In recent years, China-US trade relations have been volatile, with frequent policy adjustments. Their complexity and rapidly changing nature have brought unprecedented challenges to trade enterprises between the two countries. Especially for those engaged in...Importing US goods to ChinaandExporting products from the US to ChinaFor various market entities, how to accurately grasp and respond toreciprocal tariffsarising from trade frictions, and seek possibletariff exemptionpathways has become crucial for sustainable and stable business operations. In this environment of uncertainty, professional policy interpretation and compliant application procedures are particularly important.

Facing ongoing trade frictions, the Chinese government has established corresponding tariff exclusion mechanisms to balance trade impacts, ensure stability in domestic industrial and supply chains, and meet needs in specific sectors. While we cannot provide a universal answer to whether reciprocal tariffs can be exempted - as each case requires specific analysis - we can share that through actively utilizing officially established channels, enterprises do have opportunities to obtain tariff exemptions for specific goods. In our past services, we have successfully assisted clients multiple times in obtaining valuable tariff exemptions for their imported US goods through the Exclusion Application System for Additional Tariffs on US Goods.

To help more enterprises understand this pathway, we hereby highlight key information about the previously established Exclusion Application System for Additional Tariffs on US Goods:

1. System background and entry point:
   This system was established and managed by Chinas State Council Tariff Commission, aiming to allow eligible Chinese enterprises to apply for exclusion of additional tariffs on US-origin goods that are either planned for import or already imported and listed in the additional tariff catalog. Enterprises can typically find the application portal and related notices through official designated websites such as the Ministry of Finance Tariff Department or China Council for the Promotion of International Trade. This mechanism reflects the policy orientation of maintaining overall trade positions while addressing practical difficulties of specific industries and enterprises.
2. Applicant eligibility:
   Generally, applicants are enterprises registered in China with actual importExporting products from the US to Chinaneeds, or industry associations representing sector interests. These entities need to prove that their imported goods are important for domestic production, technological advancement, or livelihood security, or demonstrate significant difficulties in sourcing from non-US regions.
3. Required application materials:
   Applytariff exemptionTypically, a comprehensive set of materials needs to be submitted. The specific list will be refined with each batch of exclusion declaration notice, but the core content generally includes:
   • Detailed information of the goods applying for exclusion (such as 8-digit HS code, product name, specifications, intended use, etc.).
   • A statement of reasons for applying for exclusion, focusing on the substitutability (or non-substitutability) of the goods, domestic market supply conditions, impact on the applying enterprise and downstream industries, and reasons for inability to procure from non-US regions.
   • Relevant trade documents such as import contracts, invoices, and bills of lading (if imports have already occurred).
   • An introduction to the basic situation of the enterprise and relevant business qualification certificates.
   • Other supplementary materials required according to specific notices.
4. Review and Implementation Process:
   After submitting the application, the Office of the Customs Tariff Commission of the State Council, together with relevant departments, will review the application materials according to established procedures. The review process will comprehensively consider factors such as domestic industrial development needs, technological advancement requirements, market supply structure, and impact on related industries and public interests. Goods that pass the review will be included in the exclusion list and publicly announced. For goods that have been approved for exclusion, during the exclusion validity period:
   • For goods not yet imported, the additional tariffs imposed as countermeasures against US Section 301 measures will no longer be levied from the effective date of the exclusion list.
   • For tariffs already imposed, eligible import enterprises can apply for tax refunds according to regulations.

These successful cases have not only alleviated the cost pressure caused byreciprocal tariffsfor our clients, ensured the stability of their supply chains, but also demonstrated the flexibility and specificity of Chinas policies in the complex international trade environment.

As a key enterprise with years of experience in import and export, Zongdaifu has not only accumulated rich practical experience in international trade but also maintained continuous attention and deep understanding of international trade policies and regulations, including those related to China-US trade. We are well aware that in the current situation, timely access to and correct interpretation of the latest tariff policies are crucial for enterprises engaged inImporting US goods to ChinaandExporting products from the US to Chinabusiness.

Therefore, we solemnly promise that our company has a professional team and capabilities to provide the latest policy consultations onreciprocal tariffsandtariff exemptionFor the latest policy consultations, utilize official channels to secure the most current tariff preferential policies. We are committed to helping clients navigate risks, reduce costs, seize opportunities, and achieve sustainable development in complex trade environments. Should your company have related needs, please feel free to contact us for professional support and services.