Tariff exclusions for 178 kinds of Chinese imports that Trump’s trade office extended are set to expire after Nov. 9

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Tariff relief on 178 categories of Chinese-made goods runs out at the end of Nov. 9 unless the U.S. Trade Representative extends it again. The Office of the U.S. Trade Representative, which runs the Section 301 tariffs on China, has so far announced nothing beyond that date. Goods that enter the country after the cutoff would carry the duties the exclusions have been waiving.

The deadline matters most to companies that import those products and to the businesses downstream that buy them, from manufacturers to retailers that price in the cost of tariffs. Anyone who imports these goods has to decide in the coming weeks whether to budget for a return of the tariffs on entries after Nov. 9 or to wait for another extension notice.

The Nov. 9 cutoff is the next date to watch, and the Trade Representative has not said whether another extension follows it.

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Which date the notice sets

The extension was published in the Federal Register on Dec. 1, 2025, as a notice of product exclusion extensions signed by USTR General Counsel Jennifer Thornton. Its DATES section says the modifications “extend the exclusions through 11:59 p.m. eastern daylight time on November 9, 2026.” That is the legal cutoff for the 178 exclusions, and it is why the exclusions last through Nov. 9 and expire once that day ends.

The paperwork is not perfectly consistent. The background and determination sections of the same notice say the exclusions run “until November 10, 2026,” and so does USTR’s Nov. 26, 2025 announcement. Both versions describe relief that ends as Nov. 9 turns into Nov. 10, and only the DATES text gives a clock time, 11:59 p.m. Eastern on Nov. 9.

The notice gives its reason in one sentence: the extension came “in light of the trade and economic deal reached between President Trump and President Xi Jinping of China.” It does not say whether that deal will keep the exclusions alive past November. It says only that USTR “may continue to consider further extensions and/or additional modifications as appropriate.”

How the list grew and was extended since 2023

The 178 exclusions did not start as a single list. According to the same notice, USTR asked for public comment on Dec. 29, 2023, on 352 reinstated exclusions and 77 tied to COVID-19. On May 30, 2024, it extended 164 exclusions through May 31, 2025. On Sept. 18, 2024, it added fourteen exclusions for certain solar manufacturing equipment, which together with the 164 make the 178 now in force.

After that the extensions got shorter. In a notice published June 5, 2025, USTR extended the 164 and the fourteen through Aug. 31, 2025. On Sept. 2, 2025, it extended the 178 by 90 days, through Nov. 29, 2025. The November 2025 notice then pushed the expiry out to Nov. 9, 2026. Every step so far has been an extension rather than a lapse.

The notice also says USTR no longer accepts comments on the exclusions, so there is no open docket where importers can ask for another round. General questions go to Philip Butler, a senior associate general counsel at USTR, and questions about customs classification or implementation go to U.S. Customs and Border Protection at traderemedy@cbp.dhs.gov.

The solar equipment line and what stays in force

Fourteen of the 178 cover certain solar manufacturing equipment, the one group in the list that USTR added separately in 2024. The notice describes them as exclusions effective Jan. 1, 2024. The other 164 carry over from the earlier reinstated and COVID-related exclusions. The law firm Shapiro, in a Dec. 1, 2025 client alert, reads the exclusions as applying to products listed under HTSUS 9903.88.69 and 9903.88.70 and advises importers to keep applying them as long as their goods match the exact product descriptions, to watch for CBP entry guidance, and to expect that USTR could review or modify them again.

The newest paperwork shows the exclusions still being maintained. In a Federal Register notice published Oct. 7, 2026, USTR amended five of the product exclusions to follow changes in the Harmonized Tariff Schedule. The amendment is effective as of July 1, 2026. It does not mention the Nov. 9 expiry and does not announce another extension, but it confirms the agency is still administering the list.

Entering goods before and after Nov. 9

The cutoff is a date of entry, not a date of order, so the cost question turns on when shipments arrive. Products that clear customs on or before Nov. 9 under the exclusion keep the relief. Shipments arriving afterward would be assessed the Section 301 duty unless USTR publishes a new notice first. The last extension came in a Nov. 26, 2025 announcement, three days before the Nov. 29 expiry it replaced.

Importers sorting out which of their products sit on the list should start with the exclusion descriptions in the notice’s annexes, since Shapiro’s advice is to apply an exclusion only when the goods match its exact product description.

Planning shipments around the Nov. 9 cutoff

The full list of the 178 exclusions sits in the annexes of the Federal Register notice, which is the free and official place to check whether a specific product description is covered. Anyone who buys the goods through an importer can ask the importer which exclusion, if any, applies to each shipment and what date it is expected to enter the country.

Contracts that pass tariff costs through to a buyer deserve a second look before November. A price quoted on the assumption that the exclusion applies can change if a shipment is delayed past Nov. 9.

The most reliable signal will be a new USTR notice in the Federal Register. The agency announced the 2025 extensions through Federal Register notices, and the latest filing on the list, the Oct. 7 amendment, shows the exclusions were still in effect as of this week.

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This article was produced with AI assistance and reviewed by The Financial Wire’s editorial team.

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