In April, when USTR published the original list, it gave interested parties the opportunity to appear at public hearings and submit written comments. We’re now seeing a similar process for this new proposed list:
- Requests to appear at public hearings due July
24, 2019 - Submission of written comments due Aug. 5, 2019
- Public hearing will convene on Aug. 5, 2019 in
Washington, DC
The new list contains 89 HTS subheadings, covering goods such as fermented milk, various cheeses, olives, fruit, coffee, pasta, meats, and metal products. USTR warned that duties on the final lists could be up to 100% of the value of the products. These retaliatory tariffs stem from a conflict that dates back to 2004, over Boeing and Airbus subsidies.
Actions to Consider
If you import goods from this new list of 89 subheadings, we urge you to submit comments, as a number of commenters on past tariff cases were able to get their products removed from the initial list. Our affiliated attorney Tom O’Donnell has taken companies through the comments process and he, along with the rest of our affiliated team of Customs attorneys, is ready to help companies with this critical first step.
Importers and manufacturers of goods on either list should stay updated on the status of the tariffs. Previous tariff actions on Chinese-origin goods have included a procedure to request an exclusion of a particular product; if these proposed tariffs on EU-origin goods are imposed, there may be a similar exclusion process as well.
This blog is provided for informational and educational purposes only and does not constitute legal advice, and is not intended to form an attorney-client relationship. Please contact your regular FDAImports representative for additional information.
