January 2026 U.S. Tariff Roundup: Developments and Opportunities - Davis Wright Tremaine

The U.S. Trade Representative (USTR) has announced significant proposed modifications to Section 301 tariffs on goods from China, following a mandated four-year review. This review, triggered by requests from domestic industries, aims to address concerns regarding China's technology transfer policies, intellectual property, and innovation. The proposed changes include substantial tariff increases on a range of products and the introduction of new tariffs on others, primarily targeting strategic sectors.

Importers of various products from China are directly affected by these potential changes. Most notably, the proposed tariff on Electric Vehicles (EVs) is set to quadruple from 25% to 100%. Other critical sectors facing significant increases include lithium-ion EV batteries, lithium-ion non-EV batteries, and battery parts, all proposed to rise from 7.5% to 25%. These proposed tariff adjustments are generally slated to take effect on January 1, 2026, unless otherwise specified.

Further proposed increases target key materials and medical supplies. Natural graphite and permanent magnets, currently tariff-free, are proposed to face a new 25% tariff. Solar cells (silicon photovoltaic) could see their tariff rate double from 25% to 50%. Essential medical items such as syringes and needles are proposed to jump from 0% to 50%, while certain Personal Protective Equipment (PPE), including respirators and face masks, would increase from 0% to 25%. Additionally, medical gloves are proposed to rise from 7.5% to 25%, and tariffs on specific steel and aluminum products are set to increase to 25% from their current rates of 0-7.5%.

Given these impending changes, importers should proactively review their supply chains and assess their reliance on Chinese-origin goods, particularly those identified in the proposed tariff modifications. It is crucial to calculate the potential impact of these increased costs on business operations and explore alternative sourcing strategies from non-Chinese suppliers. Engaging with the USTR during any open public comment periods can provide an opportunity to voice concerns or support. Furthermore, continuous monitoring of official announcements and consulting with trade counsel are recommended to navigate these complex developments effectively and ensure ongoing compliance.