New 4th Tranche of Tariffs on China Imports of $300 Billion under Consideration - Request for Comments by United States Trade Representative

Butzel first reported the Trump Administration’s decision to increase existing tariffs on $200 Billion worth of Chinese imports in our Client Alert of May 6^th. The alert explains that tariffs on products covered by List 3 of the Section 301 tariffs were to increase from 10 to 25%. This increase took effect on May 10^th. The Trump Administration has now issued a request for comments on a new list of proposed tariffs which is scheduled to appear in the May 15^th Federal Register. This proposed List 4 identifies possible tariffs on an additional $300 Billion worth of Chinese products imported into the US.

The list is not focused on traditional auto parts, as most imported auto parts from China are already covered by Lists 1 - 3 of the Section 301 tariffs. Instead, the new list covers nearly all remaining Chinese imports. The request for comments lays out a process for comments and objections to the proposed tariffs, sets a hearing date for June 17^th, and a deadline to request to testify as June 10^th.  Written comments can be submitted until June 24^th.

This proposed List 4 is apparently a response to China’s recent announcement that it plans to raise tariffs on U.S. importers.    China’s retaliatory tariffs will be imposed at the following levels:

• 25% tariffs on 2,493 items from current 10%
• 20% tariffs on 1,078 items from current 10%
• 10% tariffs on 974 items from current 5%
• 5% tariffs to continue on 595 items. Auto parts, which were initially on the list but have been exempted since December, are still excluded.

The proposed List 4 of Section 301 tariffs escalates the trade war with China - a ‘war’ the Trump Administration believes it can win. Butzel Long has worked with clients to submit comments and exclusion requests for Section 301 and 232 tariffs. We are able to assist any clients that have questions regarding these updates or who wish to file comments (or to testify) about the proposed List 4 of the Section 301 tariffs.

Leslie Alan Glick
202.454.2839
glick@butzel.com

Catherine Karol
313.225.5308
karol@butzel.com

Mitch Zajac
313.225.7059
zajac@butzel.com

Raul Rangel Miguel
202.454.2841
rangel@butzel.com

He Xian
517.372.4449
xian@butzel.com