What importers argued
Between October 2024 and March 2025, USTR ran a fifth Section 301 exclusion process — for machinery used in domestic manufacturing. 1,111 requests were filed. Every one of them is still readable in full on USTR's live portal, and not one of them ever received a published decision.
There are no outcomes on this docket, so there is no grant rate on this page. USTR published no determination for any of these 1,111 requests, and no Federal Register notice of machinery exclusion determinations exists. Any exclusion granted under this process would in any case have expired on 31 May 2025.
What this corpus supports is a description of what importers argued. It cannot support any claim about what works.
On the widely-quoted “183 requests”. Trade-press coverage from December 2024 reported 183–185 filings. That was a snapshot taken while the docket was still open; it ran for three more months and closed with 1,111. The smaller figure describes about a sixth of the corpus.
What the form asked
Unlike the 2018–20 tranches, this process put the rationale on the public record field by field. Below is every public field on the request form, with how often it was answered. This is the closest thing that exists to a structured record of how importers argue for an exclusion.
| Field, as labelled on the form | Requests with the field | Answered |
|---|---|---|
| USTR Exclusion Request ID | 1,111 | 1,111 |
| Full Organization Legal Name | 1,111 | 1,111 |
| Third Party | 1,111 | 1,111 |
| Third Party Organization Name | 1,111 | 353 |
| Please provide the 8-digit HTSUS item number for the Chinese-origin manufacturing equipment that you wish to address in this exclusion request. | 1,111 | 1,111 |
| Please provide the 10-digit HTSUS item number for the Chinese-origin manufacturing equipment you wish to address in this exclusion request. | 1,111 | 1,111 |
| Manufacturing Equipment Name and Description (e.g., dimensions, weight, material composition, etc.): | 1,111 | 1,111 |
| Manufacturing Equipment Function, Application, and Principal Use: | 1,111 | 1,111 |
| Is the Chinese-origin manufacturing equipment of concern subject to an antidumping or countervailing duty order issued by the U.S. Department of Commerce? | 1,111 | 1,111 |
| Will the Chinese-origin manufacturing equipment of concern be used for domestic manufacturing? | 1,111 | 1,111 |
| Please address whether the manufacturing equipment of concern, or comparable manufacturing equipment, is available from sources in the United States? | 1,111 | 1,111 |
| Please address whether the manufacturing equipment of concern, or comparable manufacturing equipment, is available from sources in third countries? | 1,111 | 1,111 |
| Please discuss any attempts of the requesting organization to source the manufacturing equipment of concern from the United States or third countries. | 1,111 | 1,111 |
| Has the requesting organization purchased the manufacturing equipment of concern from a source in the United States or in a third country in the past five years? | 1,111 | 1,111 |
| Please comment on whether granting the exclusion request for the particular manufacturing equipment of concern would support domestic manufacturing. | 1,111 | 1,111 |
| Please comment on whether the manufacturing equipment of concern is strategically important or related to "Made in China 2025" or other Chinese industrial programs. | 1,111 | 1,111 |
| Please describe how the Chinese-origin manufacturing equipment of concern will be used for domestic manufacturing, as well as indicate the manufacturing sector. | 1,083 | 1,083 |
Who filed against these requests
Any interested party could file a response supporting or opposing a request, and a domestic producer opposing one had to state whether it had tried to sell comparable equipment to the requester in the previous two years. Position and relationship are structured fields on that form, so the counts below are what was filed, not a reading of it.
| Position taken, as filed | Filings |
|---|---|
| Support | 59 |
| Object | 25 |
Who the responders were
| Relationship to the requester, as filed | Filings |
|---|---|
| Other | 53 |
| Industry Association | 18 |
| U.S. manufacturer of equipment identified in the exclusion request, or comparable manufacturing equipment | 11 |
| Third-country manufacturer or importer of equipment identified in the exclusion request, or comparable manufacturing equipment | 2 |
A response is a public filing supporting or opposing a request. Position and relationship are structured fields on the response form and are counted exactly as filed. No inference is drawn about requests with no response, and — since this docket has no published outcomes — no relationship between a response and any outcome is asserted or could be.
Objections are rare here, and that is worth stating plainly. Only 2.0% of requests drew one. On the 2018–20 tranches the presence of an opposition is widely believed to matter a great deal — but those dockets' responses are either unlinked (Lists 1–2) or gone with the portal (Lists 3–4A), so that belief cannot be tested against outcomes anywhere in this corpus.
How importers argued, field by field
A transparent survey of the rationale fields, with the coding rules published and the unclassified share counted: How importers argue →
Concentration by heading
| HTS-4 heading | Requests | Distinct filers |
|---|---|---|
| 8479 | 221 | 48 |
| 8419 | 172 | 19 |
| 8486 | 147 | 11 |
| 8477 | 66 | 15 |
| 8429 | 48 | 4 |
| 8441 | 46 | 17 |
| 8422 | 42 | 15 |
| 8421 | 37 | 14 |
| 8462 | 32 | 15 |
| 8428 | 32 | 14 |
| 8456 | 30 | 16 |
| 8515 | 24 | 11 |
| 8463 | 21 | 7 |
| 8453 | 19 | 2 |
| 8465 | 14 | 6 |
| 8455 | 12 | 5 |
| 8514 | 12 | 10 |
| 8438 | 12 | 4 |
| 8464 | 11 | 4 |
| 8474 | 10 | 5 |
| 8458 | 10 | 4 |
| 8449 | 9 | 4 |
| 8543 | 9 | 5 |
| 8452 | 8 | 3 |
| 8460 | 8 | 4 |
Source: USTR Comments Portal, docket USTR-2024-0020, retrieved 2026-09-09. View the docket.