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.