What Changed
Effective September 1, 2019Section 301 List 4A took effect September 1, 2019, covering approximately $120 billion in Chinese imports at a 15% tariff rate. Unlike the first three lists that targeted primarily industrial and intermediate goods, List 4A directly affected consumer goods including apparel, footwear, electronics, and household products. List 4B was suspended and never implemented. List 4A was reduced to 7.5% as part of the Phase One trade deal effective February 14, 2020.
Rate Changes
| Item | Before | After |
|---|---|---|
| S301 List 4A Chinese goods ($120B) | 0% S301 | 15% S301 |
Who's Affected
US importers and retailers of consumer goods from China. The List 4A tariffs were the first Section 301 tariffs to directly affect the broad consumer market, raising import costs on everyday products. Retailers and e-commerce businesses faced immediate price pressure as the tariffs applied to their core product categories across apparel, electronics, and home goods.
Analysis
Section 301 List 4A: $120 Billion in Chinese Consumer Goods at 15% (effective 2019-09-01). Section 301 List 4A took effect September 1, 2019, covering approximately $120 billion in Chinese imports at a 15% tariff rate. Section 301 of the Trade Act of 1974 authorizes the USTR to investigate and respond to unfair trade practices by foreign governments, including subsidies and discriminatory policies that harm US commerce. The ongoing Section 301 action against China was initiated in 2018 and covers tens of billions of dollars in Chinese imports across four product lists. A four-year statutory review conducted in 2024 resulted in targeted increases on strategic sectors — electric vehicles, solar cells, batteries, semiconductors, and critical minerals — reflecting bipartisan consensus on the need to protect US competitiveness in clean energy and technology. Section 301 tariffs stack on top of the base MFN rate and, for certain products, on top of the Section 122 surcharge as well, creating compound tariff rates that can exceed 100% for some Chinese goods. The 2024 review confirmed that existing tariffs on Chinese goods will remain in force, providing businesses with certainty that Section 301 rates are not a temporary measure. USTR's approach of using "replacement rates" — where the 2024 increases replace the base list rates rather than stacking on top of them — is critical to understand when calculating effective tariff costs. For example, Chinese EVs face a 100% Section 301 rate that replaces the prior 25% rate; they do not face 125%.
Impact & Next Steps
Importers of Chinese goods should verify the specific List (1, 2, 3, or 4A) that applies to their HTS codes, as rates vary by list. The 2024 review replacement rates (EVs at 100%, solar at 50%) apply as final rates, not as additions to prior rates. Country-of-origin rules apply: products substantially transformed in China are subject to S301 even if shipped from a third country. Consider supply chain diversification for strategic categories to reduce S301 exposure.