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Tariff update: NATM explains exclusion process

July 11, 2018
Looking for relief from the latest round of tariffs on Chinese products? NATM outlines what to do, and by when.

With tariffs on $34 billion in Chinese goods taking effect last week, including on materials critical to transportation equipment manufacturers, the Office of the U.S. Trade Representative (USTR) has published details of the process to obtain product exclusions and submit objections.

This round of trade sanctions, under Section 301, covers 818 tariff lines on products imported from China under the U.S. response to China’s unfair trade practices related to the forced transfer of U.S. technology and intellectual property, according to the USTR notice.

To help its members make sense of the exclusion process, the National Association of Trailer Manufacturers (NATM), with the support of the government affairs representatives at K&L Gates, has broken down the 10-page guidance into some key points:

  • Exclusions will be made on a product basis. A particular exclusion will apply to all imports of the product, regardless of whether the importer filed a request.
  • If USTR grants a product exclusion, tariffs paid by the importers will be refunded retroactive to July 6, 2018. The exclusion will be effective for one year (through July 5, 2019).
  • The deadline for filing a product exclusion request is October 9, 2018.
  • Interested parties must submit a separate request for each product. Each request must specifically identify a particular product, and provide supporting data and the rationale behind the requested exclusion.
  • USTR wants interested parties to use a "request form" when filing their exclusion request.
  • Interested parties may provide confidential information, but must also file a public version of the request.
  • Following public posting of the filed request on, interested parties will have 14 days to file responses to the request for product exclusion.  After the close of the 14-day response period, interested parties will have an additional 7 days to reply to any responses received in support of or opposition to the request.

More information about the process as well as additional background on the tariffs can be found here