Are you buying goods from China? Relying on Chinese suppliers? If you are, then the recent talk about tariffs has probably unnerved you, to say the least.
Aircraft parts have been specifically identified as a target for tariffs. This could mean a new 25% tariff imposed on every aircraft part imported from a supplier in China. But the fact that aircraft parts have been named does not necessarily mean that they will be subject to tariffs. There is still an opportunity to influence the final list.
The Office of the U.S. Trade Representative (USTR) has published information about their intended hearings on the China tariffs. The first key date is April 23 – that’s just two weeks away!! April 23 is the deadline for filing a request to appear, with a summary of your expected testimony.
USTR will review these comments before issuing a final tariff list.
So what sort of information is USTR seeking from the public? Comments should include the following information:
- The specific products to be subject to increased duties, including whether products listed in the Annex should be retained or removed, or whether products not currently on the list should be added.
- The level of the increase, if any, in the rate of duty.
- The appropriate aggregate level of trade to be covered by additional duties.
But you should also consider developing testimony about these important topics:
- Whether imposing increased duties on your articles would be practicable or effective to influence China’s objectionable acts, policies, and practices (concerning intellectual property);
- Whether maintaining or imposing additional duties on your article would cause disproportionate economic harm to U.S. interests, including small- or medium-size businesses and consumers;
- Whether your articles have benefited from Chinese industrial policies, including Made in China 2025 (such articles are considered to be primary targets, so if your article did not benefit then this is an argument for possibly removing it);
- The amount of disruption to the U.S. economy (a disruptive effect on America is a reason to reduce or remove the proposed tariff);
- Legal or administrative constraints on the tariff (such as the Agreement on Civil Trade in Aviation);
- Likely impact on U.S. consumers (USTR has ranked products in order to select those with the lowest consumer impact – but may not have considered the secondary consumer effect on the cost of air travel).
Here is the USTR schedule for the data collection effort:
- April 23, 2018: Due date for filing requests to appear and a summary of expected testimony at the public hearing and for filing pre-hearing submissions
- May 11, 2018: Due date for submission of written comments
- May 15, 2018: The Section 301 Committee will convene a public hearing in the main hearing room of the U.S. International Trade Commission, 500 E Street SW Washington, DC 20436 beginning at 10:00 am.
- May 22, 2018: Due date for submission of post-hearing rebuttal comments