USTR Update

Yesterday, the United States Trade Representative (USTR) proposed a 25% tariff on the remaining $300 million worth of goods coming from China, also known as List 4. Specific to the lighting industry, List 4 includes two notable HTS codes:

8414.51.30 (ceiling fans)
8539.50.00 (LEDs)

The list of affected HTS codes can be found here.
 
As far as timing goes, the official notice should be published in the Federal Register by the end of the week. A public meeting will be held, beginning on June 17 and requests to appear must be submitted by June 10. All comments for the record are due seven days after the public meeting concludes.
 
It is important to note that this week’s release is not final, as it is still in the proposal phase while USTR receives comments and conducts the public meeting. Details on how to participate in the public meeting or how to submit comments will be included in the Federal Register notice. Once that process closes, USTR will review everything, make a final determination and set an enforcement date. List 4 can be considered final when the determination is published in the Federal Register. 
 
Using history as a guide, the List 3 public meeting went on for days because of the amount of products under consideration. The same can be expected for List 4. USTR has typically released the final determination anywhere from one week to one month after the closing of the comment period, and then set an enforcement date from two weeks to one month after publication in the federal register. Therefore, an enforcement date for List 4 is probable for some time in July, right before Members of Congress go home for the August recess. It should also be noted that President Trump and Chinese President Xi Jinping could meet during next month’s G-20 summit.
 
Additional information will be forthcoming as it becomes available.
 

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