What Happened
On August 28, 2025, the Office of the United States Trade Representative (USTR) announced that several product exclusions under Section 301 tariffs on Chinese goods will be extended through November 29, 2025.
👉 Official USTR Press Release
These exclusions, originally set to expire on August 31, apply to goods tied to the U.S. investigation into China’s technology transfer, intellectual property, and innovation practices.
Here’s what’s included:
164 previously extended exclusions (first announced May 2024)
14 solar manufacturing equipment exclusions (announced September 2024)
Codified under HTSUS 9903.88.69 and 9903.88.70
In short, importers get an additional 3 months of tariff relief before the next major decision point.
Why This Matters for E-commerce & Importers
If you import finished goods or components from China, this update should be flashing on your radar.
1. Short-Term Relief from Tariff Costs
These extensions mean qualified goods can still avoid additional Section 301 duties.
That gives your brand more breathing room to:
Keep landed costs stable during Q4 and early 2026
Lock in supply chain commitments under the current tariff structure
Avoid mid-year sourcing disruptions or surprise cost spikes
2. Accuracy Matters — Review Your Classifications
Exclusions are product-specific, based on precise HTS codes and product descriptions.
If your sourcing, materials, or classification changes—even slightly—you could lose eligibility.
“Importers should review the updated HTSUS provisions to determine if their products qualify for the extended exclusions.”
— Troutman Pepper Locke Advisory
3. The Clock Is Ticking
This is a temporary extension. Come November 29, 2025, the current exclusions expire unless further action is taken.
That means:
Tariffs could snap back on overnight
Your landed cost forecasts could change immediately
Brands relying on these exclusions should model both “tariff back on” and “extended again” scenarios now
4. DTC Brands Face Unique Exposure
If your Shopify brand imports products from China—apparel, electronics, packaging, etc.—you’ll want to revisit:
Margins: Recalculate profit if tariffs return
Pricing: Build flexibility into 2026 retail pricing and promotions
Sourcing: Explore alternate manufacturing countries or dual-sourcing
Cash Flow: If tariffs hit again, your duty payments could spike 15–25% instantly
Actionable Checklist for Importers
Before this flies under the radar, here’s a practical checklist for your operations team:
✅ Audit your import SKUs
List every SKU with China origin and map its HTS classification.
✅ Check if you’re covered
Review exclusions under HTSUS 9903.88.69 and 9903.88.70. Confirm product descriptions match exactly.
✅ Update your cost modeling
Run two scenarios:
Scenario A: exclusions expire (tariffs reapply)
Scenario B: exclusions get renewed again
✅ Revisit sourcing strategy
Consider moving partial production elsewhere or pre-ordering before November 29 to lock in tariff-free goods.
✅ Monitor USTR & CBP updates
These programs can shift quickly—subscribe to USTR and CBP updates to stay ahead.
✅ Leverage duty recovery programs
If your business exports or destroys unsellable goods, explore duty drawback opportunities. Many importers are leaving six figures in unclaimed refunds on the table, that’s where solutions like Evana can help.
Key Takeaways
The USTR has extended key China tariff exclusions through November 29, 2025.
This offers short-term relief, but it’s not permanent—plan for both outcomes.
Now’s the time to review your HTS codes, cost models, and supply chain dependencies.
DTC and Shopify brands should use this window to secure margins, forecast risk, and explore refund strategies like duty drawback.
💡 Pro Tip: Even if your products don’t qualify for this specific exclusion, every importer should have a duty recovery strategy in place. Between exclusions, reclassifications, and drawback refunds, importers can often recover millions in overpaid duties.
-Parker Burr
Founder, Evana & Bylders Newsletter
