© [2019], Sandler, Travis & Rosenberg, P.A. Originally published in the [06/11/2019] issue of the Sandler, Travis & Rosenberg Trade Report. Reprinted by permission. 

The Office of the U.S. Trade Representative announced May 13 a list of approximately $300 billion in goods imported from China on which USTR is proposing to impose Section 301 additional tariffs of up to 25 percent.

USTR states that this extensive list of 3,805 full and partial HTSUS subheadings, which can be seen here, covers essentially all products not already subject to Section 301 additional tariffs. It includes all apparel, footwear, and manufactured textile products, among others, but excludes pharmaceuticals, certain pharmaceutical inputs, select medical goods, rare earth materials, and critical minerals.

USTR will hold a public hearing on this proposal June 17 and requests to appear at this hearing are due June 10. Written comments, including input on the specific tariff levels that should be imposed and requests to exclude specific subheadings from the proposed tariff increase, are due June 17. The tariff hike could be implemented any time after June 24 in any amount up to 25 percent, on top of the regular rate of duty.