U.S.-China Tariffs Update – December 3, 2025

December 3, 2025

Following the U.S.-China trade talks in Malaysia and the meeting between Presidents Trump and Xi on October 30, 2025, in South Korea, the two countries have agreed to a series of mutual actions to reduce trade barriers between the U.S. and China starting from November 10, 2025.

China agreed to:

• Terminate the additional 15% tariff on imported chicken, wheat, corn and cotton from the United States and the 10% tariff on sorghum, soybeans, pork, beef, aquatic products, fruits, vegetables and dairy products from the United States that had been imposed in March 2025;
• Continue to suspend the 24% additional tariff on imports from the United States for one year while retaining the 10% rate;
• Suspend until November 10, 2026, the export restrictions under MOFCOM & Customs Public Notices No. 55 (superhard materials items), No. 56 (rare earths production equipment and materials), No. 57 (rare earths) and No. 58 (Lithium-ion batteries and synthetic graphite anodes) and under MOFCOM Public Notices No. 61 (export controls on rare earth items) and No. 62 (export controls on rare earth technologies);
• Suspend until November 27, 2026, the export restrictions on gallium, germanium, antimony and graphite under MOFCOM Public Notice No. 46 of 2024 dated December 3, 2024;
• Suspend its countermeasures on five U.S. subsidiaries of Hanwha Ocean Co., Ltd. for one year; and
• Suspend the retaliatory special port fees and investigation of maritime, logistics and shipbuilding sectors relating to the U.S.'s announcement of a Section 301 investigation under Chinese Ministry of Transport Public Notice No. 54 (special port fees) and relevant implementing measures and MOT Public Notice No. 55 (investigation) for one year.

In addition to the removal and suspension of the above tariff and non-tariff countermeasures, China also agreed to take measures to end the flow of fentanyl to the U.S.; purchase U.S. soybeans during the last two months of 2025, and 2026, 2027 and 2028 and resume purchases of U.S. sorghum and hardwood logs; and terminate its various investigations targeting U.S. companies in the semiconductor supply chain, including its antitrust, anti-monopoly and anti-dumping investigations.

The U.S. agreed to:

• Lower the "fentanyl tariffs" on Chinese imports by 10%, effective November 10, 2025, until November 10, 2026;
• Further extend until November 10, 2026, the Section 301 tariff exclusions that had been scheduled to expire on November 29, 2025;
• Suspend until November 10, 2026, the implementation of the interim final rule entitled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities; and
• Suspend until November 10, 2026, implementation of the responsive actions taken pursuant to the Section 301 investigation on China's Targeting the Maritime, Logistics and Shipbuilding Sectors for Dominance.

The U.S. actions were taken pursuant to Executive Order 14358: Modifying Reciprocal Tariff Rates Consistent With the Economic and Trade Arrangement Between the United States and the People's Republic of China and Executive Order 14357: Modifying Duties Addressing the Synthetic Opioid Supply Chain in the People's Republic of China, both of which were signed by President Trump on November 4, 2025.

We have been monitoring the development of the U.S.-China tariff and non-tariff measures and worked closely with many of our clients on these issues. For more information, please contact Robert Oberlies, Michael Meagher or Jackson Guo.