© [2019], Sandler, Travis & Rosenberg, P.A. Originally published in the [08/30/2019] issue of the Sandler, Travis & Rosenberg Trade Report. Reprinted by permission.

Importers and others have until Sept. 20 to submit comments on the proposed increase from 25 percent to 30 percent of the additional tariff being imposed on $250 billion worth of imports from China. This increase is scheduled to take effect Oct. 1 for the following products.

– 818 tariff subheadings with an approximate annual trade value of $34 billion (list 1 goods)

– 279 tariff subheadings with an approximate annual trade value of $16 billion (list 2 goods)

– 5,733 tariff subheadings with an approximate annual trade value of $200 billion (list 3 goods)

USTR notes that any such increase will not apply to products previously excluded from the Section 301 tariffs “under the procedures set out in the USTR exclusion process.”

Those commenting on the proposed tariff increase should specifically address (a) whether it would be practicable or effective in obtaining the elimination of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation that the U.S. has identified as unreasonable or discriminatory and burdening or restricting U.S. commerce, and (b) whether the proposed increase on particular products would cause disproportionate economic harm to U.S. interests, including small or medium-sized businesses and consumers.