STR analysis has identified certain types of importers that may be able to avoid anticipated new Section 301 tariffs related to forced labor. Importers should submit comments to this effect by the July 6 deadline.
The Office of the U.S. Trade Representative has proposed additional tariffs of 10-12.5 percent on imports from 60 economies following Section 301 investigations into the measures they have taken to prohibit imports of goods produced with forced labor.
These additional tariffs would be imposed on all products except those listed in annex A to this notice. These exceptions include (1) all articles and parts currently subject to section 232 tariffs, (2) raw materials that, if subject to the proposed tariffs, could lead to the unavailability of domestic supply, (3) products that could cause economy-wide disruptions if subject to the proposed tariffs, (4) certain products that cannot be grown or produced in sufficient quantities in the U.S. or obtained from other sources, (5) informational materials (e.g., books), donations, and accompanied baggage, and (6) articles for which additional tariffs may not contribute substantially to the elimination of the investigated acts, policies, and practices.
STR has identified two other potential exceptions to the anticipated tariffs.
- Imports of goods that are wholly the growth, product, or manufacture of a single country are unlikely to have been made with any inputs imported from one of the countries identified in the forced labor proposal.
- Imports by companies participating in CTPAT Trade Compliance, or that have achieved Tier 3 status within CTPAT, have visibility on forced labor issues built into their supply chains and therefore can make the argument that their imports should not be subject to the potential tariffs.
Companies meeting either of these additional criteria, or any of those listed by USTR, should therefore submit by the July 6 deadline comments seeking exemptions from the forced labor tariffs. They may also wish to participate in a public hearing scheduled for July 7.
Contact Ned Steiner or Said Ishak for further information or assistance in preparing and filing comments.
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