publish a separate notice or notices for the next review stage. Interested persons will be invited to comment on the effectiveness of the actions, other possible actions and effects on the U.S. economy, including consumers.
Recalculate affected quotes when a later notice changes a product list, rate or exclusion, or when CBP implementation changes. Today’s confirmed fact is continuation; the content and timing of any future modification remain unknown.
Facts, analysis and unknowns
Source facts: eligible requests prevented the two 2018 actions from terminating, and USTR will conduct a further statutory review. CZ Overseas analysis: import teams should retain current Section 301 controls and verify treatment at product level. Unknown: without the merchandise, classification, list, exclusion and entry record, this guide cannot determine a specific rate or CBP outcome.
Primary sources: Federal Register 2026-20510, the official govinfo PDF and the May 2026 first-step notice, checked 8 October 2026. Review again when USTR publishes the further review process or when a product list, exclusion or CBP instruction changes.
Frequently asked questions
Does continuation create a new uniform tariff on all Chinese goods?
No. It confirms that two existing actions did not terminate; it does not publish a new uniform rate or product list.
Can an importer set the Section 301 line to zero because the anniversary passed?
No. The actions remain in effect. Product treatment still requires classification, the controlling list, any valid exclusion and the entry date.
Does this notice extend every product exclusion?
No such conclusion can be drawn. Each exclusion needs its own source, legal description, HTS reference, validity and entry conditions.
What this lets readers complete
Importers can keep a traceable landed-cost assumption instead of treating the anniversary as a silent zero-rate date. China suppliers can provide the product facts needed for classification and list review without claiming an importer’s legal conclusion.
Continue the review
Use the supplier quotation comparison guide to normalize the commercial baseline, then separate other trade-remedy exposure with the AD/CVD product-scope guide. For a public-information workflow, contact Chris without sending confidential entry, customer or payment records.