China’s Retaliatory Actions to Trump 2.0 Tariffs

At a Glance

• A tariff on products from China announced by the Trump administration in February initiated an exchange of retaliatory tariff increases and other actions between the U.S. and the Chinese government.
• While many of China’s trade regulation changes in recent months are in direct response to the U.S. government’s tariff actions, there are several non-targeted developments that may affect U.S. clients.

In response to the Trump administration’s announcement of a fentanyl-related tariff on products from China at 10%, China took the following actions on February 4, 2025:

• New Tariff: PRC State Council Tariff Commission announced new tariffs on the following imported merchandise originating from the U.S., which took effect on Feb 10, 2025 (Tariff Commission Announcement [2025] No. 1):
  • Additional 15% tariff on coal and liquefied natural gas as specified in Annex 1.2.
  • Additional 10% tariff on crude oil, agricultural machinery, large displacement automobiles and pickups as specified in Annex 2.
• Unreliable Entity List: PRC Ministry of Commerce (MOFCOM) announced to add two U.S. entities into Unreliable Entity List (Unreliable Entity List Working Commission [2025] No. 4). For entities identified in this list, the government may, at its discretion, take one or more of the following measures, which may be decided in a later announcement:
  • Restricting or banning their engagement in the import to and export from China.
  • Restricting or banning their investment in China.
  • Restricting or banning the entry of their relevant persons and means of transportation in China.
  • Restricting or canceling the work permit, stay or residential qualification of their relevant persons in China.
  • Imposing a fine of a corresponding amount as appropriate.
  • Other necessary measures as needed.
• Anti-Monopoly Investigation of Google: China’s Administration of Market Regulation (SAMR) announced an anti-monopoly investigation into Google Inc (SMAR Decision on Initiating the Investigations on Google Inc’s potential violation of Anti-monopoly Law). Google’s business in China includes advertising and the Android operating system. Although no further details were disclosed in the announcement, it is generally believed that the investigation will focus on Android, as SMAR mentioned multiple times in previous articles that Google’s work with the operating system has monopolized and violated competition regulations.
• WTO Complaint: China requested WTO dispute consultations with the United States regarding the fentanyl-related tariffs on Feb 5. (WTO | 2025 News items - China initiates WTO dispute complaint regarding US tariff measures)
• Five Minerals Added to Export Control List: MOFCOM and the General Administration of Customs of China (GACC) announced the addition of five minerals and their related products to the PRC Dual-Use Export Control List, subject to export control licensing administration (MOFCOM GACC Announcement [2025] No. 10). Although this development is not specifically targeting any special region or country, we have noticed the restrictions have material impact on U.S. clients’ business.
  • Tungsten
  • Tellurium
  • Bismuth
  • Molybdenum
  • Indium

In response to the Trump administration’s increase of the fentanyl-related tariff from 10% to 20%, China took the following actions on March 4, 2025:

• New Tariff: PRC State Council Tariff Commission announced new tariffs on imported merchandise originating from the U.S., which took effect on March 10, 2025 (Tariff Commission Announcement [2025] No. 2):
  • Additional 15% tariff on chicken, wheat, corn, and cotton as specified in Annex 1.
  • Additional 10% tariff on sorghum, soybeans, pork, beef, aquatic products, fruits, vegetables and dairy products as specified in Annex 2.
• Export Control Entity List: MOFCOM announced the addition of 15 U.S. entities to the Export Control Entity List for national security purposes (MOFCOM Announcement [2025] No. 13). Any export of dual-use items to entities identified under the Export Control Entity List are prohibited and should be stopped immediately unless specially approved by MOFCOM.
• Unreliable Entity List: MOFCOM announced the addition of 10 U.S. entities to the Unreliable List (Unreliable Entity List Working Commission [2025] No. 5). Any export and import activities or new investment by those entities in China are prohibited.
• Ban on Imports of Logs: GACC announced the suspension of log imports from the U.S., citing the need to protect China’s national agriculture and forestry production and ecological security (GACC Announcement [2025] No. 29).
• Suspension of Soybean Import License: GACC announced the suspension of soybean import licenses for three major U.S. exporters (GACC Announcement [2025] No. 30).
• Anti-Circumvention Investigation on U.S. Fiber Optical Products: MOFCOM initiated an anti-circumvention investigation of U.S. Fiber Optical Products (MOFCOM Announcement [2025] No. 14). Notably, this is the first anti-circumvention investigation by the Chinese government. The petition alleged the U.S. exporters may have circumvented China's anti-dumping measures on U.S. non-dispersion-shifted single-mode optical fiber products by exporting the relevant cut-off wavelength-shifted single-mode fibers to China.
• Revised WTO Complaint: China submitted a revised request for WTO dispute consultations with the United States related to the fentanyl tariff on March 5 (WTO | 2025 News items - China initiates WTO dispute complaint regarding US tariff measures).

In response to the Trump administration’s announcement of a reciprocal tariff on products from China at 34%, China took the following actions on April 4, 2025:

• New Tariff: The PRC State Council Tariff Commission announced an additional 34% tariff on all imported merchandise originating from the U.S., which took effect on April 10, 2025 (Tariff Commission Announcement [2025] No. 4). Any merchandise shipped before April 10 EST and arriving before noon on May 13 EST is exempt.
• Export Control Entity List: MOFCOM announced the addition of 16 U.S. entities to the Export Control Entity List (MOFCOM Announcement [2025] No. 21). Any export of dual-use items to entities identified under the Export Control Entity List are prohibited and shall be stopped immediately unless specially approved by MOFCOM.
• Unreliable Entity List: MOFCOM announced the addition of 11 U.S. entities to the Unreliable List (Unreliable Entity List Working Commission [2025] No. 7). Any export and import activities or new investment in China by those entities are prohibited.
• Suspension of Import License: GACC announced the suspension of the import licenses for sorghum, PMBM (Poultry meat and bone meal) and poultry products of several U.S. exporters (GACC Announcement [2025] No.54 & GACC Announcement [2025] No. 55).
• New AD Investigation: MOFCOM announced the initiation of anti-dumping investigations on CT machine x-ray tube assemblies from the U.S. and India (MOFCOM Announcement [2025] No. 20).  
• Anti-Monopoly Investigation of DuPont China Group: SAMR announced an anti-monopoly investigation of DuPont China Group (SMAR Decision on Initiating the Investigations on DuPont China Group’s potential violation of Anti-monopoly Law).

The following actions taken by the Chinese government on April 4 were not intended to target a specific country or region, but may have material impact to U.S. clients:

• Seven Rare Earth Products Added to Export Control List: MOFCOM and GACC announced the addition of seven rare earth and related products to the PRC Dual-Use Export Control List (MOFCOM GACC Announcement 2025 No. 18):
  • Samarium (Sm)
  • Gadolinium (Gd)
  • Terbium (Tb)
  • Dysprosium (Dy)
  • Lutetium (Lu)
  • Scandium (Sc)
  • Yttrium (Y)
• Trade Remedy – Industry Competitiveness Investigation: MOFCOM initiated an industry competitiveness investigation on CT machine x-ray tube assemblies in addition to the AD investigation mentioned above (MOFCOM Announcement [2025] No. 19). Products covered include medical x-ray CT tubes for use in 16-slice and above computed tomography (CT) equipment, as well as tube cores compatible with the above tubes (including standalone cores, semi-finished tubes and complete tubes in various forms).  

  Notably, this is the first time China launched an industry competitiveness investigation. According to PRC Foreign Trade Law 2022, if the import of products causes serious damage or threat of serious damage, the government may take “necessary protectional measures” to eliminate or decrease the damages or threat of damages even if no dumping or subsidy margin is found. The vauge provisions announced may grant the government wide discretion.

In response to the Trump administration’s announcement increasing the reciprocal tariff on China from 34% to 84%, China took the following actions on April 9, 2025:

• Additional Tariff: The PRC State Council Tariff Commission announced the increase of the additional tariff rate from 34% to 84%, which means imposing an additional 84% tariff on all goods imported since April 10, 2025 (Tariff Commission Announcement [2025] No. 5). All other provisions in Announcement No. 4 stayed the same.
• Export Control Entity List: MOFCOM announced the addition of 12 U.S. entities to the Export Control Entity List (MOFCOM Announcement [2025] No. 22). Export of dual-use items to those entities are prohibited. Any export of dual-use items to those entities shall stop immediately. If any export is needed under special circumstance, the exporter shall apply to the MOFCOM. 
• Unreliable Entity List: MOFCOM announced the addition of six U.S. entities to the Unreliable List (Unreliable Entity List Working Mechanism [2005] No. 8). Any export and import activities related to China by those entities are prohibited. Any new investments by those entities in China are prohibited.
• WTO Complaint - China requested WTO dispute consultations with the United States concerning the reciprocal tariff on April 8, 2025 (WTO | 2025 News items - China initiates WTO dispute regarding US “reciprocal tariffs”).

In addition to the above, certain public media accounts with government background speculate that China is also considering the following retaliation measures:

• Additional tariff on agriculture products such as soybeans and sorghum
• Ban on import of U.S. poultry imports
• Suspension of China-U.S. fentanyl cooperation
• More countermeasures in trade business, such as restriction on procurement, providing legal consultation services, etc.
• Ban or reduction of import of American movies
• Investigations on the intellectual property benefits obtained by U.S. companies in China

In response to the Trump administration’s announcement increasing the reciprocal tariff from 84% to 125% on April 11, 2025, China announced a new tariff:

• New Tariff: The PRC State Council Tariff Commission announced an increase of its retaliation tariff from 84% to 125% on all U.S. merchandise, effective since April 12, 2025 (Tariff Commission Announcement [2025] No. 6). Any product shipped before April 10, 2025, and imported before noon of May 13 EST are exempted.

The tariff commission further stated in its announcement that, “at the current tariff level, there is no market acceptance for U.S. goods exported to China. If the U.S. continues to play the tariff numbers game, China will ignore it. However, if the U.S. insists on continuing to substantially infringe on China's interests, China will resolutely counterattack and fight to the end.”

Legal Clerk Lucy Zhang contributed to the preparation of this article.