Additional Update on Section 301 Tariffs Involving China


In earlier client alerts (June 15, 2018 and April 4, 2018), we have discussed the proposed tariffs under section 301 against China that arose as a result of allegedly unfair Chinese intellectual property practices. The administration, in its openly declared trade war with China, has been expanding on the implementation of these duties and issued a new Federal Register Notice dated June 20, 2018. This notice sets out procedures for entry of products already determined to be subject to tariffs and assigns a special tariff number to be used to identify them in addition to the regular HTS number.  Products of China that are provided for in new HTSUS heading 9903.88.01, as established by Annex A of this notice that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on July 6, 2018, shall be subject to an additional duty of 25 percent ad valorem.

For the newly proposed products that have not been finalized, written submissions and hearings on the newly proposed list of products issued June 15th.

Below is the schedule for submission of comments and testimony as to the newly proposed products, which are described in Annex C.

All annexes and the complete text of the Federal Register notice here.

Comment and hearing deadline:

To be assured of consideration, you must submit comments and responses with respect to the proposed list of products in Annex C to this notice in accordance with the following schedule:

June 29, 2018: Due date for filing requests to appear and a summary of expected testimony at the public hearing and for filing pre-hearing submissions.

July 23, 2018: Due date for submission of written comments.

July 24, 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 9:30 a.m.

July 31, 2018: Due date for submission of post-hearing rebuttal comments.

Leslie Alan Glick

Catherine Karol

Mitch Zajac

Raul Rangel Miguel

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