US Section 301 Four-Year Review Deadline (July 2026): An Importer’s Survival Guide

A landmark moment is approaching in US-China trade relations. The second statutory four-year review of Section 301 tariffs, initiated by USTR on May 6, 2026, could result in the automatic termination of 25% duties on approximately $50 billion in Chinese imports — unless domestic industry representatives act before the July 5 and August 22 deadlines.

Key Facts

How the Termination Mechanism Works

Under 19 USC § 2417(c), Section 301 tariff actions are not permanent. At each four-year anniversary, tariffs automatically terminate unless a domestic industry representative submits a written continuation request within the 60-day window before the anniversary date.

This is not hypothetical — Section 301 actions have previously terminated when no continuation request was filed. While domestic industries are likely to file requests, there is no guarantee.

Impact by Stakeholder

US Importers & Distributors

If tariffs on Lists 1 and 2 sunset, the landed cost of covered goods drops by up to 25% overnight. Importers should prepare contingency plans for both scenarios. Key: duty stacking remains complex — MFN base + Section 301 + Section 122 (through July 24) + Section 232 all apply.

E-Commerce & Marketplace Sellers

Amazon FBA and DTC brands importing List 1/2 products from China should monitor developments closely. A tariff sunset could meaningfully improve unit economics on affected SKUs.

Action Checklist

1. Audit your HTS codes: identify which products fall under List 1 (9903.88.01) or List 2 (9903.88.02).
2. Monitor USTR daily from late June through July 5 — continuation requests may come at any time.
3. Build scenario models under both “tariffs continue” and “tariffs sunset” outcomes.
4. Check exclusion eligibility: 178 product categories remain exempt through November 10, 2026.
5. Review supplier contracts: add tariff-adjustment clauses to share risk.