On June 15, 2018, the Trump Administration announced that additional tariffs will be imposed on certain goods from China under Section 301 of the Trade Act of 1974. A press release issued by the Office of the United States Trade Representative (USTR), states that beginning on July 6, 2018, an additional 25% tariff will be imposed on 818 tariff lines (“List 1”) of the original 1,333 lines that were included on the proposed list originally published by USTR on April 6.

The 818 tariff lines on List 1 primarily include machinery and machinery parts and components of Chapters 84 and 85 of the HTSUS, as well as a wide range of vehicles and vehicle parts. The complete list of the covered items on List 1 can be accessed at https://ustr.gov/sites/default/files/enforcement/301Investigations/List%201.pdf.

USTR also issued a second list of 284 tariff items proposed for becoming subject to the Section 301 duties (“List 2”). List 2 includes certain chemicals, plastics, metal articles, as well as additional articles of machinery and transportation. List 2 can be accessed at https://ustr.gov/sites/default/files/enforcement/301Investigations/List%202.pdf.

List 2 will be subject to a notice and comment process following which USTR will make a determination as to the products from List 2 that will become subject to the additional 25% duty. Details as to the timing of the process for finalizing List 2 are expected to be issued in the coming weeks.

USTR indicated that it will be providing an opportunity for importers and other affected parties to request an exclusion of particular products from the additional duties. Details on the process for requesting these exclusions will be issued in the next few weeks.

Like other recent trade developments, the imposition of Section 301 tariffs has taken several turns since first being proposed in March. If you have any questions, please contact Joseph Spraragen ([email protected]) or any of our attorneys.