On August 13, the Trump Administration announced the “next steps” in implementation of the approximately $300 billion in additional tariffs set to go into effect September 1. This fourth round of Section 301 tariffs (known as “List 4”) was originally announced on May 17; however, the USTR has now modified and separated that list into List 4A and List 4B. Several products (25 tariff lines in total) were removed from the lists following the public comment and hearing process on the basis of health, safety, national security and other factors. Most significantly, however, is the delayed implementation of tariffs against List 4B articles until December 15.
The List 4B articles include cell phones, laptop computers, video game consoles, toys, computer monitors, sporting equipment, and certain articles of apparel and footwear. The list itself, coupled with the December 15 effective date, suggests the move was heavily influenced by a desire not to further burden American consumers and businesses during the busy shopping season leading up to the holidays. In fact, President Trump later announced this delay was “for Christmas season, just in case some of the tariffs would have an impact on US customers…” This delayed effective date for List 4B provides US importers a significant stay as they build inventories in preparation for the holiday shopping season.
The tariff lines contained in List 4A (approximately 3,230) will still face the 10% additional tariff effective September 1. Though the USTR has yet to publish the official notice, we are not anticipating an “on the water” exception will be provided as occurred when the List 3 tariffs were increased from 10% to 25%. List 4A goods entered into the US or withdrawn from warehouse for consumption on or after September 1 will be subjected to the additional 10% tariff. The remaining tariff lines of List 4B (approximately 540) will not be subjected to the 10% tariff until December 15.
The lists are available online: