If your company relies on materials, hardware, subcomponents or other supplies from China, then you need to examine the government’s latest investigation.
The U.S. International Trade Commission (USITC) has opened a new factfinding investigation. The investigation is examining the impact of revoking normal trade relations treatment for China.
“Normal trade relations” is the term of art that describes the trade relationship between the United States and its trading partners. This is also called “most-favored nation” status in the World Trade Organization (WTO) context.
There are currently four countries that do not have normal trade relations with the United States: Belarus, Cuba, North Korea and Russia. Those four countries pay much higher base tariffs. Currently, the United States imports relatively little from these four jurisdictions. For example, in 2025 the U.S. imported $3.8 billion in goods from Russia, and in 2024 the U.S. imported $3.0 billion in goods from Russia.
Compare this to imports from China: In 2024 the United States imported $438.7 billion in goods from China. That volume slipped to just $308.4 billion in 2025 due to US-China trade disputes, but that is still a very large volume of imports. The slippage from 2024 to 2025 shows that duty rates can have significant impact on import volumes.
The People’s Republic of China was granted normal trade relations status in February 1980, pursuant to title IV of the Trade Act of 1974 (19 U.S.C. 2431 et seq.). In 2001, Public Law 106–286 (114 Stat. 880) was passed to make permanent the People’s Republic of China’s normal trade relations status.
The normal trade relations status made merchandise from the People’s Republic of China eligible for the duties set forth in column 1 of the HTSUS. Column 2 is the column reserved for the four countries that do not enjoy normal trade relations with the United States. For each tariff code, the column 2 duties are typically much higher.
If the United States revokes normal trade relations from China, then imports originating from China would be subject to the “column 2” duties. China would become the fifth country added to the column list.
Column two has higher duty rates, but what does that really mean? Aircraft parts under heading 8807 typically enjoy a zero percent base rate, but under column two they would be subject to a 27.5% duty rate. Steel cotter pins are typically subject to a 3.8% duty rate but under column two they are subject to a 45% duty rate. Aircraft jet engine parts are often admitted under a zero percent base rate, but under column two they would be subject to a 35% duty rate. As you can see, moving China to column two dramatically increases the import duties that importers will pay.
In September, the House Appropriations Committee published a report that asked the USITC to investigate removing normal trade relations status from China.
Trade Enforcement Analysis.–The Committee directs the ITC to complete, no later than 180 days after the enactment of this Act, an investigation and prospective economic analysis of revoking permanent normal trade relations (PNTR) treatment of all products of the PRC on the U.S. economy, U.S. industry, and product sourcing over a six-year period. The ITC is further directed to provide this report to the Committee within 30 days of completion. The report should include the results of the ITC’s investigation and analysis including detailed information, to the extent practicable, on U.S. trade, production, and prices in the industries that would be directly and most affected by the imposition of rates of duty in Column 2 of the Harmonized Tariff Schedule (19 U.S.C. 1202) on products from China. The report should also examine an alternative scenario where Congress revokes PNTR with a five-year phase-in of tariffs on a subset of national security products.
Here’s where you come in. As an industry, we need to compile data to show what the effect of this sort of change would be on American businesses. We know that some of our members are sourcing Chinese origin materials as raw materials or subcomponents to their aircraft parts. It is important that we let the government know how this will affect our industry, so they can make an informed decision.
History also shows us that when the United States imposes sanctions that affect another country, like China, the other country may impose sanctions on goods from the United States. This means that a trade war can adversely affect aircraft parts both on the supply side and on the international sales side.
Please let MARPA Know:
- What volume of Chinese origin supply/materials are you sourcing?
- What is the annual dollar value of Chinese origin supply/materials that are you sourcing?
- What sorts materials are you sourcing from China?
We will need to file our responses with the government by 5:15 p.m. Eastern Time, on Monday, April 13, 2026, so we ask that members of MARPA submit their data to MARPA by Wednesday, April 8, 2026 so we can assemble it into an industry report.
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