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Aircraft Parts, aviation, Export, International Trade, Uncategorized

Chinese Tariffs Will Impact Aircraft Parts

The Chinese Government has announced tariffs that are applied against aircraft parts coming from the United States.

In August, the Chinese Government announced that it would be implementing tariffs against a wide variety of US goods (also against Canadian goods).  Those goods included a variety of aircraft parts.  The August announcement projected that the start date would be announced at a later time.  The announcement was made in Taxation Committee Announcement [2018] No. 6.  An English translation of this Announcement 6 can be obtained through Google.

On September 18, China announced that the proposed tariffs would be reduced in Taxation Committee Announcement [2018] No. 8 (September 18, 2018).  An English translation of this Announcement 8 can be obtained through Google.

The tariffs appear to be effective as of September 24.  The tariffs are divided across four annexes.  It appears that aircraft seats and refurbished aircraft tires are subject to 10% tariffs under annex two, and other aircraft parts are subject to 5% tariffs under annexes three and four.  A partial list of aircraft articles subject to tariffs follows (with Chinese tariff code followed by a description):

Annex 2 (originally proposed at 20% tariff – now appears to have been reduced to 10% tariff in Announcement 8)

94011000 Aircraft seat
40121300 Refurbished tire for aircraft

Annex 3 (originally proposed at 10% tariff – now appears to have been reduced to 5% tariff in Announcement 8)

40113000 New pneumatic rubber tires for aircraft
84071010 Output power ≤298kw aircraft ignition engine

Annex 4 (5% tariff)

85112010 Ignition magneto, permanent magnet DC generator, magnetic flywheel for locomotives, aircraft and ships
85113010 Distributors and ignition coils for locomotives, aircraft and ships
85115010 Other locomotives, aircraft, and marine generators
85119010 Electric ignition and starting device parts for locomotives, boats and aircraft
85392120 Tungsten halogen lamps for trains, aircraft and ships
85393120 Hot cathode fluorescent lamps for trains, aircraft and ships
85393920 Other discharge lamps for trains, aircraft and ships
88021100 Helicopter with no load weight ≤ 2 tons
88022000 Small aircraft and other aircraft
88023000 Medium aircraft and other aircraft
88039000 Other unnamed aircraft and spacecraft parts

About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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