On June 15, the Office of the United States Trade Representative (USTR) announced plans to move ahead with Section 301 tariffs, which will be phased in. USTR has published a first list of 818 tariff lines, which is now final. U.S. Customs and Border Protection will collect the tariffs starting July 6.

A second list of 284 tariff lines includes new products that were not included in the April preliminary list published by USTR. This list is still subject to a public notice and comment period, including a public hearing, and is therefore likely to change. 

USTR also announced that companies may have an opportunity to request exclusions from tariffs on specific products. Details for the public comment process, hearing, and exclusion process are still outstanding and will be published in a forthcoming Federal Register notice.

AHRI staff has analyzed both tariff lists here. A summary follows:

• The first list of 818 tariff lines (finalized list)
  • AHRI member products include: boilers, pumps, compressors, furnaces, refrigerators, freezers, water heaters, heat exchangers, motors, and control equipment. 
• The second list of 284 tariff lines (list is subject to change)
  • AHRI member products include: heat exchangers, motors, and control equipment. 

On June 15, China announced that it will respond if the USTR implements the Section 301 tariffs. In April, China released a retaliatory list of 106 products imported from the U.S. that would be subject to a 25 percent tariff. AHRI staff did not identify any HVACR or water heating products on that list, an unofficial translation of which can be found here.

In a Presidential Statement published June 15, President Trump announced that the United States "will pursue additional tariffs if China engages in retaliatory measures...." AHRI will continue to track new developments and will update members accordingly.

Publication date: 6/15/2018

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