A Display Supply Chain Consultants analysis of International Trade Commission data confirmed the firm’s initial read that the Chinese-sourced display product lines targeted July 10 for proposed 10 percent Trade Act Section 301 tariffs (see 1807110034) accounted for minuscule import shipments in 2017, DSCC President Bob O’Brien told us. Of the 21 Harmonized Tariff Schedule (HTS) product codes listed in the Office of the U.S. Trade Representative notice under the “8528" heading for displays, only four of those classifications of imports had customs values exceeding $1 million last year for all countries of origin, including China, said O’Brien. The top four classifications, which combined accounted for only $90 million in imports from China last year, are: (1) HTS 8528.59.10, incomplete or unfinished color video monitors, not incorporating a VCR or video player. Imports from all countries totaled $99.3 million in 2017, of which $72.3 million (73 percent) came from China; (2) HTS 8528.69.10, incomplete or unfinished color video projectors, not incorporating a VCR or player. All 2017 imports totaled $12.4 million, of which $9.1 million (73 percent) were from China; (3) HTS 8528.59.05, incomplete or unfinished color video monitors, incorporating a VCR or player. Total 2017 imports were $9.5 million, of which $2.7 million (29 percent) came from China; (4) HTS 8528.42.00, finished CRT monitors. Total 2017 imports were $8.5 million, of which $5.9 million (69 percent) came from China. O’Brien said many regard CRT monitors as dead, but about 57,000 units were imported to the U.S. last year. Two classifications of flat-panel subassemblies made the tariffs list for the first time: (1) HTS 8529.90.54, flat-panel screen assemblies for TVs, color video monitors and video projectors. Total imports were $30 million, of which $18 million (60 percent) came from China; (2) HTS 9013.80.90, liquid crystal devices and optical appliances and instruments, "not elsewhere specified or included." Total 2017 imports were $834 million, of which $251 million (30 percent) were from China. Canada generated the most 2017 imports in the HTS 9013.80.90 category. Element Electronics sources LCD panels from China under the HTS 9013.80.90 subheading for the sets it assembles in South Carolina, the company told the USTR’s office in May 22 comments. Element representatives declined comment on the potential blow the company faces from having Chinese-sourced LCD panels now included on the proposed tariffs list.

The Section 321 entry exemptions do not apply to bulk shipments sent to foreign-trade zones that are broken up for individual consumption entries below the $800 de minimis level prior to a consumer order, CBP said in May 8 ruling the agency released on July 17. Much of the decision hinges on the definition of "importation," as expected (see 1806050049). The ruling came in response to an internal advice request from Jim Swanson, CBP director-cargo and conveyance security and controls, it said. CBP recently said the new Section 301 tariffs won't apply to Section 321 entries (see 1807050033).

A Display Supply Chain Consultants analysis of International Trade Commission data found the firm’s initial read that the Chinese-sourced display product lines targeted July 10 for proposed 10 percent Trade Act Section 301 tariffs (see 1807110055) accounted for minuscule import shipments in 2017, DSCC President Bob O’Brien told us. Of the 21 Harmonized Tariff Schedule (HTS) product codes listed in the Office of the U.S. Trade Representative notice under the “8528" heading for displays, only four of those classifications of imports had customs values exceeding $1 million last year for all countries of origin, including China, O’Brien said.

China filed an additional complaint at the World Trade Organization over the U.S. Section 301 tariffs. A 10 percent tariff on $200 billion in Chinese imports has not yet been imposed, and will not be imposed until public input on the more than 6,000-product list is received (see 1807110050). In the past, the U.S. has accepted consultations in Geneva with China even before tariffs begin (see 1804190039).

International Trade Today is providing readers with some of the top stories for July 9-13 in case they were missed.

With the publication of the Office of U.S. Trade Representative’s notice in Wednesday’s Federal Register on procedures for requesting exclusions from Trade Act Section 301 tariffs on Chinese imports (see 1807080001), docket USTR-2018-0025 for posting such requests became active in the regulations.gov portal. No requests were posted yet by our Friday deadline. Exclusion requests are due by Oct. 9, and if granted will apply for a year retroactively to July 6, said the notice. Once a request is posted, the public will have 14 days to file responses to that request, it said. After that 14-day period, “interested persons” will have seven days to reply to those responses, it said. Though Oct. 9 is the deadline for the exclusion requests, “international trade team” lawyers at BakerHostetler are “advising clients to file as soon as possible in anticipation of the large administrative backlog that they expect.” Though the Trump administration’s threat to impose 10 percent tariffs on an additional $200 billion worth of Chinese imports (see 1807110034) “doesn't necessarily raise the risk of an all-out trade war, the tariffs would affect some industries and individual corporate borrowers,” said S&P Global Friday. Together with the 25 percent tariffs enacted July 6 on $34 billion in Chinese imports and the proposal to impose tariffs on another $16 billion in goods, “the total amount of $250 billion now represents about half the value of China's annual exports to the U.S.,” it said. The absence of an immediate “tit-for-tat” retaliatory response from China “lends hope to the belief that China-U.S. trade negotiations aren't completely off the table,” said S&P. “We are obviously not sanguine about the risk. Our current base-case assumption is that the tariffs, if imposed, will not likely greatly affect either economy. However, they would affect some industries and individual corporations.” The U.S.-China friction already is contributing to “jitters in the financial markets and is coloring business investment decisions,” said S&P. If China wants to retaliate with tariffs on U.S. goods, it “can’t match” the $200 billion figure because American imports to China totaled only $130 billion last year, it said: “Should China opt to pursue non-tariff actions that affect services and investments, it could damage global business and consumer confidence, investment prospects, and growth.”

With the publication of the Office of U.S. Trade Representative’s notice in Wednesday’s Federal Register on procedures for requesting exclusions from Trade Act Section 301 tariffs on Chinese imports (see 1807080001), docket USTR-2018-0025 for posting such requests became active in the regulations.gov portal. No requests were posted yet by our Friday deadline. Exclusion requests are due by Oct. 9, and if granted will apply for a year retroactively to July 6, said the notice. Once a request is posted, the public will have 14 days to file responses to that request, it said. After that 14-day period, “interested persons” will have seven days to reply to those responses, it said. Though Oct. 9 is the deadline for the exclusion requests, “international trade team” lawyers at BakerHostetler are “advising clients to file as soon as possible in anticipation of the large administrative backlog that they expect.” Though the Trump administration’s threat to impose 10 percent tariffs on an additional $200 billion worth of Chinese imports (see 1807110034) “doesn't necessarily raise the risk of an all-out trade war, the tariffs would affect some industries and individual corporate borrowers,” said S&P Global Friday. Together with the 25 percent tariffs enacted July 6 on $34 billion in Chinese imports and the proposal to impose tariffs on another $16 billion in goods, “the total amount of $250 billion now represents about half the value of China's annual exports to the U.S.,” it said. The absence of an immediate “tit-for-tat” retaliatory response from China “lends hope to the belief that China-U.S. trade negotiations aren't completely off the table,” said S&P. “We are obviously not sanguine about the risk. Our current base-case assumption is that the tariffs, if imposed, will not likely greatly affect either economy. However, they would affect some industries and individual corporations.” The U.S.-China friction already is contributing to “jitters in the financial markets and is coloring business investment decisions,” said S&P. If China wants to retaliate with tariffs on U.S. goods, it “can’t match” the $200 billion figure because American imports to China totaled only $130 billion last year, it said: “Should China opt to pursue non-tariff actions that affect services and investments, it could damage global business and consumer confidence, investment prospects, and growth.”

With the publication of the Office of the U.S. Trade Representative’s notice in the July 11 Federal Register on procedures for requesting exclusions from Trade Act Section 301 tariffs on Chinese imports (see 1807100049), docket USTR-2018-0025 for posting such requests became active in the regulations.gov portal. No requests were posted yet as of International Trade Today's deadline. Exclusion requests are due by Oct. 9, and if granted will apply for a year retroactively to July 6, the notice said. Though Oct. 9 is the deadline for the exclusion requests, international trade lawyers at BakerHostetler are advising "clients to file as soon as possible in anticipation of the large administrative backlog that they expect,” the law firm said.

With the publication of the Office of U.S. Trade Representative’s notice in Wednesday’s Federal Register on procedures for requesting exclusions from Trade Act Section 301 tariffs on Chinese imports (see 1807080001), docket USTR-2018-0025 for posting such requests became active in the regulations.gov portal. No requests were posted yet by our Friday deadline. Exclusion requests are due by Oct. 9, and if granted will apply for a year retroactively to July 6, said the notice. Once a request is posted, the public will have 14 days to file responses to that request, it said. After that 14-day period, “interested persons” will have seven days to reply to those responses, it said. Though Oct. 9 is the deadline for the exclusion requests, “international trade team” lawyers at BakerHostetler are “advising clients to file as soon as possible in anticipation of the large administrative backlog that they expect.” Though the Trump administration’s threat to impose 10 percent tariffs on an additional $200 billion worth of Chinese imports (see 1807110034) “doesn't necessarily raise the risk of an all-out trade war, the tariffs would affect some industries and individual corporate borrowers,” said S&P Global Friday. Together with the 25 percent tariffs enacted July 6 on $34 billion in Chinese imports and the proposal to impose tariffs on another $16 billion in goods, “the total amount of $250 billion now represents about half the value of China's annual exports to the U.S.,” it said. The absence of an immediate “tit-for-tat” retaliatory response from China “lends hope to the belief that China-U.S. trade negotiations aren't completely off the table,” said S&P. “We are obviously not sanguine about the risk. Our current base-case assumption is that the tariffs, if imposed, will not likely greatly affect either economy. However, they would affect some industries and individual corporations.” The U.S.-China friction already is contributing to “jitters in the financial markets and is coloring business investment decisions,” said S&P. If China wants to retaliate with tariffs on U.S. goods, it “can’t match” the $200 billion figure because American imports to China totaled only $130 billion last year, it said: “Should China opt to pursue non-tariff actions that affect services and investments, it could damage global business and consumer confidence, investment prospects, and growth.”

The Section 301 tariffs on goods from China do not apply to covered imports that are part of a set if that set is classified under a subheading that is not included in the Section 301 list, CBP told the National Customs Brokers & Forwarders Association of America. "If the product that imparts the essential character to the set (i.e., the [Harmonized Tariff Schedule of the U.S.] under which the entire set is classified) is covered by the Section 301 remedy, then the entire set will be subject to the additional 25% duties," CBP told the NCBFAA. "If the HTSUS under which the entire set is classified is not covered by the Section 301 remedies, but the set contains a component that is classified in a subheading covered by the 301 list, the 301 duties will not be assessed on the individual component at this time."