§72 / US · CN · EU · KR

USTR §301 isn't an investigation — it's a delivery schedule. 16 economies, 135 days.

March 11 — USTR Greer named 16 economies and 21 sectors. Statutory window: 12 months. Greer's public target: July 24, 135 days. Compared with the 2017 China §301 investigation that ran 322 days from launch to first tariff, this calendar is 58% shorter. The investigation is still running; the destination has been marked.

2026-04-26 · By Marcus · 7 min read

On March 11, USTR Jamieson Greer posted a Federal Register notice naming 16 economies. The list, in the order trade press tends to recite it: China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan (China), Bangladesh, Mexico, Japan, India. The 21 sectors run from aluminum to transportation equipment — steel, aluminum, non-ferrous metals, autos, batteries, cement, chemicals, electronics, energy goods, glass, machine tools, machinery, paper, plastics, processed food and beverages, robotics, satellites, semiconductors, ships, solar modules, transportation equipment.

The statutory window under §301(b) is twelve months. The number Greer keeps repeating in public is July 24, 2026. From the March 11 launch to that target date is 135 days.

To weigh those 135 days, pull out the 2017 calendar.

That earlier USTR opened its §301 investigation against China on August 18, 2017 — technology transfer and intellectual property. Public hearing October 10. Two rounds of written comments. Internal coordination with Commerce and the trade advisory committees ran for months. The presidential memorandum signed March 22, 2018. List 1 — $34 billion of Chinese imports at 25% — went into effect July 6, 2018. From investigation start to first tariff: 322 days.

This round: launch March 11, comment deadline April 15, hearing May 5, action target July 24. 322 days versus 135 — a 58% compression.

The schedule reads as: the procedural investigation is still running, but the destination has already been marked.

Who is on the list and who is missing both matter.

China needs no explanation — that is the original use case for this statute. Vietnam, Bangladesh, Cambodia, Malaysia, Thailand, Indonesia together carry the message that the 2018 transshipment chain is what's being closed this round. The USITC's 2023 retrospective on §232 documented the path: from 2018 through 2021, steel volumes routed through Vietnam, Thailand and Malaysia rose 340%. This time USTR has named every stop along the way.

Korea, Japan, Taiwan (China) and Singapore form a different category. In steel, semiconductors, robotics and satellites, these are the industrial economies whose capacity sits adjacent to China's. Putting them on the same instrument that targets the alleged source of the overcapacity says that USTR is no longer treating "excess capacity" as a uniquely Chinese problem.

Switzerland and Norway took two readings at the law firms. Switzerland sits on this list while it sits on the 15% preferential tier of the §232 pharmaceutical proclamation issued April 2 — USTR is willing to grade an economy on different curves in different files. Norway is on the list because of aluminum and non-ferrous metals; Norsk Hydro is the largest aluminum producer in Europe.

The European Union is named as a bloc. Mexico is also there. The two together create a geometric symmetry — the CBAM perimeter, the USMCA perimeter, the §301 perimeter all describe the same map in three different vocabularies.

India is the most delicate case. Being named places India outside the "preferred" tier — consistent with the §232 pharmaceutical proclamation that grouped India with the 100% default tier rather than the 15% preferential one.

Who is missing? Russia is absent — there is no remaining trade between Washington and Moscow worth bargaining over. Brazil is absent — US-Brazil steel has historically been handled through bilateral TRQs. Turkey is absent — read into that what you will. Canada is absent — USMCA has its own rooms for these arguments. The names not on the list say more than several of the names on it.

Of the 21 sectors, several are familiar §232 / §301 territory — steel, aluminum, non-ferrous metals, autos, chemicals, solar modules, electronics. The newer entries are different: semiconductors, robotics, satellites, machine tools, processed food.

Semiconductors on the list signals that this round of "excess capacity" is no longer a synonym for last-generation industry. The center of gravity in robotics and machine tools has migrated quickly to China over the last several years — this is the industrial-internet version of the steel-overcapacity narrative. Satellites is the freshest entry on the trade beat — the investigation's framing reaches into Chinese civilian commercial-satellite contracts, which carries the military-civil boundary directly into trade enforcement scope. Processed food is the sharpest politically — it is the entry with the shortest pass-through to a household grocery bill, and the one with the highest inflation salience.

The hearing runs May 5 through May 8, four days. The schedule is organized by sector, not by economy.

By-sector scheduling means USTR is not interested in hearing 16 separate "we don't have overcapacity" statements economy by economy. The intent is to put 16 capacity profiles and 16 market-share numbers on the same page within each sector. China across the table from Korea, Japan from Taiwan (China), the EU from Switzerland — direct capacity counterparties on the same day's docket.

ITIF's April 15 submission is the most useful filing in the public record. It unbundles "structural excess capacity" through several public-economics measures — the ratio of domestic demand to capacity, the share of capacity directed at exports, and the gap between long-run prices and costs. These measures, set down in the public record, become a default reference line for everyone else who has to argue. The unspoken implication of putting that reference line on the table — applying USTR's own preferred metrics, the list of economies properly described as having structural excess capacity may not stop neatly at 16.

Industry feedback splits cleanly.

Domestic US steel, aluminum and auto unions and producer associations stand with USTR — they did so in 2018, the rationale has not changed. Importers, retailers and consumer-facing trade associations make the same argument they made in 2018: tariffs land at the shelf, the bill ends up at the household. Those voices did not change the policy outcome in 2018; they are unlikely to change it in 2026.

The two new groups have not lined up. Robotics has a delicate problem: Japanese FANUC and Yaskawa, Korean Hyundai industrial-robotics products are effectively non-substitutable for US factory-floor demand — naming them on the same instrument as Chinese overcapacity divides the US manufacturing base against itself. Semiconductors is in wait-and-see mode — the trade association has not issued a unified position, the larger members plan to file individually.

CFOs this week: model the three tariff-tier scenarios for a July 24 landing. Highest-probability tier 1: steel, aluminum, non-ferrous metals, 5–15 percentage points. Tier 2: autos, semiconductors, robotics, starting at 10%. Tier 3: satellites and processed food deferred to 2H 2026. Run those three scenarios on the LBO cash-flow model now — that buys a quarter of lead time over reacting to the formal announcement.

Supply chains by June 15: re-audit supplier exposure across the 16 named economies. Where a single HS code's suppliers span multiple listed economies, the window to rebalance the mix without large contract-break costs closes in early July.

Legal this week: prepare hearing testimony. The written-comment deadline (April 15) is past. On May 5 each industry's company time slots are allocated by request order — companies that filed hearing requests earliest are scheduled first and set the agenda; later filers respond to it. The order of speaking has historically counted for more in §301 hearings than any single number.

July 24 is a date, not an option.

Figures

Mar 2018
Original §232: 25% steel / 10% Al, metal-content basis
2019-2024
TRQ deals: JP 1.25 Mt · KR 2.63 Mt · EU quota
Feb 2025
Aluminum raised 10% → 25%
Apr 6 2026
Restructure: 50% A-I / 25% I-B / 15% transitional · full customs value
Dec 2027
Annex II 15% transitional carve-out expires
§232 STRUCTURE OVER TIME (CBP guidance · White House proclamations)
Figure 1 — §232 timeline. April 2026 marks the largest single restructure since the original 2018 proclamation.
0%25%50%75%100%🇨🇳 China§122§301§232 (50%)94%Effective ~94%🇯🇵 Japan§122§232 above-quota67%Above 1.25 Mt TRQ — in-quota = 17%🇰🇷 Korea§122§232 above-quota67%Above 2.63 Mt TRQ — in-quota = 17%🇬🇧 UK (95% melt-in-UK)§122§232 UK rate42%Special carve-out (50% ⇒ 25%)🇲🇽 Mexico§232 (full)50%USMCA exempts §122; melt-and-pour in MX/USA required
Figure 2 — Effective duty stack on HS 7208 (hot-rolled flat steel) into the US, by country of origin, post April 6 2026.
AnnexCoverageExamplesRateBasis
I-AArticles made entirely or almost entirely of steel/Al/CuBars, rods, plates, sheets, tubes, pipes, unwrought metal50%Full customs value
I-BDerivative articles with substantial metal contentBicycles, washing machines, prefab structures, wire products25%Full customs value (was: metal content)
IIMetal-intensive industrial / electrical grid equipment (transitional)Transmission towers, transformers, certain wind components15%Full customs value · expires Dec 31, 2027
IIITrade Agreement Partner-origin metal, drawback-eligibleAnnex I-B articles where metal smelted in UK/EU/JP/KR/MX/CAVariesDrawback restored
Figure 3 — §232 classification regime. Sources: April 2 2026 White House proclamation, Annexes I-A / I-B / II / III; CBP CSMS #68253075.