SECTION 301 TARIFFS ON CHINESE GOODS EFFECTIVE JULY 6, 2018

The Trump administration announced on June 15, 2018 a list of 818 products from China that will be subject to an additional 25 percent duty for goods as of July 6, 2018.  The administration also released a list of 284 other tariff lines which were not included in any previous proposal on which additional duties could be imposed following a public notice and comment process. The USTR will convene a public hearing regarding the second list of tariff lines on July 24, 2018. Interested parties are required to file a request to appear at the hearing and a summary of expected testimony by June 28, 2018. Written comments pertinent to the second list of tariff lines are due by July 23, 2018. Rebuttals to those comments are due by July 31, 2018.

Please click on the link US Trade Representative Link to the Section 301 Duties Fact Sheet

These tariffs are being imposed as part of the U.S. response to China’s unfair trade practices related to improperly obtaining U.S. technology and intellectual property.   The proposed list of 1,333 tariff lines for products was first introduced on April 6, 2018.

The USTR will soon provide an opportunity for the public to request the exclusion of particular products from the additional duties subject to this action. It will issue a notice in the Federal Register with details regarding this process within the next few weeks.

Your company should immediately examine these lists and conduct classification reviews of products to determine if you are or might be affected by the new tariffs.  We recommend that you consider utilizing the exclusion process once it is announced to request exclusions of specific products from the tariffs.

According to the Office of the U.S. Trade Representative, the two lists contain products from industrial sectors that contribute to or benefit from the “Made in China 2025” industrial policy, which include aerospace, information and communications technology, robotics, industrial machinery, new materials, and automobiles. USTR states that the lists do not include goods cellular telephones or televisions.

The first list comprises 818 products with a total import value of $34 billion, down from the 1,300 goods valued at $50 billion that had originally been proposed. A large percentage of the goods on this list are from HTSUS Chapters 84, 85, 87, 88, and 90, such as engines and motors; construction, drilling, and agricultural machinery; machines for working minerals, glass, rubber, or plastic; rail locomotives and rolling stock; motor vehicles and motorcycles; helicopters and airplanes; and testing, measuring, and diagnostic instruments and devices.

The second list comprises 284 tariff lines with a total import value of about $16 billion. Many of these products are also classified in Chapters 84, 85, 97, and 90, but various products in chapters 27, 34, 38, 39, 70, 73, 76, and 89 are also included. Affected goods include plastics and plastic products; industrial machinery; machinery for working stone, ceramics, concrete, wood, hard rubber or plastic, and glass; cargo containers; tractors; and optical fibers.