Public comments submitted in response to a U.S. International Trade Commission (USITC) investigation on the withdrawal of Permanent Normal Trade Relations (PNTR) for China show a split between supporters and opponents on the possible move.
In February, the USITC announced the PNTR withdrawal investigation. As the USITC explains, its general factfinding investigations, such as this one conducted under section 332(b) of the Tariff Act of 1930, cover matters related to tariffs, trade, and competitiveness. The resulting reports "convey the USITC’s objective findings and independent analyses on the subjects investigated." However, the USITC "makes no recommendations on policy or other matters in its general factfinding reports." Nevertheless, this report could provide the basis for executive or legislative action, as the Trump administration or Congress might try to make use of the report to pursue their agenda on these issues.
The USITC's press release for the PNTR investigation says that it "is undertaking a new factfinding investigation that will examine the impact of revoking permanent normal trade relations (PNTR) treatment for all products of China on the U.S. economy, U.S. industry, and product sourcing over a six-year period." To this end, the USITC is "instituting this investigation, Effects on the U.S. Economy of Revoking China’s Permanent Normal Trade Relations Status (Inv. No. 332-609)."
The USITC expects to publish its report by August 21, 2026. In its notice of investigation, the USITC notes that the House committee report calling for the investigation states that "this investigation (1) should include 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 of the United States on products of China; (2) should examine an alternative scenario in which Congress revokes PNTR treatment, with a five-year phase-in of tariffs, on a subset of national security products from China; and (3) should be transmitted to the House of Representatives and Senate Committees on Appropriations within 210 days of the Act’s enactment."
The following is a representative sample of the comments received by the USITC (there will be no public hearing in the investigation).
Skeptics of withdrawing PNTR
Computer & Communications Industry Association (CCIA)
CCIA’s members have a direct and substantial interest in this investigation. Revoking PNTR for China and applying Harmonized Tariff Schedule (“HTS”) Column 2 duty rates would profoundly affect the technology sector: both upstream, through increased costs of imported components and finished goods, and downstream, through likely retaliatory measures from China that could curtail U.S. firms’ access to the Chinese market and disrupt global supply chains.
U.S. Fashion Industry Association (USFIA)
Revocation of PNTR for China Would Result in a Massive Price Increase on Apparel
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Revocation of China PNTR Would Harm American Brands and Retailers and Result in a Massive Tax Increase on American Families
Solar Energy Industries Association (SEIA)
Solar paired with energy storage is increasingly important for meeting energy demand, maintaining reliability, and supporting the growth of new AI, data center, and manufacturing applications. Domestic manufacturers of solar and BESS technology have made great strides in recent years to onshore manufacturing of key components along their supply chains. A revocation of China’s PNTR status would burden domestic manufacturers by raising input costs and fail to resolve the expertise, material qualification, and scaleup bottlenecks associated with domestic equipment and upstream manufacturing. Furthermore, many of the imported products that would receive a higher duty rate as a result of the revocation are already tariffed at higher rates under other statutory authorities or are being actively considered for additional tariffs. A change in China’s PNTR status would merely slow the pace of domestic solar and storage manufacturing while failing to resolve key growth barriers.
National Milk Producers Federation and the U.S. Dairy Export Council
As we have seen over the past several years, China has not hesitated to retaliate against the United States by raising tariffs on U.S. exports or intentionally cutting back on purchasing U.S. goods. Our concern is that if the U.S. government were to revoke China’s PNTR status, China would retaliate by imposing retaliatory tariffs, revoking Most Favored Nation (MFN) status for U.S. products into the Chinese market more broadly, and/or reversing the progress that has been made through the Phase One Agreement, thereby risking large losses to U.S. dairy competitors in New Zealand, the European Union and elsewhere.
US-China Business Council (USCBC)
In 2023, USCBC released new research that we commissioned from Oxford Economics demonstrating that revocation of China’s permanent normal trade relations (PNTR) status would materially harm the US economy, jobs, consumers, and businesses. The report concluded that revocation would result in: (1) increased prices; (2) the elimination of hundreds of thousands of jobs; and (3) diminished global competitiveness for American companies. A copy of the report can be found online here ...
United States Council for International Business (USCIB)
We understand that revocation of China PNTR is being evaluated by policymakers as a perceived way to de-risk the US economy. While USCIB supports efforts to safeguard supply chains, we believe revocation of PNTR to be an overly blunt instrument unsuited to this goal, shifting all products to much higher duty treatment, with significant implications for supply chains, prices, and US operations. Based on the current structure of US-China supply chains, we expect PNTR revocation to have particularly acute impacts in industries where China has been a stable source for intermediate inputs and finished consumer goods and where near-term substitution is constrained by capacity, qualification, and regulatory requirements.
National Foreign Trade Council (NFTC)
World Trade Organization (WTO) rules require all members, including the United States, to extend most favored nation (MFN) treatment “immediately and unconditionally” to new WTO members. Consequently, Congress enacted the U.S.-China Relations Act of 2000 (H.R.4444), replacing annual reviews and approvals of China’s trade status with Permanent Normal Trade Relations (PNTR). Passage of this legislation was necessary for the United States to benefit from commitments China made as part of its WTO membership. Withdrawing PNTR for China would effectively terminate the United States’ recognition of China’s WTO rights, which would almost certainly cause China to retaliate. Retaliation could result in higher Chinese tariffs on U.S. imports, but may also target U.S. interests beyond tariffs, ...
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Regardless of what form retaliation takes, a unilateral U.S. move to withdraw PNTR for China will leave U.S. businesses at a disadvantage in the Chinese market compared to rival companies from other WTO member countries that are not subject to retaliation.
Consumer Technology Association (CTA)
The consumer technology industry depends on global supply chains to design, manufacture, and distribute products used by consumers and businesses across the United States. These supply chains span multiple countries, including China, rely on inputs, components, and assembly processes. Revoking China’s PNTR would subject these supply chains to significantly higher tariffs and increase costs throughout the economy, ... .
The U.S. International Trade Commission (Commission) should evaluate China’s PNTR revocation within the context of the current tariff environment. The United States already maintains multiple layers of tariffs and trade restrictions under Sections 122, 232, and 301. Revoking China’s PNTR would compound these measures and substantially amplify their cumulative economic impact, ... .
Footwear Distributors & Retailers of America (FDRA)
Removing China’s PNTR status would mean all products from China would be subject to the high column 2 rates of the Harmonized Tariff Schedule of the United States (HTS). This would result in drastic tariff rate increases for footwear. Currently only Cuba, North Korea, Russia and Belarus have the column 2 rates. Putting China in the same tariff category as North Korea would substantially harm U.S. footwear companies and consumers.
It would be impossible for U.S. footwear companies and consumers to mitigate the harm from revoking China’s PNTR status.
International Dairy Foods Association (IDFA)
... it is simply not feasible to ignore or easily substitute a market of China’s size and global influence. Many U.S. dairy processors rely on specialized products from China to produce the safe, affordable, and nutritious dairy products which feed millions of Americans. Certain critical products are unavailable through other suppliers outside of China.
In the event of a revocation of China’s Permanent Normal Trade Relations (PNTR) status, no segments of the U.S. dairy industry would be immune to double-digit cost increases on the supply side.
National Retail Federation (NRF)
NRF believes an assessment of the economic effects of permanent normal trade relations tariff status for China will find significant net negative impacts, particularly for consumers. Tariff rate increases will be substantial for consumer goods found in nearly every household. For categories like toys, the effective tariff rates would nearly quadruple above the already-inflated effective rate faced in 2025, which has a current base tariff rate of 0% but includes as well tariffs imposed under Sections 301 and 232 as well as the International Economic Emergencies Act. Apparel and travel goods could face effective tariff rates of around 100%. Small retailers are not in a position to absorb these double-digit cost increases. Moreover, much of the production that could leave China to avoid higher rates already has moved. What remains in China are the products where cost-competitive alternatives are hardest to find, especially since other countries are likely to face additional Section 301 and 232 tariffs as well. If the products are not available elsewhere for affordable prices, they may no longer be available to consumers, which may lead to reduced options, potential empty shelves or very high prices for any remaining products that are available. That means American consumers will bear the brunt of the additional costs. Commission modeling should incorporate these facts in its model parameter assumptions.
Supporters of withdrawing PNTR
The United States has become unacceptably dependent on China for strategically critical goods and inputs, even as the Chinese Communist Party has proven willing to weaponize control of critical supply chains. The need for critical supply -chain independence is the most urgent motivation for policymakers’ increased interest in revoking China’s PNTR.
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American businesses deserve stability and predictability; the American national interest requires critical supply -chain independence. Legislatively rescinding PNTR and imposing a well-designed, phased -in, China-specific tariff regime targeting the most strategically critical goods is an important step towards achieving both.
Coalition for a Prosperous America
Permanent Normal Trade Relations (PNTR) status with China imposed major costs on the U.S. manufacturing base while delivering only limited consumer price benefits. Rising import competition from China contributed to factory closures, wage pressure, job losses, and long-term industrial weakening in the United States. Chinese import competition caused 2.0 to 2.4 million net U.S. job losses from 1999 to 2011. At the same time, the consumer price effects were modest. Imports from China and other dynamic Asian economies reduced U.S. inflation by only about 0.1 percentage point per year on average from 1996 to 2005.
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In total, CPA’s GTAP-FP model indicates that revoking China’s PNTR status would produce substantial gains for the U.S. economy by shifting demand away from Chinese imports and toward domestic production. The modeled results show higher U.S. output, employment, wages, and household income, with especially strong gains in manufacturing industries heavily exposed to Chinese import competition. The results also show a sharp reduction in imports from China and a significant improvement in the U.S. trade position.
Information Technology and Innovation Foundation (ITIF)
ITIF views the People’s Republic of China (PRC) as a power trader, focusing on inducing trade dependencies and using trade to gain a competitive advantage for its advanced industries, all to limit the development and advancement of its adversaries. China’s failure to meet its accession commitments to the World Trade Organization (WTO)—including its forced technology transfer, subsidies for local champions, and weak intellectual property rights (IPRs) protections and trade secret theft—is well documented by ITIF. China should come into full and immediate compliance with its WTO commitments; otherwise, as a last resort, the U.S. government should revoke China’s PNTR status. ITIF previously proposed this approach in 2021, stating that “if China decides to develop an alternative economic system that is not compatible with existing multilateral rules, then it shouldn’t be in the WTO—or at least it shouldn’t enjoy the same benefits as countries that respect agreed-upon rule.”
With this goal, ITIF’s comments focus on identifying: i) how dependent U.S. firms, especially those in national power industries, are on Chinese imports, ii) the cost of revoking China’s Most-Favored Nation (MFN) status and imposing tariffs in column 2 of the Harmonized Tariff Schedule of the United States (so-called “column 2 tariffs”), and iii) potential remedies and tradeoffs of imposing China column 2 tariffs.
NAATBatt International (North American trade association for the advanced battery industry)
The question before the Commission is not whether the United States should reduce its dependence on China-based battery supply chains. It should, and it must. The question is how to do so in a way that builds American strength and attracts private sector investment rather than creating a self-inflicted wound.
National Council of Textile Organizations (NCTO)
NCTO strongly supports the revocation of China’s Permanent Normal Trade Relations (PNTR) status as a necessary first step in restoring U.S. leverage and addressing persistent non-market practices. Revoking PNTR would remove the automatic guarantee of Normal Trade Relations (NTR) treatment, thereby creating both policy leverage and allowing future tariff treatment to be aligned with U.S. strategic interests.
While revocation would, as a legal matter, default China to Column 2 duty rates under the Harmonized Tariff Schedule, NCTO emphasizes that Congress should adopt a tailored post-PNTR framework. Congress has the authority to design a calibrated approach, including phased tariff increases and sector-specific measures, rather than relying solely on the statutory default. In this regard, NCTO supports replacing PNTR with a targeted regime that increases tariffs on finished textile and apparel products while avoiding additional duties on machinery and inputs that are not available domestically. Such an approach would maximize leverage while minimizing unintended harm to critical supply chains.
Furthermore, NCTO urges that textiles and apparel be formally designated as national security products under any alternative framework in which Congress considers a phased revocation of PNTR, including a five-year tariff implementation period. Such designation would appropriately recognize the essential role that the domestic textile industry plays in supporting critical U.S. government and defense needs.