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July 16, 2020
China 301: USTR Considers Extension of July List 4A Exclusions
Today, the Office of the U.S. Trade Representative ("USTR") announced the decision to consider the possible extension of certain exclusions granted for products on List 4A of the Section 301 trade action against China.  To date, USTR has issued six  product exclusion notices on List 4A and intends to publish a seventh notice in the coming days.   Today's  announcement requests comment on the possible extension of product exclusions granted under the sixth product exclusion notice, published on July 10, 2020, as well as those products granted an exclusion under the anticipated seventh product exclusion notice.  Any exclusions granted an extension by USTR will continue to be excluded from the Section 301 duties on List 4 for up to an additional 12 months.   

Product exclusions eligible for extension under the July 10 exclusion notice include 61 individual exclusions that cover a variety of commodities such as fabrics, artwork, and various steel products.  A complete list of the exclusions eligible for extension during this comment period will be available once the seventh product exclusion notice on List 4A is published in the coming days.  All of these exclusions are set to expire on September 1, 2020.  The comment docket opened July 15, 2020  and the deadline for submission of comment is August 14 , 2020

As discussed in our previous alerts, USTR is also considering extensions for expiring List 2 exclusions granted in September and October of 2019 and extensions for expiring List 4 exclusions granted in March, May, and June of 2020.  The deadline for comment on extension of these List 2 and List 4 exclusions is  July 30, 2020 .  
 
USTR has not yet extended any exclusions in the absence of comments in support of extension.  Therefore, we strongly recommend that you consider submitting comments in support of the extension of any product exclusions benefiting you or your suppliers.  Please let us know as soon as possible if any of the products on this list are important to you. 
 
Please let us know if you have any questions. 
The Mowry & Grimson Team