Tariff Exclusion Extensions Considered for China List 1

The Office of the U.S. Trade Representative (USTR) is considering an extension of up to 12-months from the Section 301 additional tariffs on the third set of exclusions on List 1 goods from China.  Comments may be submitted to the USTR between February 16 and March 16.

List 1 goods, valued at $34 billion, have been subject to an additional 25% tariff since July 6, 2018, and the third set of exclusions, issued in April 2019, is set to expire on April 18, 2020.  The third set of exclusions are reflected in 21 specially prepared product descriptions, which covered 348 separate exclusion requests, and include:


HTSUS Subheading Product Description
8413.19.0000 Pumps designed for countertop appliances for serving beer, the foregoing that control the level of carbonation by means of sonic waves
8420.10.9080 Roller machines designed for cutting, etching or embossing paper, foil or fabric, manually powered
8421.21.0000 Water oxidizers and chlorinators
8425.39.0100 Ratchet winches designed for use with textile fabric strapping
8428.33.0000 Continuous action elevators and conveyors, designed to convey mineral materials
8431.20.0000 Counterweight castings of iron or steel designed for use on fork lift and other works trucks
8431.20.0000 Tines, carriages, and other goods handling apparatus and parts designed for use on fork lift and other works trucks
8466.93.9885 Parts of drill sharpening machines
8479.90.9496 Outer shells of hydraulic accumulators, of iron or non-alloy steel, cylindrical with hemispherical heads on each end
8479.90.9496 Parts of mechanical awnings and shades
8479.90.9496 Reject doors, pin protectors, liners, front walls, grates, hammers, rotor and end disc caps, and anvil and breaker bars, of iron or steel, the foregoing parts of metal shredders
8479.90.9496 Steering wheels designed for watercraft, of stainless steel, having a wheel diameter exceeding 27 cm but not exceeding 78 cm
8481.10.0090 Pressure regulators of brass or bronze, whether high or low inlet type, having a rated flow rate of 55,000 – 150,000 BTU/hr, maximum inlet pressure of 0.17 MPa to 1. 72 MPa, inlet connection with POL or thread type of fitting
8481.90.9040 Pipe brackets of aluminum, each with 4 ports, the foregoing measuring 27.9 cm x 20.3 cm x 17.8 cm and weighing 11.34 kg, designed for installation into air brake control valves
8481.90.9040 Push pins and C-poles of steel, designed for use in variable force solenoid valves
8482.10.5032 Ball bearings of a width not exceeding 30 mm
8504.90.9690 Inductor baseplates of aluminum, each with a length measuring 149.20 mm or more but not over 275 mm, with a width measuring 119.40 mm or more but not over 232 mm and with a depth of 10.50 mm or more but not over 19 mm, with a weight of0.48 kg or more but not over 3.2 kg
8515.90.4000 Parts of soldering irons and soldering machines
8536.50.9065 Motor vehicle gear shift switch assemblies, comprised of a plunger, connector and gear shift lever
8536.50.9065 Pressure switches designed for use in heat pumps and air-conditioning condensers having a rating of 1.90 megapascals or more but not over 4.55 megapascals
9030.33.3800 Instruments for measuring or checking voltage or electrical connections; electrical circuit tracers

The USTR’s focus of the evaluation will be whether the product remains available only from China, and products will be evaluated on a case-by-case basis.

Interested stakeholders, including importers, law firms, and trade associations, of the excluded products should complete both Form A and Form B in order to be considered for the extension.

Commenters filling out Form A must provide the following information:

  • Publication date of the Federal Register notice containing the relevant exclusion, available by clicking here
  • Full product description and 10-digit HTSUS number for the excluded product
  • Whether the product is subject to an antidumping or countervailing duty order
  • Whether the commenter supports or opposes extending the exclusion and why
  • Whether the excluded product or comparable products are available from sources in the U.S. or third countries, and any changes in the global supply chain for the product since July 2018 (or any other relevant industry developments)

Commenters filling out Form B should be prepared to provide the following information, which will be treated as business confidential:

  • Efforts undertaken since July 18 to source the product from the U.S. or third countries
  • The value and quantity of the excluded product purchased in 2018 and the first half of 2019 and whether these purchases are from a related company
  • Whether Chinese suppliers have lowered their prices for the excluded product following the imposition of tariffs
  • The value and quantity of the excluded product purchased from domestic and third-country sources in 2018 and the first half of 2019
  • Any efforts undertaken since July 2018 to source the excluded product from the U.S. or third countries
  • The commenter’s gross revenue for 2018 and the first half of 2019
  • Whether the excluded product is sold as a final product or as an input
  • Whether the imposition of tariffs on the excluded product will result in severe economic harm to the commenter or other U.S. interests
  • Any additional information in support of the extension request