China’s countermeasures in response to US tariffs

Zhiwei Chen
Zhiwei Chen
Senior Counsel, Crowell & Moring LLP, China
Published 15 May 2025

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This recording examines China's countermeasures against US tariffs and what they mean for trade and customs compliance professionals managing US-China supply chains.

Topics covered:

  • The five rounds of Chinese retaliatory tariffs against US-origin goods (February–April 2025), from targeted early measures to across-the-board tariffs reaching 125%, and up to 140% in some sectors once combined with existing duties
  • The interaction between China's new tariffs and existing Section 301 duties and MFN rates
  • Non-tariff countermeasures: export controls on critical minerals, additions to China's Unreliable Entity List and Export Control Entity List (70+ US entities), antitrust and AD/CVD investigations, and suspension of export qualifications for US food and agriculture companies
  • Company adaptation strategies, including "China plus one" and "US plus one" sourcing shifts, valuation adjustments, and unannounced ("silent") Chinese tariff exemptions on 131 tariff lines
  • Export licensing delays and end-use/end-user certification requirements for dual-use items sourced from China
  • China's tiered customs penalty regime for violations, from administrative fines to criminal smuggling, including the duty-evasion threshold that triggers criminal liability
  • China's Anti-Foreign Sanctions Law and Unreliable Entity List enforcement, including the PVH and Illumina sanctions cases and a first Anti-Foreign Sanctions Law damages settlement

For a broader overview of the topic, please watch the full recording. The slides are available in the Resources section.

Please note that this summary was generated using AI, based on the recording and available slides.

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