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Trade & Policy
1. Section 301 Hearings Are Done. Rebuttal Comments Due ~July 14. The Tariff Swap Is 16 Days Away.
USTR's Section 301 Committee convened three days of public hearings at the U.S. International Trade Commission (July 7-9). Nearly 60 witnesses testified. Over 500 written comments were submitted before the July 6 deadline. Post-hearing rebuttal comments are due five days after the last hearing day, which puts the deadline around July 14. After that, USTR can finalize the tariff rates and implementation date. The clock is running.
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16
Days: S122 Expires
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60
Countries Under S301
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500+
Comments Filed
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What this means for importers: Section 122's 10% surcharge expires July 24. Congress hasn't acted to extend it. White & Case's analysis confirms the hearing timeline "closely tracks the expiration date" and says the proposed rates are designed to "provide continuity." Gibson Dunn called it "an early test of whether the Trump Administration can use traditional trade authorities to rebuild broad tariff coverage." The 10% rate covers 14 entities (Canada, EU, Ecuador, Indonesia, Mexico, Pakistan, plus 8 others). The 12.5% covers 46 economies including China, Japan, India, Korea, Vietnam, Brazil, and Australia. Annex A exclusions cover ag, aviation, minerals, pharma, and industrial inputs. A textile mechanism would reduce rates on some apparel. The Board of Trade proposal for US-China bilateral trade has a separate comment deadline of July 10. If you import from any of the 60 named economies and goods arrive after July 24, model your landed costs against a 10-12.5% adder. The swap is not theoretical anymore.
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