A Must-Read for Lithium Battery & Electronics Importers: Section 301 Tariff Review on China Is Now Underway

Background: An Eight-Year Tariff Mechanism Enters Its Next Review Cycle 

On May 6, 2026, the Office of the United States Trade Representative (USTR) formally initiated the second four-year statutory review of Section 301 tariffs on Chinese imports via a Federal Register notice. These tariffs, originally enacted in two tranches during the first Trump administration in 2018, cover over 500 tariff subheadings at a 25% rate. 

After the first review, the Biden administration kept the tariffs and pushed rates higher across several strategic sectors. Effective September 27, 2024, EV tariffs climbed from 25% to 100%. EV lithium battery tariffs moved from 7.5% to 25% on the same date. Non-EV lithium battery tariffs reached 25% as of January 1, 2026. USTR's own review report acknowledged the tariffs have produced measurable results, redirecting U.S. sourcing away from China and toward allies and trade partners. 

Current Process: Key Deadlines Are Approaching 

The review runs in two phases. In phase one, domestic industries that benefit from the tariffs must file continuation requests at least 60 days before the respective anniversaries, with key deadlines falling on May 7 and July 5. Provided at least one request is received, the USTR will open a second phase for public comment on the tariffs' economic effectiveness. 

According to Retail Industry Leaders Association (RILA), a Section 301 investigation typically reaches a final determination within 12 months of initiation. Once measures take effect, they require no Congressional approval. They can stay in place all the way through the next review cycle. 

Baker Tilly's Managing Director of Global Trade Advisory Services, Pete Mento, put it plainly. Section 301 tariffs are no longer a temporary trade measure. They are now built into sourcing strategies, pricing models, and long-term supply chain decisions. 

The Broad Context: Section 301 as the Cornerstone of U.S. Tariff Policy 

On February 20, 2026, the U.S. Supreme Court ruled 6-3 that global tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were unconstitutional. In response, the administration invoked Section 122 of the Trade Act of 1974 to implement a 150-day, 10% provisional global tariff, set to expire on July 24, 2026. 

RILA notes that Section 301 stands on more durable legal ground than IEEPA. Its retaliatory tools also go further than tariffs alone. 

In March 2026, the Trump administration opened two new Section 301 investigations. One targets manufacturing overcapacity across 16 economies. The other looks at forced labor compliance among 60 trading partners. Both are expected to conclude by July 24, 2026, the same date the Section 122 tariffs expire. 

The Diplomatic Variable: The Trump-Xi Beijing Summit 

The same week USTR announced the review, President Trump is set to visit Beijing on May 14 and 15 for a summit with President Xi Jinping. Foreign Policy reports this will be Trump's first trip to China in nearly a decade. The two sides have held six rounds of trade consultations since 2025. The most recent, in Paris, touched on a proposed Board of Trade framework covering agriculture, energy, and aerospace. 

Brookings Institution analysts note that USTR Jamieson Greer has framed the trip around one word: stability. This is not a relationship reset. The tariff truce from the 2025 APEC summit expires November 10, 2026. What comes out of Beijing this week will set the tone for those renewal talks. 

What This Means for Cross-Border Importers 

For brands and businesses importing consumer electronics and lithium batteries into the U.S., the tariff exposure is real and already in effect. Under USTR's final rate modification, consumer electronics and charging products carry a 25% Section 301 tariff. Lithium batteries, UN3480 and UN3481 alike, sit at 25%. EVs face 100%. A 10% Section 122 tariff stacks on top of all of that, expiring July 24, 2026. 

RILA points out that brands and retailers typically lock in sourcing and supply chain decisions months or even years ahead. With active tariff threats spanning dozens of markets and product categories, planning windows are shrinking. Forward visibility is thin. 

Localized Operations as a Buffer Against Policy Uncertainty 

RILA notes that companies are shifting supply chain priorities away from cost optimization alone. System capability, fulfillment reliability, and multi-channel inventory management are now the focus. 

FBD GROUPS is a U.S.-based one-stop 3PL provider specializing in Hazmat-classified products.

Certified under DOT, IATA, ISO 9001, ISO 14001, and OSHA standards, FBD GROUPS runs over 900,000 square feet of warehouse space across California, Texas, and Georgia, with support teams in Taipei and Shenzhen. We cover the full logistics chain: U.S. customs clearance, local warehousing, order fulfillment, last-mile delivery, reverse logistics, and RMA repair management. 

To find out how FBD GROUPS can keep your supply chain stable and compliant through shifting tariff policy, get in touch with our team.