President Trump announced March 22 his intent to levy additional tariffs of 25 percent on goods imported from China following a Section 301 investigation of China’s acts, policies, and practices on intellectual property.

According to press reports, the tariffs could target as many as 1,500 tariff lines representing $50 billion to $60 billion worth of imports. The Office of the U.S. Trade Representative states that sectors subject to the proposed tariffs will include aerospace, machinery, and information communication technology. In addition, USTR Robert Lighthizer indicated in testimony to Congress that the administration considered products that the U.S. can or does source from other countries so that the effect on consumers of any tariff on such products from China would be minimized. This could broaden the tariff list to include other sectors, such as apparel or footwear.

A proposed list of affected products and tariffs will be published in the Federal Register no later than April 6. Comments will be due 30 days from publication of that notice, which will also announce a date for a public hearing. This will provide an opportunity for companies to advocate for the inclusion or exclusion of specific products. After USTR has completed its review and analysis of the comments submitted it will publish a final list of products and tariff increases and implement any such tariffs.

Other measures announced by the president following USTR’s Section 301 investigation include (a) filing a World Trade Organization case against China’s “discriminatory technology licensing practices” and (b) restrictions to be proposed by the Treasury Department on investment by China in sensitive U.S. industries or technologies.

Companies importing from China should act now to assess the possible impact of these additional tariffs on their supply chains. Sandler, Travis & Rosenberg can help companies review their import data in the Automated Commercial Environment to evaluate potential exposure and how it might be mitigated.

For more information, please contact Thomas G. Travis at (305) 894-1001 or Nicole Bivens Collinson at (202) 730-4956.

Copyright © 2021 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.


J. Nicole Bivens Collinson
President, International Trade & Government Relations
Thomas G. Travis
Managing Partner

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