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 involve 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 has 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 several additional tariff mitigation strategies available for both importers and exporters that can manage the effects of the new tariff. 

 Tariff Mitigation Strategies 

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