USTR: Extensions, Exclusions And Tariffs - Oh My!

CHINA 301 TARIFFS: USTR CONSIDERS EXTENSIONS OF JUNE LIST 1 EXCLUSIONS

The Office of the U.S. Trade Representative (USTR) has published notice in the Federal Register announcing that it will consider extending exclusions from Section 301 tariffs on certain products. This latest announcement covers List 1 product exclusions granted in USTR's June 2019 notice currently set to expire on June 4, 2020. Accordingly, USTR is providing for public comment regarding whether to extend particular exclusions granted in the June 2019 notice.

The covered exclusions include one entire ten-digit Harmonized Tariff Schedule (HTS) subheading and 88 specially prepared product descriptions determined by USTR. Product exclusions granted an extension by USTR will be exempt from Section 301 duties for up to an additional 12 months. USTR has made no announcement regarding the continuation of these extensions after the additional 12-month period lapses.

Interested parties can submit comments regarding the extension of a particular exclusion granted in the June 2019 notice through USTR's online portal. Parties may submit comments beginning April 1 through April 30, 2020.

Thus far, USTR has granted extensions for two other rounds of product exclusions. After granting only six of 31 exclusions set to lapse in December 2018, USTR determined last week that it will extend only 11 of 33 product exclusions set to expire on March 25, 2020.

Separately, USTR has an open docket for comment on the possible extension of other certain List 1 product exclusions. The comment period for extensions of exclusions granted on May 14, 2019 is set to close April 12, 2020. A link to all 301 exclusions granted so far can be found here. 

As always, we encourage RV Industry Association members to review the list of exclusions set to expire so that you do not unknowingly lose an exemption important to your manufacturing operations.

USTR ANNOUNCES NEW LIST 3 EXCLUSIONS AMID CORONAVIRUS AND ECONOMIC DOWNTURN

On March 26, the Office of the U.S. Trade Representative (USTR) will publish its latest announcement of a new round of exclusions covering a broad range of products on List 3 of the Section 301 tariff action. The notice contains exclusions for one entire 10-digit HTS subheading, 176 specifically identified product descriptions, and amends a previous announcement to add five new exclusions specifically for ventilation fans. This announcement comes amid increased calls from the U.S. business community for relief from the Section 301 tariffs during the economic downturn caused by the global coronavirus pandemic.

In addition to the exclusions for ventilation fans, products covered in this round include motor vehicle windshields and rear-view mirrors, printed circuit boards, AC motors, shelves, cabinets, lamps, outdoor tables, tires, and textile fabrics, among other products. 

These exclusions are applicable for any importer of the excluded merchandise, regardless of whether the importer filed an exclusion request. As with previous List 3 exclusion rounds, these exclusions apply retroactively for goods entered for consumption or withdrawn from warehouse on or after September 24, 2018 and will remain in effect until August 7, 2020.  

For questions or more information, contact Samantha Rocci at srocci@rvia.org.