U.S. vs. China: Where Does Chinese Market Access to the U.S. Stand Today?

The blog has been updated to incorporate:

• Two BIS Guidances on Chinese chip controls and diversion risk mitigation
• BIS policy statement regarding export controls on U.S. chips

Since 20 January 2025, the U.S. Administration has announced several new restrictions on China which remain in force today:

1. 10% Reciprocal Tariff: Effective 14 May 2025, the U.S. committed to cutting the reciprocal tariffs on Chinese imports from 125% to 10%. This temporary 90-day measure follows U.S.-China negotiations in Geneva.

2. Fentanyl-Linked Additional Tariff:  Since March 2025, the U.S. has applied a 20% additional tariff on certain Chinese imports to address the synthetic opioid crisis.

3. De-Minimis Tariffs: Effective 14 May 2025, duties on low-value imports from China and Hong Kong were reduced to 54% (from 120%) or USD 100 (from a USD 200 hike set for 1 June 2025) per package.

4. Section 232 Enacted Tariffs on Steel, Aluminium, and Autos: Between February and April 2025, the U.S. imposed 25% tariffs under Section 232 on several products. Tariff stacking is permitted between the steel and aluminium tariffs, but auto-related tariffs take precedence and prevent the application of additional steel or aluminium duties on the same products:

• • Automobile parts, including engines, transmissions, and electronics (from 3 May 2025)
  • Passenger vehicles and light trucks (from 3 April 2025)
  • Derivative steel articles (from 12 March 2025)
  • Aluminium and derivative aluminium products (from 12 March 2025; increased from 10% to 25%; new duties on derivatives)

5. Chinese Entity Blacklisting: Between February and April 2025, the U.S. imposed sanctions on numerous Chinese and Hong Kong-based entities for allegedly supporting Iran's military and oil industries, advancing quantum technologies, developing advanced AI models, and other activities deemed contrary to U.S. national security interests.

6. Chips Export Restrictions: On 13 May 2025, the Bureau of Industry and Security (BIS) published considerations regarding what might trigger export licenses on advanced chips to D:5 countries (including China). Earlier, the U.S. government imposed export license requirements on chipmakers Intel, AMD, and NVIDIA for shipments of advanced AI processors to China, Hong Kong, and Macau.

7. Restrictions on Using Chinese Advanced Chips: On 13 May 2025, the Bureau of Industry and Security (BIS) published two guidelines. One contains an industry warning against using Chinese advanced chips that violate export controls, and another provides red flags and due diligence steps to prevent controlled technology diversion.

Furthermore, these actions have appeared in various reports, although they have not been officially confirmed by the U.S. government:

8. DeepSeek Bans: Between January and March 2025, several U.S. government agencies prohibited the use of Chinese DeepSeek AI applications on government devices, with similar restrictions implemented across multiple states.

In addition, future restrictions might be imposed under:

1. Ongoing Section 232 Investigations: Between February and May 2025, the U.S. launched new Section 232 investigations into potential national security risks posed by imports of:

• • Commercial aircraft and jet engines (1 May 2025)
  • Trucks and truck parts (22 April 2025)
  • Critical minerals and their derivatives (15 April 2025)
  • Pharmaceuticals and ingredients (1 April 2025)
  • Semiconductors and manufacturing equipment (1 April 2025)
  • Lumber and timber products (1 March 2025)
  • Copper (25 February 2025)

2. Ongoing Section 301 Investigations: The U.S. has launched new Section 301 investigations into the unfair trading practices related to:

• • Foreign digital services taxes targeting U.S. firms (Potential investigation - 21 February 2025)
  • China’s maritime, logistics, and shipbuilding sectors (launched 17 April 2024)

3. New Trade Defence Investigations: The U.S. has initiated antidumping and countervailing investigations on imports of fibreglass door panels and polypropylene corrugated boxes from China following applications from American industry coalitions.

4. Investment Restrictions: The "America First Investment Policy" memorandum outlines intentions to expand restrictions on investments from China in strategic sectors and to enact restrictions on outbound U.S. investments to China.

5. Other Legislative Proposals: In March 2025, the U.S. House of Representatives approved the "Decoupling from Foreign Adversarial Battery Dependence Act", which aims to prohibit the Department of Homeland Security from purchasing batteries manufactured by six specified Chinese companies.

• On 12 May 2025, the U.S. committed to cutting the reciprocal tariffs on Chinese imports from 125% to 10%. This temporary 90-day measure follows U.S.-China negotiations in Geneva.
• 11 April 2025: The White House announced that certain electronic items are exempt from the reciprocal tariffs. This exemption applies to China as well as other jurisdictions.  

• On 3 March 2025, the U.S. raised additional tariffs on certain Chinese imports from 10% to 20% to address the synthetic opioid crisis.

• Late on 12 May 2025, a new Executive Order was published decreasing the duties applicable to low-value imports from China and Hong Kong. Effective 14 May, these imports will now be subject to either a 54% ad valorem duty or a flat-rate duty of USD 100 per package.

• Previously, as of 1 June 2025, these imports were scheduled to face a 120% ad valorem duty or a flat-rate duty of USD 200 per package.

• During May 2025, these imports face a 120% ad valorem duty or USD 100 per package. 

Between February and April 2025, the U.S. imposed 25% tariffs under Section 232 on several products. Tariff stacking is permitted between the steel and aluminium tariffs, but auto-related tariffs take precedence and prevent the application of additional steel or aluminium duties on the same products: 

• On 26 March 2025, the U.S. Administration imposed a 25% additional tariffs on passenger vehicles and light trucks, taking effect on 3 April 2025, as well as a 25% additional tariff on imports of automobile parts, including engines, transmissions, and electronics, effective 3 May 2025.

• On 11 February 2025, the U.S. Administration increased Section 232 additional import tariffs on aluminium and derivative aluminium products from 10% to 25% (new duties on derivatives), effective 12 March 2025.

• On 10 February 2025, the U.S. Administration implemented 25% Section 232 additional import tariffs on certain derivative steel articles, effective 12 March 2025. 

Between February and April 2025, the U.S. imposed sanctions on various entities from China for alleged activities contrary to U.S. national security interests:

• 13 May 2025: The Department of the Treasury sanctioned three Chinese entities reportedly involved in supporting “Iran's illicit international oil trade”, which allegedly funds Iran's military and its regional activities.

• 29 April 2025: The United States sanctioned entities from Hong Kong and China for procuring ballistic missile propellant ingredients for Iran's Islamic Revolutionary Guard Corps.

• 2 April 2025: The Department of the Treasury imposed sanctions on a Hong Kong-based entity allegedly involved in supporting the Houthi network. 

• 26 March 2025: The Bureau of Industry and Security (BIS) added 42 Chinese entities to the Entity List for allegedly acting contrary to the national security and foreign policy interests of the United States. These entities were added to deter the advancement of Chinese quantum technologies and military modernisation efforts. 

• 26 March 2025: The U.S. Bureau of Industry and Security (BIS) added 11 Chinese entities and 1 Taiwanese entity to the Entity List for allegedly acting contrary to the national security and foreign policy interests of the United States due to their alleged involvement in activities viewed as supporting China's military modernisation. These include efforts to acquire or attempt to acquire U.S.-origin items for developing advanced AI models, computing chips, and exascale supercomputers.

• 20 March 2025: The Department of the Treasury imposed sanctions on entities allegedly supporting Iran's oil industry. These entities are based in Hong Kong, China, and other countries.

• 13 March 2025: The Department of the Treasury imposed sanctions on 15 ship management entities in multiple jurisdictions for their alleged ownership or operation of vessels that have delivered Iranian oil to China or lifted Iranian oil from storage in Dalian, China.

• 5 March 2025: The Department of the Treasury sanctioned a Chinese entity, Shanghai Heiying Information Technology Company Ltd, as part of measures against cyber activities compromising U.S. national security.

• 26 February 2025: The Department of the Treasury sanctioned six entities based in Hong Kong and China, allegedly engaged in the procurement of unmanned aerial vehicle (UAV) components on behalf of Iran. 

• 24 February 2025: The Department of the Treasury sanctioned 15 entities in multiple jurisdictions, including China, for alleged involvement in the sale and transportation of Iranian petroleum-related products.

• 6 February 2025: The Department of the Treasury sanctioned an international network allegedly facilitating the shipment of Iranian crude oil to China. These entities are registered in Hong Kong, India, Iran, the Marshall Islands and Seychelles.

• 13 May 2025: The Bureau of Industry and Security (BIS) published a policy statement regarding the application of export controls to advanced computing integrated circuits (chips) used for AI model training. It identifies three export scenarios that may trigger license requirements for D:5 countries*. 

• 16 April 2025: The US government reportedly imposed an export license requirement on Intel for shipments of certain advanced artificial intelligence processors to China.

• 15 April 2025: US chipmaker Advanced Micro Devices Inc (AMD) announced that the US government imposed an export license requirement for shipments of its MI308 products to China (including Hong Kong and Macau).

• 9 April 2025: US chipmaker NVIDIA Corporation stated that the US government imposed an export license requirement for shipments of its H20 integrated circuits to China (including Hong Kong and Macau).

*Afghanistan, Armenia, Azerbaijan, Belarus, Cambodia, China (including Hong Kong), Georgia, Iraq, Kazakhstan, North Korea, Kyrgyzstan, Laos, Libya, Macau, Mongolia, Russia, Syria, Tajikistan, Turkmenistan, Ukraine (Crimea Region only), Uzbekistan, Venezuela, and Vietnam.

• 13 May 2025: The Bureau of Industry and Security (BIS) published two guidances, namely the "Guidance on Application of General Prohibition 10 (GP10) to People's Republic of China (PRC) Advanced-Computing Integrated Circuits (ICs)" and the "Industry Guidance to Prevent Diversion of Advanced Computing Integrated Circuits". The documents highlight that violators of US rules face criminal and administrative penalties.
  • The first guidance warns that using Chinese advanced chips (especially Huawei Ascend 910B/C/D) likely violates EAR General Prohibition 10, as they were developed contrary to U.S. export controls.
  • The second guidance outlines eleven red flags and seven due diligence measures to prevent diversion, including scrutinising incorporation dates and infrastructure needs. 

• 18 March 2025: According to consistent media reports, the US Commerce Department prohibited the use of the Chinese DeepSeek Artificial Intelligence application by its employees on government-issued devices.

• 31 January 2025: According to consistent media reports, the National Aeronautics and Space Administration (NASA) prohibited the use of Chinese DeepSeek Artificial Intelligence application by employees and blocked the access to the platform from its systems.

In addition to the federal agency actions listed above, several U.S. states —such as West Virginia, Kansas, North Dakota, Alabama, Oklahoma, South Dakota, Tennessee, Pennsylvania, Iowa, Virginia, New York, and Texas— have reportedly taken action against DeepSeek and other Chinese applications and platforms.

Between February and May 2025, the U.S. launched new Section 232 investigations into potential national security risks posed by imports of the following goods. Based on the findings, the U.S. Administration may introduce tariffs on the following products:

• On 1 May 2025, the U.S. Department of Commerce initiated a Section 232 investigation to assess the national security impacts of importing commercial aircraft and jet engines, and their parts. Commerce is required to deliver its findings within 270 days.

• On 22 April 2025, the US Department of Commerce initiated a Section 232 investigation to assess the national security impacts of imports of trucks, truck parts, and their derivative products. Commerce is required to deliver its findings by 20 January 2026.

• On 15 April 2025, the U.S. Administration directed the Secretary of Commerce to initiate an investigation under Section 232 national security risks posed by imports of processed critical minerals and derivative products.

• On 1 April 2025, the US Department of Commerce initiated a Section 232 investigation to assess the national security impacts of importing pharmaceuticals, related ingredients and derivative products. Commerce is required to deliver its findings by 27 December 2025.

• On 1 April 2025, the US Department of Commerce initiated a Section 232 investigation to assess the national security impacts of importing semiconductors, semiconductor manufacturing equipment (SME), and related derivative products. Commerce is required to deliver its findings by 27 December 2025.

• On 1 March 2025, the U.S. Administration directed the Secretary of Commerce to initiate a Section 232 investigation to assess the national security impacts of importing timber, lumber, and derivative products.   

• On 25 February 2025, the U.S. Administration directed the Secretary of Commerce to initiate a Section 232 investigation to assess the national security impacts of importing copper, including raw, refined, and scrap copper, as well as copper alloys and derivative products. Commerce is required to deliver its findings within 270 days. 

• On 21 February 2025, the U.S. Administration directed U.S. agencies to counter foreign taxes and regulations that allegedly harm American technology companies. The directive includes potential trade investigations and tariffs.

• On 17 April 2024, the USTR initiated a Section 301 investigation into the alleged acts, policies, and practices of China targeting the maritime, logistics, and shipbuilding sectors. As a result of the investigation, the US Administration may impose countermeasures.

• 9 April 2025: The U.S. initiated an antidumping investigation and an anti-subsidy investigation on imports of fibreglass door panels from China. These investigations follow the application by the American Fiberglass Door Coalition.

• 7 April 2025: The U.S. initiated an antidumping investigation on imports of polypropylene corrugated boxes from China and Vietnam and an anti-subsidy investigation on imports of polypropylene corrugated boxes from China. These investigations follow the application lodged by CoolSeal USA Inc, Inteplast Group Corporation, SeaCa Plastic Packaging, and Technology Container Corp.

• 21 February 2025: The U.S. Administration issued a memorandum on the America First Investment Policy. The memorandum outlines the Administration's intention to expand restrictions on investments from China, persons affiliated with China and "other foreign adversaries or threat actors" to protect U.S. businesses involved in agriculture, critical infrastructure, energy, security, raw materials and "other strategic sectors". The memorandum also outlines the U.S. government's intention to enact restrictions on outbound investments to China.

• 11 March 2025: The U.S. House of Representatives approved a bill titled "Decoupling from Foreign Adversarial Battery Dependence Act". The bill was introduced a day before in the U.S. Congress. The bill aims to prohibit the Department of Homeland Security from the United States purchasing batteries manufactured by six Chinese companies. The targeted companies are Contemporary Amperex Technology Co. Ltd. (CATL), BYD, Envision Energy, EVE Energy, Hithium Energy Storage Technology, and Gotion High-tech.

This blog will be updated on an ongoing basis. 

A similar blog outlining Chinese measures in force today is available here.