The U.S. Trade Representative has published a list of additional products excluded from the Section 301 tariffs on Chinese origin products. Additional duties of 25% ad valorem were applied to these products as of July 6, 2018. The exclusions are retroactive to July 6, 2018 and will extend for one year after publication of the April 18, 2019 notice. A complete list of the 21 product areas covered by this exclusion is provided below.

This is the third set of exclusions that the U.S. Trade Representative has applied to the list. Importers had the opportunity to file exclusion requests until October 9, 2018. An initial set of exclusions was announced in December 2018, and a second set in March 2019. With this third set, the U.S. Trade Representative grants relief to importers of 21 specially prepared product descriptions that would otherwise be subject to the 25% additional tariff.

On a related note, the U.S. Trade Representative recently announced that the administration is considering imposing additional tariffs of up to 100% on certain products imported from the European Union. The legal authority referenced in the April 2019 announcement is Section 301 of the Trade Act of 1974, i.e. the same legal authority under which the 10% and 25% additional duties were imposed on goods from China. The list includes many consumer goods, as well as industrial products. Additional information is available here:

Should you have any questions regarding the topics discussed herein, or wish to participate in the process with respect to the duties being considered on EU products, please do not hesitate to contact our office.

New List of Products Excluded from Sec. 301 Tariffs on Chinese Origin Imports:

  1. Pumps designed for countertop appliances for serving beer, the foregoing that control the level of carbonation by means of sonic waves (described in statistical reporting number 8413.19.0000);

  2. Roller machines designed for cutting, etching or embossing paper, foil or fabric, manually powered (described in statistical reporting number 8420.10.9080)

  3. Water oxidizers and chlorinators (described in statistical reporting number 8421.21.0000)

  4. Ratchet winches designed for use with textile fabric strapping (described in statistical reporting number 8425.39.0100)

  5. Continuous action elevators and conveyors, designed to convey mineral materials (described in statistical reporting number 8428.33.0000)

  6. Counterweight castings of iron or steel designed for use on fork lift and other works trucks (described in statistical reporting number 8431.20.0000)

  7. Tines, carriages, and other goods handling apparatus and parts designed for use on fork lift and other works trucks (described in statistical reporting number 8431.20.0000)

  8. Parts of drill sharpening machines (described in statistical reporting number 8466.93.9885)

  9. Outer shells of hydraulic accumulators, of iron or non-alloy steel, cylindrical with hemispherical heads on each end (described in statistical reporting number 8479.90.9496)

  10. Parts of mechanical awnings and shades (described in statistical reporting number 8479.90.9496)

  11. Reject doors, pin protectors, liners, front walls, grates, hammers, rotor and end disc caps, and anvil and breaker bars, of iron or steel, the foregoing parts of metal shredders described in statistical reporting number 8479.90.9496)

  12. Steering wheels designed for watercraft, of stainless steel, having a wheel diameter exceeding 27 cm but not exceeding 78 cm (described in statistical reporting number 8479.90.9496)

  13. Pressure regulators of brass or bronze, whether high or low inlet type, having a rated flow rate of 55,000 – 150,000 BTU/hr, maximum inlet pressure of 0.17 MPa to 1.72 MPa, inlet connection with POL or thread type of fitting (described in statistical reporting number 8481.10.0090)

  14. Pipe brackets of aluminum, each with 4 ports, the foregoing measuring 27.9 cm x 20.3 cm x 17.8 cm and weighing 11.34 kg, designed for installation into air brake control valves (described in statistical reporting number 8481.90.9040)

  15. Push pins and C-poles of steel, designed for use in variable force solenoid valves (described in statistical reporting number 8481.90.9040)

  16. Ball bearings of a width not exceeding 30 mm (described in statistical reporting number 8482.10.5032)

  17. Inductor baseplates of aluminum, each with a length measuring 149.20 mm or more but not over 275 mm, with a width measuring 119.40 mm or more but not over 232 mm and with a depth of 10.50 mm or more but not over 19 mm, with a weight of 0.48 kg or more but not over 3.2 kg (described in statistical reporting number 8504.90.9690)

  18. Parts of soldering irons and soldering machines (described in statistical reporting number 8515.90.4000)

  19. Motor vehicle gear shift switch assemblies, comprised of a plunger, connector and gear shift lever (described in statistical reporting number 8536.50.9065)

  20. Pressure switches designed for use in heat pumps and air-conditioning condensers having a rating of 1.90 megapascals or more but not over 4.55 megapascals (described in statistical reporting number 8536.50.9065)

  21. Instruments for measuring or checking voltage or electrical connections; electrical circuit tracers (described in statistical reporting number 9030.33.3800)

Information Provided by GDLSK (Grunfeld, Desiderio, Lebowitz, Silverman and Klestadt, LLP


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