China Retaliates with Tariffs and Non-Tariff Measures in Response to Trump's Additional Tariffs

On March 4, 2025, China announced it would impose additional tariffs on certain US agricultural imports from March 10, 2025, in retaliation to President Trump's March 3 executive order issued under the International Emergency Economic Powers Act (IEEPA) to increase the 10% tariff on all imports from China to 20% on March 4.

The tariffs include a 15% additional duty on imports of US chicken, wheat, corn, and cotton, and a 10% additional duty on imports of US sorghum, soybeans, pork, beef, aquatic products, fruits, vegetables, and dairy products, among others. In conjunction with these tariff measures, China also announced on the same day other non-tariff retaliatory actions, including banning 15 US entities from importing any dual-use items from China.

China's tariff actions

According to Notification No. 2/2025 dated March 4, 2025, of China's State Council Tariff Commission (SCTC), China will impose tariffs on certain US imports effective as of March 10, 2025. These include:

• A 15% additional tariff on US imports of chicken, wheat, corn, and cotton falling under 29 tariff lines of China's 2025 Tariff Schedule (see Annex 1 of the SCTC notification – in Chinese); and
• A 10% additional tariff on US imports of sorghum, soybeans, pork, beef, aquatic products, fruits, vegetables, and dairy products (among others) falling under 711 tariff lines (see Annex 2 of the SCTC notification – in Chinese).

The notification specifies that this action is a response to the unilateral tariff measures imposed by the United States on Chinese imports announced on March 3, 2025. Like the previous retaliatory action in February 2025, the SCTC clarifies in the notification that no exemption or reduction mechanism will apply to these retaliatory tariff measures. Goods already in transit before March 10, 2025, and imported between March 10 and April 12, 2025, will be exempt from the additional tariffs. 

On the same day, the Ministry of Commerce (MOFCOM) also disclosed in its daily press briefing that it will include Trump's new tariff measures into the earlier-filed WTO complaint against Trump's 10% tariffs on China with the WTO dispute settlement body.

China's non-tariff actions

China's Ministry of Commerce ("MOFCOM") announced in Notification No. 13/2025 dated March 4, 2025 immediate export controls on 15 US entities in the defense industry, prohibiting Chinese individuals or entities from exporting any dual-use items to any of the entities (i.e., Leidos, Gibbs & Cox, Inc., IP Video Market Info, Inc., Sourcemap, Inc., Skydio, Inc., Rapid Flight LLC, Red Six Solutions, Shield AI, Inc., HavocAI, Neros Technologies, Group W, Aerkomm Inc., General Atomics Aeronautical Systems, Inc., General Dynamics Land Systems, and AeroVironment). MOFCOM explained that these measures are intended to "safeguard national security and interests and fulfill international obligations on non-proliferation."

China also announced several other actions against US companies on March 4, 2025, including immediately adding 10 US entities to the Unreliable Entity List (UEL) (i.e., TCOM, Limited Partnership, Stick Rudder Enterprises LLC, Teledyne Brown Engineering, Inc., Huntington Ingalls Industries Inc., S3 AeroDefense, Cubic Corporation, TextOre, ACT1 Federal, Exovera, and Planate Management Group), and banning imports of gene sequencers from Illumina, Inc.

On the same day, China's customs authority suspended imports of logs from the United States as well as imports of soybeans from three US entities: GHS Inc., Louis Dreyfus Company Grains Merchandising LLC, and EGT, LLC. In Notification No. 29/2025 and Notification No. 30/2025, the General Administration of Customs (GAC)  citied recent quarantine inspections that revealed the presence of forest pests, including bark beetles and longhorn beetles, in US-imported logs, and ergot and seed coating in soybeans from the three US entities. 

Finally, MOFCOM released Notification No. 14/2025 dated March 4, 2025, initiating an unprecedented anticircumvention investigation into certain cut-off shifted single-mode optical fiber from the United States. China has imposed antidumping duty measures on these products since April 22, 2011. The domestic industry filed its circumvention complaint on February 10, 2025, alleging that US exporters altered product descriptions and HS codes to evade China's antidumping duty measures. This marks the first formal anticircumvention investigation conducted by China.

Although the Chinese government has not explicitly linked these actions to the trade dispute with the United States, their timing may signify the Chinese government's intent to leverage non-tariff measures or other non-trade mechanisms as part of its retaliation efforts.

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We provide below a list of partners and senior attorneys within the Global International Trade Practice of White & Case. Please contact any of them with questions about this report or other trade issues.

• Washington, DC: David Bond (Partner); Ryan Brady (Partner); Cristina Brayton-Lewis (Partner); Jay Campbell (Partner); Nicole Erb (Partner); Farhad Jalinous (Partner); David Lim (Partner); Gregory Spak (Partner)
• Mexico: Francisco de Rosenzweig (Partner); Carlos Vejar (Local Partner)
• Brussels: James Killick (Partner); Sara Nordin (Partner)
• Geneva: Jasper Wauters (Partner); Charles Julien (Partner)
• London: Chris Thomas (Counsel); Ed Pearson (Senior Associate)
• Paris: Orion Berg (Partner)
• Tokyo: William Moran (Partner)
• Dubai: Marcus Sohlberg (Counsel)

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