Tariff Exclusion Intelligence

What actually wins a tariff exclusion

Base rates from 52,746 decided Section 301 exclusion requests filed 2018–2020, computed per tranche, cross-checked against the published GAO figure, and corrected for a concentration problem that distorts every headline number published so far.

Read this before the numbers. As of 2026-09-09, no live US tariff action accepts product-specific exclusion requests with published outcomes. Every process that produced the rates below has closed. USTR was asked to create a new one in July 2026 and declined.

These are historical base rates under closed processes. They are not a forecast, and there is currently nothing live to forecast. See the live process map.

52,746
decided requests, 2018–20
Lists 1, 2, 3 and 4A
12.9%
granted, all filers
The published headline figure
16.9%
granted, excluding mass filers
Filers with ≤100 requests
706
HTS-4 headings with requests
4,477 distinct 10-digit lines

Grant rate by tranche

Rates are computed over decided requests and reported per tranche. They are never averaged across tranches, because each tranche ran a different process — a different filing system, a different form, and a different volume of requests.

TrancheRequestsGrantedDeniedGrant rateFiling window
List 1
$34B action (July 6, 2018)
10,814 3,656 7,158 33.8% Jul 11 2018 – Oct 9 2018
List 2
$16B action (August 23, 2018)
2,869 1,074 1,795 37.4% Sep 18 2018 – Dec 18 2018
List 3
$200B action (September 24, 2018)
30,283 1,497 28,786 4.9% Jun 30 2019 – Sep 30 2019
List 4A
$300B action (September 1, 2019)
8,780 575 8,205 6.5% Oct 31 2019 – Jan 31 2020

The collapse between List 2 and List 3 is a process boundary, not a product story. Lists 1–2 were filed as documents to regulations.gov. Lists 3–4A were filed through a separate USTR portal with a longer form, and drew roughly three times as many requests. Reading the fall from ~35% to ~5% as evidence that later products were weaker would be a mistake.

The correction nobody has published

Request counts are extremely concentrated. The single largest filer accounts for 19.4% of all 52,746 requests on its own; the ten largest account for 32.7% and the hundred largest for 53.9%. Of 4,787 distinct filers, 1,967 filed exactly one request.

That means the widely-quoted headline rate is dominated by a handful of very large filers and does not describe the position of an importer filing a small number of requests. Both views:

TrancheAll filersExcluding filers with >100 requestsRequests in the corrected view
List 1 33.8% 33.1% 7,641
List 2 37.4% 30.2% 1,920
List 3 4.9% 9.1% 12,878
List 4A 6.5% 7.6% 5,225
All four (cross-tranche) 12.9% 16.9%

Counted per filer rather than per request, the median filer's grant rate was 0% and the mean was 17.6%. 26.2% of filers won at least one request.

On the last row. The cross-tranche figures blend four different processes and are shown only because they are the numbers in public circulation. Prefer the per-tranche rows for any real use.

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