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Applying for Section 301 Tariff Exclusions on Products from China

Last Friday, the Trump Administration began imposing 25% import duties on the first list of Chinese goods, including certain parts used in auto shredder operations. China also responded with its own list of products to face duties entering China, though it does not include any scrap or other products of note to the recycling industry.

Nevertheless, the tariff measures signal that the two governments have made no progress to resolve trade tensions. In addition to reviewing a second list of Chinese goods to face tariffs, the Administration is reportedly evaluating future opportunities for tariffs against products from China. It is expected that China will retaliate in kind to any future tariff measures.

The Administration has published guidelines for companies to apply for certain products to be excluded from the tariffs. ISRI will be submitting comments, and welcomes member input. But we also encourage companies that are greatly impacted by these tariffs to also submit exclusion requests. The requests must include the following information:
  • Identification of the particular product in terms of physical characteristics (e.g., dimensions, material composition or other characteristics) ... requests will not be considered if the product is identified by producer, importer, consumer, chief use, or trademarks/tradenames;
  • 10 digit harmonized tariff subheading code (e.g., 8479.90.94.65 ... Of machines or mechanical appliances for treating metal – auto shredder wear parts);
  • Annual quantity and value of the Chinese-origin product in each of the last three years (if precise info is not available, provide an estimate and explain the basis for the estimation);
  • A rationale that includes:
    • Whether the product is available only from China, and if not, provide information on U.S. or third country sources for the particular product or comparable product; 
    • Whether the imposition of additional duties on the product would cause severe economic harm;
    • Whether the product is strategically important or related to 'Made in China 2025' or other Chinese industrial programs.

Although the deadline for submission is October 9, we recommend that submissions be made as early as possible. Tariffs will have to be paid in the meantime. If a favorable outcome is received, there will be a process for the duties to be refunded. 

Furthermore, there will be a process to respond to others' comments. For example, if a party objects to our exclusion request, we can counter the objection. Likewise, if a party petitions for a product critical to the recycling industry remain on the tariff list, we will have an opportunity to respond.

Please contact Adina Renee Adler with input, questions, or requests for support.
 

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