Additional Tariffs on Chinese Goods Effective July 6; Exclusions May be Requested

The Trump administration announced June 15 a list of 818 products from China that will be subject to an additional 25 percent duty as of July 6. The administration also released a list of 284 other tariff lines – not included in any previous proposal – on which additional duties could be imposed following a public notice and comment process. These tariffs are being imposed after a Section 301 investigation determined that China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation are unreasonable and discriminatory.

Companies should immediately examine these lists and conduct classification reviews of their products to determine if they are or might be affected by the new tariffs. In addition, companies should consider utilizing a process to be announced in the next few weeks to request exclusions of specific products from the tariffs.

According to the Office of the U.S. Trade Representative, the two lists focus on 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 commonly purchased by U.S. consumers such as cellular telephones or televisions.

1st list of Products:

2nd List of Products:

For record keeping provision, please read:

USTR will soon provide information how to request exclusion. If you would like to request for exclusion, please contact Flegenheimer Int’l and we can refer you to consultants/lawyers that can help.

The additional 25% duties on the Chinese goods will affect the bond amounts. The importer is responsible to ensure its bond is sufficient under informed compliance requirements. Remember that the bond amount is calculated based on 10% of the total duties, taxes, and fees (including ADD/CVD) paid or payable in the last 12 months. The effective and anniversary date of the bond has no bearing on the calculation. If you import any products that are subject to these duty hikes, you may be receiving a letter from CBP to increase the value of your bond