USTR initiates Section 301 investigation into China’s implementation of the “Phase One Agreement”

Comments must be received by December 1, 2025.

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october 24, 2025

The Office of the United States Trade Representative (USTR) today announced the initiation of a Section 301 investigation into China's implementation of the Economic and Trade Agreement Between the Government of the United States of America and the Government of the People’s Republic of China (“Phase One Agreement”). The investigation will assess China's adherence to its commitments under the agreement, the impact on U.S. commerce due to any non-compliance, and potential responsive actions. Read the USTR notice

According to today’s USTR release, the Phase One Agreement, reached on December 13, 2019, required China to implement structural changes in areas such as intellectual property, technology transfer, agriculture, and financial services, and to increase purchases of U.S. goods and services. However, five years later, China reportedly has not fulfilled these commitments, prompting the current investigation.

Under Section 302(b) of the Trade Act of 1974, the Trade Representative can initiate an investigation to determine if conduct is actionable under Section 301.

The USTR is inviting public comments and will hold a hearing on December 16, 2025. Interested parties should submit comments and requests to appear between October 31 and December 1, 2025.

For more information, contact a professional with KPMG Trade & Customs services:

Andrew Siciliano
Partner, U.S. & Global Practice Leader

E: asiciliano@kpmg.com

Doug Zuvich
Partner

E: dzuvich@kpmg.com

Irina Vaysfeld
Principal

E: ivaysfeld@kpmg.com

John L. McLoughlin
Principal

E: jlmcloughlin@kpmg.com

Luis (Lou) Abad
Principal

E: labad@kpmg.com

George Zaharatos
Principal

E: gzaharatos@kpmg.com

Christopher Young
Principal

E: christopheryoung@kpmg.com

Amie Ahanchian
Principal

E: aahanchian@kpmg.com

Gisele Belotto
Principal

E: gbelotto@kpmg.com

Steve Brotherton
Principal

E: sbrotherton@kpmg.com

Jessica Libby
Principal

E: jlibby@kpmg.com

Dawn Olesky
Principal

E: dolesky@pmg.com

Frances Xing
Principal

E: francesxing@kpmg.com

 

 

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