US confirms China Section 301 tariffs continue pending review

Continuation, not a new October tariff

The notice confirms that the actions originally effective on 6 July and 23 August 2018 did not terminate on their respective 2026 anniversary dates. Both remain subject to possible further modifications. This is confirmation of continued measures, not an additional tariff effective from 7 October or a finding that the second four-year review has been completed.^[1]

The statutory trigger

Section 307(c)(1) of the Trade Act of 1974, codified at 19 USC 2417(c)(1), provides for termination at the end of a four-year period if neither the petitioner nor a representative of a benefiting domestic industry submits a written continuation request during the final 60 days. USTR received qualifying requests for each action, preventing that termination. The continuation mechanism does not require importers themselves to request an extension.^[1][2]

The modified actions remain the subject of review

The earlier May notice explains that the actions were subsequently modified through supplemental product lists, temporary product exclusions and changes arising from the first four-year review. The October confirmation concerns those actions as modified, rather than reinstating only the original 2018 product lists. It does not itself announce a new rate or product-exclusion period.^[1][3]

What multinational importers should watch

Section 307(c)(3) requires USTR to review the effectiveness of the actions and alternatives, and their effects on the US economy, including consumers. USTR says separate notices will explain that process and invite comments; this continuation notice sets no new comment deadline. For groups importing affected Chinese goods, the practical message is that the anniversary dates did not remove the existing duty exposure. Any subsequent rate, product-scope or exclusion change must be assessed against its own instrument rather than inferred from this continuation notice.^[1][2]