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May 15, 2019
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SUBJECT: Proposed China Tariffs Impacting the Importation of Fireworks & Pyrotechnics Articles
On Monday, May 13, the Office of the United States Trade Representative (USTR) announced a list of approximately $300 billion in goods imported from China - including fireworks, on which USTR is proposing to impose additional tariffs of up to 25 percent.
This proposal, which can be seen here, essentially covers all products not already subject to Section 301 additional tariffs and outlines the process for the proposed List 4 commodities, the last round to be affected by the tariffs. The List 4 products include 1.4 and 1.3 fireworks, propellant powders, pyrotechnic articles, safety fuse as well as other materials. (A detailed breakdown can be found on pages 50-51 of the proposal.)
HTS Subheading Product Description
3603.00.90 Detonating caps, igniters or electric detonators
3604.10.10 Display or special fireworks (Class 1.3G)
3604.10.90 Fireworks, nesoi (includinig Class 1.4G)
3604.90.00 Signaling flares, rain rockets, fog signals and other pyrotechnic articles,
excluding fireworks
3605.00.00 Matches, other than pyrotechnic articles of heading 3604
The proposed tariff is an additional ad valorem duty of up to 25% which will have a significant impact on the industry if enacted. President Trump is continuing trade negotiations with President Xi and is expected to negotiate during the upcoming G-20 Summit at the end of June. Thus, a final decision on this new List 4 tariffs will not likely be made before that meeting, but could occur soon after.
The USTR is soliciting public comments on the proposed tariffs and will convene a public hearing on June 17 at the U.S. International Trade Commission in Washington, DC. The APA leadership convened an emergency conference call late yesterday afternoon to discuss APA's strategy to vigorously oppose the proposed tariffs.
The APA will file extensive comments on the proposal. To enhance these comments, we will be reaching out to the membership for assistance in providing data on how the proposed tariffs will impact their companies. Additionally, we may need APA members to engage their elected Members of Congress.
Those companies who wish to submit comments independently from the APA may do so electronically by June 17 via www.regulations.gov enter docket number USTR-2019-0004. Please note this docket page will not go live until the proposal is published in the Federal Register, most likely on Friday, May 17.
Advisory #2019-13
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