Latest Updates (19 May 2025)
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
TL;DR: What recent U.S. restrictions on China are still in force today?
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:
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- 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:
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- 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:
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- 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.
The details about which U.S. restrictions on China are still in force today
U.S. Government Actions With Official Announcements
1. 10% Reciprocal Tariff
2. Fentanyl-Linked Additional Tariff
3. De-Minimis Tariffs
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:
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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.
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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.
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On 10 February 2025, the U.S. Administration implemented 25% Section 232 additional import tariffs on certain derivative steel articles, effective 12 March 2025.
5. Chinese Entity Blacklisting
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.
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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.
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2 April 2025: The Department of the Treasury imposed sanctions on a Hong Kong-based entity allegedly involved in supporting the Houthi network.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
6. Chips Export Restrictions
*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.
7. Restrictions on Using Chinese Advanced Chips
U.S. Government Actions Without Official Announcements
8. DeepSeek Government Bans
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.
What to keep an eye out for
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 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.
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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.
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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.
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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.
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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.
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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.
2. Ongoing Section 301 Investigations
3. New Trade Defence Investigations
4. Investment Restrictions
5. Other Legislative Proposals