Comments Matters For Companies Making Exclusion Requests

Despite being overshadowed by COVID-19 the last few months, the trade war rages on and Section 301 tariffs remain in place for most imports from China. While the Office of the U.S. Trade Representative (USTR) has established a process for companies to request exclusions, it continues to reject most of these requests.

“While we’d obviously love to see USTR grant more exclusions and extensions, especially as businesses struggle with the financial impacts of COVID-19, the most important thing manufacturers and suppliers can do is file comments supporting exclusions and extensions for Chinese imports that are important to their business,” said RV Industry Association Senior Manager of Government Affairs Samantha Rocci. “Comments matter. The number of extension requests that have been granted without them is zero. You can’t win if you sit out of the game.”

Since 2018, over 50,000 tariff exclusion requests have been filed by U.S. businesses. A study done by the Mercatus Center at George Mason University showed that as of June 8, 2020, 34 percent of List 1 exclusion requests were approved, 37 percent of List 2, 5 percent of List 3, and 1.9 percent of List 4a requests.

It is worth noting that the majority of the List 4a requests remain pending, which is reflected by the incredibly small number of approved requests for that list. Most of the requests that have been approved on that list are for medical equipment that have been prioritized during the pandemic.

While these numbers may look discouraging, zero is worse. That is the number of exclusions that have been extended without supporting comments.

The RV Industry Association publishes updates on all open comment periods on the Association website and in our newsletters and stands ready to file comments on behalf of any members who use imports on any of the Section 301 lists. Currently, extension comments are open for List 2 exclusions granted in September and October of 2019 and List 4 exclusions granted in March, May and June of 2020. The deadline for comment on extension of these List 2 and List 4 exclusions is July 30, 2020. Members can submit comments using USTR’s online portal.

For more information please contact Samantha Rocci at srocci@rvia.org.