📢 Breaking — May 27, 2026
The US Trade Representative is seeking public comment to determine which Chinese goods could qualify for permanent tariff reductions following the May 2026 US-China trade deal. If you import from China, this is the formal process that shapes your tariff rates going forward.
On May 27, 2026, Reuters reported that the US government is opening a public comment period to identify which Chinese goods may be eligible for tariff cuts. This follows the 90-day US-China tariff truce announced in May 2026, which temporarily lowered most tariffs on Chinese goods from 145% down to around 30%. The public comment process is how the USTR collects input from businesses, industry groups, and importers before making any permanent rate changes.
For Amazon FBA sellers, importers, and manufacturers sourcing from China, this is a direct opportunity to influence which product categories get rate relief — and to plan around what may or may not change when the 90-day pause ends in mid-August 2026.
After months of escalation that pushed US tariffs on Chinese goods as high as 145% under IEEPA authority, US and Chinese negotiators reached a 90-day framework agreement in May 2026 in Geneva. The headline number: most tariffs dropped to approximately 10–30% for the duration of the pause, while both sides committed to continued negotiations.
The deal did not eliminate tariffs — it suspended the most punishing escalatory layers while talks continue. Section 301 tariffs (the original trade war tariffs from 2018–2019, ranging from 7.5% to 25%) remained in place on top of the base 10% IEEPA rate, meaning effective rates on many Chinese goods still sit between 17.5% and 35% depending on product category.
| Tariff Layer | Authority | Status (May 2026) | Rate |
|---|---|---|---|
| Base MFN Tariff | Standard | Active | 0–20% |
| Section 301 (List 1–3) | Trade Act 1974 | Active | 7.5–25% |
| Section 301 (List 4A) | Trade Act 1974 | Active | 7.5% |
| IEEPA Escalatory Tariffs | IEEPA | Paused (90-day truce) | 0% (was +115%) |
| Fentanyl-linked surcharge | IEEPA | Active | +20% |
The public comment period now being opened targets the question: which of the remaining tariff layers — particularly Section 301 — should be permanently reduced, and on what goods?
The United States Trade Representative runs formal rulemaking processes under the Administrative Procedure Act before making permanent changes to tariff schedules. A public comment period works like this:
The notice announces which tariff action is under review, the proposed changes, and the window to submit written comments. This is typically published on regulations.gov within a few days of the announcement.
Any importer, industry association, manufacturer, or consumer can submit a comment explaining why a particular product category should — or should not — receive a tariff reduction. Comments are most effective when they include specific HTS codes, dollar figures on tariff impact, and evidence of US economic harm or benefit.
After the comment period closes (typically 30–60 days), USTR staff review all submissions. High-volume, well-documented comment campaigns on specific product categories carry real weight — the Section 301 exclusion processes in 2019–2022 showed this repeatedly.
For importers who experienced serious margin compression when tariffs hit 145%, this public comment period is the formal channel to make the case for your product category.
The USTR typically prioritizes tariff reductions where US businesses can demonstrate: (a) no viable domestic substitute, (b) significant cost pass-through to US consumers, or (c) competitive disadvantage vs. companies sourcing from exempt countries. Based on the 2019–2022 exclusion processes and the current negotiating context, the categories with the strongest case include:
| Product Category | Common HTS Chapters | Current S301 Rate | Cut Likelihood |
|---|---|---|---|
| Consumer electronics (non-smartphones) | 84, 85 | 7.5–25% | Medium |
| Industrial machinery components | 84 | 25% | Medium-High |
| Solar panels / cells | 8541 | 25%+ | Low (political sensitivity) |
| Medical devices & equipment | 90 | 7.5–25% | High |
| Textiles and apparel | 50–63 | 7.5–15% | Low |
| Auto parts (non-EV) | 87 | 25% | Medium |
| Chemical intermediates | 28, 29 | 25% | Medium-High |
Categories where US domestic industry lobbies hard against cuts — steel, aluminum, EVs, solar — are unlikely to see relief regardless of the comment volume. The practical cuts, if they come, will be on intermediate goods with no US domestic equivalent and on consumer goods where price inflation has been politically costly.
Once the Federal Register notice is published (expected within 1–2 weeks of the May 27 announcement), comments can be submitted at regulations.gov. Search for the USTR docket number referenced in the notice.
📋 What makes an effective comment
Be specific about HTS codes. Don't just write "electronics" — cite the 8-digit HTS subheading. USTR reviewers work from the tariff schedule, not from product descriptions.
Quantify the impact. How many dollars in tariffs did your business pay on this product in 2024–2025? What did it cost your customers? Concrete numbers matter more than general arguments.
Document sourcing alternatives. If you've tried Vietnam, Mexico, or India alternatives and found them impractical for your product, explain why. This addresses the "just move your supply chain" counter-argument.
Industry associations (e.g., the Consumer Technology Association, National Retail Federation, or sector-specific groups) often coordinate member submissions to maximize impact. If you're in a relevant industry group, check whether a coordinated comment campaign is already underway.
The 90-day truce from the May 2026 Geneva framework runs until approximately mid-August 2026. Three outcomes are possible at that point:
Scenario 1 — Extension: Both sides agree to extend the pause while negotiations continue. This is the most likely outcome given the complexity of a full deal. The 90-day format was also used in 2019 before it eventually broke down, so markets will be watching for signals in July.
Scenario 2 — Partial permanent deal: Certain tariff layers (likely some IEEPA escalatory tariffs) become permanently reduced or removed on specific goods. This is where the public comment process matters — the categories with strong business advocacy are the ones most likely to land in a partial deal.
Scenario 3 — Reversion: Talks collapse and tariffs snap back toward the escalated levels. The 145% effective rate (or something near it) would return. Given both sides' political incentives, this is the least likely outcome in August, but the risk is non-zero beyond a 12-month horizon.
⚠️ Planning Assumption
Don't price your Q3 and Q4 2026 inventory assuming tariff cuts will be permanent. The comment period is just starting — any formal rate changes would take several months to implement even under an expedited process. Run your landed cost scenarios at current rates plus a best-case scenario, not the other way around.
For anyone sourcing from China and selling through Amazon or other US channels, the public comment period creates two practical action items right now.
Short-term: If your product category is likely to see tariff relief, and you've been holding back orders because of the cost impact, the 90-day window is the time to get inventory in the door at the reduced ~30% effective rate before the situation changes. Calculate your landed cost at current paused rates and make sourcing decisions accordingly.
Medium-term: Submit or support a comment for your product category. Even if you're a small seller, industry association submissions benefit all members. If you sell through categories like electronics accessories, home goods, or industrial supplies, check whether there's a relevant trade group filing comments and consider adding your voice.
The Section 301 tariff refund process from prior years showed that businesses who engaged the USTR process early got better outcomes than those who waited to see what happened. The same logic applies here.
Calculate Your Landed Cost at Current Tariff Rates
Model your import costs with the current paused rates — and run a worst-case scenario before you commit to inventory.
Calculate Now →The exact dates will be published in the Federal Register notice, expected within 1–2 weeks of the May 27, 2026 announcement. Comment periods of this type typically run 30–45 days. Monitor regulations.gov and search for USTR dockets related to Section 301 China tariff modifications.
Anyone can submit a comment — individuals, small businesses, large corporations, trade associations, and consumers. In the 2019–2022 Section 301 exclusion rounds, thousands of small importers submitted individual product exclusion requests. The quality of the submission matters more than the size of the company. Specific HTS codes, documented financial impact, and evidence of no viable domestic alternative are the most persuasive elements.
It depends on the product. The IEEPA escalatory tariffs were paused, bringing most goods down from 145% to roughly 30% effective rates. However, the base MFN tariff, Section 301 tariffs (7.5–25% depending on list), and the 20% fentanyl-linked surcharge remain active. For most manufactured goods from China, the current effective all-in tariff rate is in the 17.5%–35% range. Use the tariff calculator with your specific HTS code for an accurate number.
Even in an expedited scenario, permanent tariff reductions require Federal Register publication, a comment period, and a final rule — a process that typically takes 3–6 months minimum. Realistically, any permanent cuts stemming from this round of comments would not take effect until late 2026 or early 2027. In the meantime, the 90-day truce rates are the operative rates through mid-August 2026.
De minimis changes were handled separately. The May 2026 Executive Order that eliminated the $800 de minimis exemption for China (implemented May 2, 2026) is a distinct policy track from Section 301 tariff rates. The public comment process being opened now is about Section 301 and IEEPA tariff levels on formal commercial imports — not de minimis. See the de minimis China guide for current rules on small-value shipments.