July 10, 2019 - Section 301 Tariffs on Imports from China – Latest Updates

For members affected by the Office of the U.S. Trade Representative's (USTR) Section 301 tariffs on imports from China, below are the latest updates on the four tariff lists.

How to Navigate the Section 301 Tariffs

Not sure if or how you are impacted by the Section 301 tariffs? Start with USTR's HTS search engine to confirm that the product is included in the Section 301 tariff action and identify the corresponding tariff list.

Additional details for each tariff list can also be found on our Section 301 resource page.

Tariff List 1 – New List of Excluded Products Issued

On July 9, USTR published a notice of additional List 1 products excluded from Section 301 tariffs on imports from China. The list of excluded products includes but is not limited to certain:

  • Oil pump housings
  • Impellers
  • Parts of oil and gas extraction beam pumps
  • Pump Parts (bases, casings and bodies, covers, expellers, grease cups, liners, manifolds, shaft castings, throatbush, volutes, bases)
  • Compressors used in AC equipment
  • Check valves
  • Bodies of certain valves
  • Flanged wheel hub bearing units
  • Inner bearing rings
  • Non-grooved pulleys
  • Hubs for conveyor pulleys

Please review the full notice to confirm if your HTS code is on the list. The exclusions are retroactive to when the 25% tariff went into effect on July 6, 2018. Previous product exclusion notices are listed below.

Tariff List 2 – Tariffs in Effect; Exclusions Pending Review

Tariffs on Section 301 List 2 products imported from China went into effect on Aug. 23, 2018. Product exclusion requests were due Dec. 18, 2018. As of July 5, 2019:

  • No exclusions have been granted
  • ~1300 exclusion requests have been denied
  • ~1600 exclusion requests are pending review

Tariff List 3 – Product Exclusions Due Sept. 30

On June 30, USTR opened the electronic submission portal for product exclusions requests subject to Section 301 List 3 tariffs on imports from China. The deadline to submit requests is Sept. 30, 2019 and interested parties have 14 days to respond, in support or opposition for the request.

The exclusion request form requests specific product identifying details, company information, and supporting data and rationale for the requested exclusion.

Products on tariff List 3 went into effect on Sept. 24, 2018 at 10% tariff rate and increased to 25% tariff rate on May 10, 2019. Exclusions will be retroactive to when the tariff went into effect on Sept. 24, 2018.

Trade Counsel to Assist Members with Filing Exclusion Requests

The Auto Care Association has partnered with the law firm Dentons US LLP to assist members with the creation and submission of exclusion requests for Section 301 List 3 products.

If you are interested in retaining Dentons for assistance, please click here for additional information. A product exclusion questionnaire (linked on the page) must submitted to Dentons by July 31, 2019.

Tariff List 4 – Tariffs on Hold

President Trump is holding off on imposing new tariffs on Section 301 List 4 products imported from China while the two countries resume trade negotiations. President Trump and President Xi of China met on the sidelines during the G20 summit in Osaka, Japan at the end of June.

As part of the temporary hold on new tariffs, China agreed to purchase more U.S. agricultural products and the U.S. agreed to lift some restrictions on Huawei.

Deadline Approaching for 2019 People Award Nominations

The Import Vehicle Community People Awards recognize men and women who have made significant contributions to the import auto care industry.

We welcome your nominations if you know of a deserving candidate for the 2019 Import Vehicle Community People Awards. The deadline to submit nominations is July 31, 2019.

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