The Office of the U.S. Trade Representative (“USTR”) announced today that it will extend certain product exclusions scheduled to expire on July 9, 2020, for twelve (12) specific products which were subject to Section 301 List 1 tariffs at a rate of 25%.  As a result of these extensions, the exclusion extensions will now expire on December 31, 2020.

The products for which the Section 301 exclusions were extended include the following:

(1) Direct-acting and spring return pneumatic actuators, each rated at a maximum pressure of 10 bar and valued over $68 but not over $72 per unit (described in statistical reporting number 8412.39.0080);

(2) Pump casings and bodies (described in statistical reporting number 8413.91.9080 prior to January 1, 2019; described in statistical reporting number 8413.91.9095 effective January 7 1, 2019 through December 31, 2019; described in statistical reporting number 8413.91.9085 or 8413.91.9096 effective January 1, 2020);

(3) Pump covers (described in statistical reporting number 8413.91.9080 prior to January 1, 2019; described in statistical reporting number 8413.91.9095 effective January 1, 2019, through December 31, 2019; described in statistical reporting number 8413.91.9085 or 8413.91.9096 effective January 1, 2020);

(4) Pump parts, of plastics, each valued not over $3 (described in statistical reporting number 8413.91.9080 prior to January 1, 2019; described in statistical reporting number 8413.91.9095 effective January 1, 2019, through December 31, 2019; described in statistical reporting number 8413.91.9085 or 8413.91.9096 effective January 1, 2020);

(5) Compressors, other than screw type, used in air conditioning equipment in motor vehicles, each valued over $88 but not over $92 per unit (described in statistical reporting number 8414.30.8030);

(6) Structural components for industrial furnaces (described in statistical reporting number 8514.90.8000);

(7) Aluminum electrolytic capacitors, each valued not over $3.20 (described in statistical reporting number 8532.22.0085);

(8) Rotary switches, rated at over 5 A, measuring not more than 5.5 cm by 5.0 cm by 3.4 cm, each with 2 to 8 spade terminals and an actuator shaft with D-shaped cross-section (described in statistical reporting number 8536.50.9025);

(9) Rotary switches, single pole, single-throw (SPST), rated at over 5 A, each measuring not more than 14.6 cm by 8.9 cm by 14.1 cm (described in statistical reporting number 8536.50.9025);

(10) Zinc anodes for use with machines and apparatus for electroplating, electrolysis or electrophoresis (described in statistical reporting number 8543.30.9080);

(11) Weather station sets, each consisting of a monitoring display and outdoor weather sensors, having a transmission range of not over 140 m and valued not over $50 per set (described in statistical reporting number 9015.80.8080); and

(12) Multi-leaf collimators of radiotherapy systems based on the use of X-ray (described in statistical reporting number 9022.90.6000).

USTR requested comments in April on whether or not it should extend the exclusions, which were originally issued on July 9, 2019. Over 100 products which were previously granted exclusions and which were not listed in this extension notice will now expire on July 9, 2020.

To view the full list of extended product exclusions, please click here.

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Nithya Nagarajan is a Washington-based partner with the law firm Husch Blackwell LLP. She practices in the International Trade & Supply Chain group of the firm’s Technology, Manufacturing & Transportation industry team.

Cortney O’Toole Morgan is a Washington D.C.-based partner with the law firm Husch Blackwell LLP. She leads the firm’s International Trade & Supply Chain group.

Camron Greer is an Assistant Trade Analyst in Husch Blackwell LLP’s Washington D.C. office.