Extension of Tariff Exclusion Allows Recyclers to Provide Renewable Source of Materials for Manufacturing

Dec 19, 2022, 10:18 AM
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Hannah Zuckerman
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On Friday, Dec. 16, 2022, the Office of the United States Trade Representative (USTR) announced a nine‑month extension of 352 product exclusions in the China Section 301 Investigation that had been scheduled to expire at the end of 2022.

These exclusions—which include the tariff exclusion on shredder wear parts—were initially reinstated in March and the extension will help align further consideration of these exclusions with the ongoing comprehensive four-year review. This means shredder wear parts imported from China will not be assessed the additional 25% tariff during this extension period.

“Extending the Section 301 tariff exclusion on auto shredder wear parts will positively impact more than 200 U.S. auto shredders operating throughout the United States,” says Robin Wiener, ISRI president. “The exclusion will allow these businesses to continue to provide a renewable source of high-quality materials for the everyday items and essential infrastructure people depend on.”

ISRI has advocated on behalf of its members on this issue since the Trump administration imposed the tariff in July 2018. The USTR granted an exemption April 18, 2019, and in 2020 the government allowed companies and organizations to request continuation of the exemption for one year, which was granted to all  who requested it.

In October 2021, when the USTR invited public comments on whether to reinstate previously extended exclusions, which included shredder wear parts, ISRI was quick to submit comments. The association explained why the exclusion for shredder wear parts should be reinstated and how the tariff has caused economic harm to U.S. small businesses, employment, manufacturing output, and critical supply chains.

In its petition, ISRI explained that these shredder wear parts are essential to annually process more than 77 million tons of ferrous materials used to make new products including automobiles, refrigerators, washers  and dryers, air conditioners, and heaters as well as building and houses. Without these parts, a key segment of the United States’ recycled materials industry would simply not be able to operate thereby hobbling the domestic steel industry that is dependent on recycled materials.

On March 23, 2022, USTR announced its determination to reinstate certain previously granted and extended product exclusions in the China Section 301 investigation retroactive to Oct. 21, 2021, extended through Dec. 31, 2022. ISRI once more petitioned the USTR for an exemption for shredder wear parts since the U.S. does not produce enough of these parts for the hundreds of U.S. shredders used to process automobiles and other ferrous and non-ferrous materials. After dozens of supporting comments were filed, the U.S. Trade Representative granted the exemption for these vital items.

On Friday, Dec. 16, 2022, the Office of the United States Trade Representative (USTR) announced...
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