US Govt.  Announces the Exclusions of Certain Chinese Products from Section 301

United States Trade Representative (the “USTR”) has granted exclusion from Section 301 of List 3 products of China. When the US President Trump signed legislation avoiding a shutdown then it was announced that there will be a Section 301 – List 3 exclusion process! This exclusion process will be put in place for List 3 products by March 17, 2019.
US Government has granted 984 individual product exclusion requests that involves 21 separate HTS codes from the additional tariffs of 25% that went into effect on July 6, 2018 on $34 billion worth of imports from China. The grant was published on December 28, 2018.

Notable Companies and Products Covered

Products that benefit from the exclusion: 

  • Injection or compression type molds for rubber or plastics (HTSUS 8480.71.80);
  • Single-row radial bearings having an outside diameter between 9 mm and 100 mm.
  • Single row radial bearing with a diameter under 9mm or over 100 mm have not been excluded (HTSUS 8482.10.5044, 8482.10.5048, and 8482.10.5052);
  • Linear-acting hydraulic engines and motors (HTSUS 8412.21.00);
  • Refrigerating or freezing equipment like ice making machines and drinking water coolers (HTSUS 8418.69.01)
  • Thermostats for air conditioning or heating systems (HTSUS 9032.10.00).
  • To view the Federal Register Notice with all the excluded product categories, click here

The requests were granted for several well established Chinese companies, a few well-known non-Chinese multinational companies and US affiliates. These companies have excluded products that include: automotive interiors, motor wheel covers, automotive plastic mold parts,  automotive advanced vision technology and safety, connectivity. Other products are listed such as:  efficiency systems for motor, ball bearings, plastic injection molding, and drinking water coolers.

There are a number of additional tariff mitigation strategies  available for both importers and exporters that can manage the effects of new tariff. 

 Tariff Mitigation Strategies 

  • Tariff Engineering
  • Free Trade Agreements
  • Foreign Trade Zones
  • Bonded Warehousing
  • Freight Consolidation
  • Drawback