On June 15, 2026, the U.S. Supreme Court denied without comment the petition for certiorari in HMTX Industries LLC v. United States, ending the final appeal in the long-running legal challenge to the Section 301 List 3 and List 4A tariffs on Chinese imports.
The Court’s decision leaves the U.S. Court of Appeals for the Federal Circuit’s ruling intact, confirming that the tariffs remain valid and enforceable. For importers, the decision effectively closes the primary litigation seeking refunds of billions of dollars in Section 301 duties paid on Chinese goods since 2018 and 2019.
The outcome is markedly different from the Supreme Court’s February 2026 decision involving tariffs imposed under the International Emergency Economic Powers Act (IEEPA). While that ruling opened the door for eligible importers to seek refunds through U.S. Customs and Border Protection’s CAPE refund process, the Section 301 tariffs remain legally intact because they were imposed under a different statute and challenged on different legal grounds.
Why Was the Section 301 Case Filed?
The dispute began after the Office of the United States Trade Representative (USTR) imposed Section 301 tariffs on China in response to findings involving technology transfer, intellectual property, and innovation practices.
The initial action covered approximately $50 billion in Chinese imports through Lists 1 and 2. After China responded with retaliatory measures, USTR expanded the action by issuing List 3 and later List 4A, extending tariffs to more than $320 billion in additional Chinese goods.
Thousands of importers challenged the expansion, arguing that Section 307 of the Trade Act of 1974 did not authorize USTR to increase the scope of an existing action so dramatically and that the agency failed to follow required administrative procedures.
The U.S. Court of International Trade rejected those arguments, and in September 2025, the Federal Circuit affirmed that USTR acted within its statutory authority. By declining to hear the appeal, the Supreme Court allowed that decision to stand.
What Does the Supreme Court’s Decision Mean?
The List 3 and List 4A tariffs remain in effect.
The tariffs continue to apply to covered Chinese-origin products and remain fully enforceable.
The refund litigation has effectively ended.
Importers who paid List 3 and List 4A duties—including the thousands of plaintiffs whose cases have been stayed before the Court of International Trade—should not expect refunds through this litigation. Those remaining cases are expected to be dismissed.
USTR’s modification authority remains broadly supported by the courts.
The Federal Circuit’s interpretation of USTR’s authority now stands, reinforcing the agency’s ability to expand existing Section 301 actions under circumstances similar to those addressed in this case. That precedent may influence future Section 301 investigations, including those involving Brazil and the recently proposed forced labor tariffs covering 60 economies.
Section 301 vs. IEEPA: Why the Outcomes Were Different
Many importers have understandably confused the two Supreme Court cases.
The February 2026 IEEPA decision concluded that the President exceeded the authority granted under the International Emergency Economic Powers Act when imposing broad import tariffs. As a result, CBP is currently processing eligible IEEPA duty refunds through its CAPE system.
The Section 301 case involved a different statute—the Trade Act of 1974—and different legal questions. Rather than challenging presidential emergency powers, the litigation focused on whether USTR exceeded its authority when expanding an existing Section 301 action. The courts concluded that it did not.
As a result, Section 301 tariffs remain on much firmer legal footing.
Frequently Asked Questions
Will importers receive refunds of Section 301 List 3 and List 4A tariffs?
No. The Supreme Court’s decision leaves the Federal Circuit’s ruling in place, effectively ending the primary litigation seeking refunds of those duties.
Does this affect IEEPA tariff refunds?
No. The Section 301 litigation is entirely separate from the IEEPA cases. Eligible importers may still pursue IEEPA refunds through CBP’s CAPE process.
Can future Section 301 tariffs still be challenged?
Potentially. This decision applies specifically to the legal issues raised in the China List 3 and List 4A litigation. Future Section 301 actions could face different legal challenges depending on the statutory authority, administrative process, and facts involved.
What Should Importers Do Now?
Although the refund litigation has effectively concluded, companies still have opportunities to manage tariff exposure.
Importers should:
- Treat Section 301 List 3 and List 4A duties as an ongoing cost of doing business.
- Continue pursuing eligible IEEPA refunds through CBP’s CAPE system where applicable.
- Review product classifications to ensure duties are being assessed correctly.
- Evaluate tariff engineering, first sale valuation, duty drawback, and Foreign Trade Zone (FTZ) strategies to reduce future duty costs.
- Closely monitor ongoing Section 301 investigations, including those involving Brazil and proposed forced labor tariffs, as the legal framework supporting these actions has now been further reinforced.
Why This Matters
The Supreme Court’s decision closes one of the most significant legal challenges to the China Section 301 tariffs since they were introduced nearly eight years ago. For importers, the focus now shifts away from litigation and toward proactive duty planning and supply chain strategy.
As new Section 301 investigations continue to emerge, understanding tariff exposure—and identifying legitimate opportunities to reduce duty costs—will remain an essential part of international trade compliance.
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With Section 301 refund litigation effectively closed, duty mitigation becomes even more important. Alba’s trade compliance experts help importers evaluate classification strategies, tariff engineering, first sale valuation, duty drawback, and Foreign Trade Zone opportunities to reduce duty exposure and strengthen long-term supply chain planning.
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