Recent China-U.S. trade negotiations raised hopes that economic ties may be stabilizing after years of escalating tensions. A key milestone was U.S. President Donald Trump’s state visit to China in mid-May 2026, during which he and President Xi Jinping explicitly agreed to build a “constructive relationship of strategic stability” based on “fairness and reciprocity.”
Yet the ongoing negotiations have done little to alter the institutional machinery of U.S. trade policy toward China. Behind the headlines, anti-dumping and countervailing duty investigations, together with recurring “sunset reviews,” continue to advance under established statutory procedures.
During Trump’s visit to China, Beijing and Washington reached preliminary agreements on tariffs, market access, investment, and critical mineral supply chains, raising hopes of stabilizing bilateral economic relations. Yet the negotiations left the U.S. trade remedy regime untouched.
The U.S. Department of Commerce and U.S. International Trade Commission (USITC) have continued anti-dumping, countervailing duty, and five-year sunset review proceedings against Chinese goods pursuant to established statutory procedures. Most trade remedy measures remain in place despite the recent easing of tensions. As Chad Bown observed, their continued operation reflects how deeply these measures are embedded in U.S. legal and political institutions, making meaningful reform difficult.
In short, recent negotiations have eased short-term trade tensions without changing the institutional foundations of U.S. trade policy toward China. These trade remedy mechanisms generate far longer-lasting bilateral economic friction than tariffs subject to diplomatic bargaining. That much is clear from recent USITC data.
The USITC Data
These data suggest that the U.S. trade remedies have become increasingly institutionalized, with China as the central focus of the system. Between January and June 2026, the USITC initiated 183 trade remedy investigations, 72 of which involved products from mainland China or Hong Kong, accounting for nearly 40 percent of all cases. The breadth of these investigations is equally striking. They included 37 anti-dumping cases, 27 countervailing duty cases, 14 Section 337 investigations, and 21 five-year sunset reviews, illustrating that China is subject to virtually every major U.S. trade remedy instrument.
Among completed cases, 57 resulted in affirmative determinations, while only two produced negative findings, highlighting the durability rather than temporary nature of existing trade restrictions. These figures indicate that trade restrictions have evolved beyond case-by-case enforcement into a stable, institutionalized system governing U.S. trade policy toward China.
Among U.S. trade remedy instruments, five-year sunset reviews most clearly illustrate the path dependence of U.S. trade policy towards China. These reviews were originally designed to determine whether existing anti-dumping and countervailing duty measures should expire (“sunset”) after five years. Yet in practice, the review process has functioned as a mechanism for maintaining existing restrictions rather than terminating them. Once trade remedy orders are incorporated into domestic legal procedures, their continuation becomes easier than their removal.
According to the USITC database, 21 China-related cases have entered the sunset review process, with many proceeding to second or even third rounds of review. Some products, including preserved mushrooms, non-oriented electrical steel, and citric acid and “certain citrate salts,” have remained subject to U.S. trade remedy measures for more than two decades. In practice, sunset reviews have evolved from an exit mechanism into a mechanism for policy continuity, reinforcing the durability of U.S. trade restrictions against China.
The industrial distribution of recent investigations also reflects changing U.S. policy priorities. Whereas trade remedies historically focused on traditional manufacturing sectors such as steel and aluminum, recent investigations increasingly target higher-value and strategically important industries, such as pharmaceuticals, chemicals, automotive manufacturing, semiconductors, electronic components, and advanced machinery. Chemicals and pharmaceuticals alone account for approximately 20 investigations – nearly one-third of all China-related cases.
This shift mirrors broader U.S. industrial policies, including the CHIPS and Science Act and the Inflation Reduction Act. It suggests that trade remedies have become steadily aligned with broader industrial and technological competition rather than serving solely as tools to addressing individual trade disputes.
Another notable trend is the growing interaction among different trade policy instruments. Anti-dumping and countervailing duty investigations remain the principal mechanisms for restricting Chinese imports. Although Section 337 investigations (dealing with “claims regarding intellectual property rights, including allegations of patent infringement and trademark infringement by imported goods”) accounted for only 14 cases, they were concentrated in technology-intensive products, including semiconductors, smart devices, and photovoltaic components.
Recent USITC investigations involving semiconductor devices, TOPCon solar cells, and smart televisions illustrate how intellectual property enforcement has become closely intertwined with broader trade policy objectives. As Jennifer Hillman has argued, trade remedies are no longer simply instruments for correcting unfair trade practices; they increasingly serve broader industrial and strategic objectives.
Taken together, these developments suggest that U.S. trade remedies have evolved beyond temporary policy tools into an institutionalized framework for entrenched strategic competition with China.
The Impact of Persistent U.S. Trade Remedies on Chinese Firms
The most immediate consequence of persistent U.S. trade remedies has been a substantial increase in compliance costs for Chinese exporters. Once an anti-dumping or countervailing duty order is issued, it becomes subject to statutory review procedures rather than discretionary political adjustment.
According to the Department of Commerce, companies participating in anti-dumping/countervailing duty proceedings are required to submit extensive documentation through its ACCESS system and remain subject to repeated administrative reviews that may establish new cash-deposit rates for future imports. The Department currently administers more than 700 anti-dumping/countervailing duty orders covering products from over 60 countries, underscoring the long-term and resource-intensive compliance burden facing firms involved in trade remedy proceedings. The burden falls disproportionately on small and medium-sized enterprises.
As a result, some Chinese exporters have scaled back or completely exited the U.S. market. What began as temporary remedies have thus become structural, long-term compliance burdens.
Beyond raising costs, persistent trade remedies have significantly increased uncertainty for Chinese exporters. Because anti-dumping and countervailing duty investigations can remain in force for many years, firms face prolonged uncertainty over future duty rates, pricing strategies, and market access. The possibility of additional duty liabilities also affects importers’ behavior, with many reducing orders, delaying procurement, or seeking alternative suppliers once investigations initiated.
Chinese manufacturers such as LONGi, JinkoSolar, and Trina Solar have faced repeated U.S. anti-dumping and countervailing duty investigations over a decade. Despite remaining globally competitive, recurring trade remedy proceedings have increased compliance burdens and accelerated adjustments to their global production networks. As a result, trade remedy risks have become an integral factor in corporate decision-making. For many exporters, uncertainty surrounding future investigations now carries consequences comparable to tariff increases themselves.
Rather than fundamentally constraining Chinese firms, persistent U.S. trade remedies have accelerated their strategic adjustment in global markets. Chinese firms have responded through market diversification, production network restructuring, and technological upgrading. As Rhodium Group observed, Chinese firms are progressively diversifying production across Asia without relocating their core industrial capabilities abroad. ASEAN remained China’s largest trading partner in 2025, with bilateral trade growing by 9.6 percent, while Belt and Road Initiative partner countries accounted for 51.8 percent of China’s foreign trade.
Many firms have also reconfigured their global production networks. Manufacturers in sectors such as electronics, photovoltaic products, and machinery have expanded production capacity in Southeast Asia, Mexico, and Central and Eastern Europe while retaining research and development, core technologies, and supply chain management in China. Chinese companies have announced nearly $400 billion in overseas clean-tech investment projects since 2014 across the EV, solar PV, and wind sectors. This approach reduces direct exposure to U.S. trade remedies while preserving China’s role in research, engineering, advanced manufacturing, and supply chain coordination.
At the same time, increasingly complex trade investigations have encouraged firms to strengthen their compliance capabilities and technological competitiveness. According to China’s General Administration of Customs, exports of mechanical and electrical products reached 7.8 trillion yuan in the first half of 2025, accounting for approximately 60 percent of China’s total exports. During the same period, exports of the country’s “new three” industries – new energy vehicles, lithium-ion batteries, and photovoltaic products – increased by 12.7 percent. Meanwhile, the International Energy Agency estimates that China accounts for more than 80 percent of global manufacturing capacity for photovoltaic modules, solar cells, and silicon wafers. Chinese firms are increasingly adjusting to a long-term institutionalized rather than temporary trade environment.
Conclusion
Recent negotiations have eased bilateral tensions, but they have not altered the underlying logic of U.S. trade remedy policy. While executive measures such as tariffs and export controls can be modified through political bargaining, anti-dumping and countervailing duty measures remain embedded in statutory procedures that are relatively insulated from diplomatic engagement. These measures have imposed significant costs on Chinese firms and reshaped their global strategies, yet they have not fundamentally undermined China’s broader industrial competitiveness.
As Ryan Hass recently argued, the objective of contemporary China-U.S. engagement is less to eliminate competition than to manage it within acceptable boundaries. Looking ahead, China-U.S. economic relations are likely to continue along a dual-track dynamic: political dialogue may ease short-term tensions, while entrenched trade remedies remain a persistent source of bilateral economic friction. For now, the “sunset” remains largely procedural rather than substantive.