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MEMA joins industries seeking clarity and fairness in China Tariff Exclusion process

Monday, August 13, 2018 - 07:00
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MEMA has joined 80 trade associations in a letter to the Trump administration making recommendations to implement a new tariff exclusion process in order to avoid similar problems to existing tariff actions that have proven onerous and opaque.
The letter, addressed to United States Trade Representative (USTR) Robert Lighthizer, seeks to ensure “basic due process and procedural fairness” in the exclusion process for Section 301 tariffs on products and goods imported from China. This call is in addition to recent concerns expressed by MEMA that the exclusion process for Section 232 tariffs on steel and aluminum are placing undue burdens on U.S. businesses.
The Trump administration has imposed 25 percent tariffs on $34 billion worth of Chinese imports. In addition, the administration has announced two more rounds of tariffs, 25 percent on an additional list worth $16 billion taking effect on August 23 and 10 percent on a list worth $200 billion. The President has directed USTR to consider increasing the duty rate on the $200 billion to 25 percent. China has also imposed retaliatory tariffs. Companies may seek exclusions from the tariffs, but the procedure is complex and time consuming.
“The Administration should ensure a workable process to reduce the negative impacts of the new China Section 301 tariffs on U.S. workers, farmers, businesses, and consumers,” the letter says. “We believe we have a shared interest to expedite and consolidate product exclusion request reviews, consideration, and final determinations and to ensure fair and transparent outcomes.”
The letter outlines more than a dozen specific steps the administration could take to make the process more fair, equitable, and transparent. In addition, MEMA has submitted comments to the Trump administration and Congress laying out the burdensome Sec. 232 exclusion process and how it places U.S. businesses and American jobs at risk.
The issue of intellectual property rights (IPR) abuses in China is a priority for MEMA, as motor vehicle parts are particularly vulnerable to counterfeiting and IP theft activities. However, tariffs are taxes that hurt U.S. companies, put jobs at risk, and negatively impact consumers. Instead, MEMA supports stronger bi-lateral engagement where China and the U.S. work together to protect the valuable IPR of our members or leveraging the powerful relationships the U.S. has with other trading partners to pressure China to enforce their own IP laws and comply with international IP laws and regulations. MEMA has also been at the forefront of efforts to ensure that exclusion processes for all tariff actions that affect motor vehicle parts suppliers, including Section 232 steel and aluminum tariffs and Section 301, are fair and transparent.
For more information about trade issues impact suppliers and MEMA’s advocacy, visit the MEMA Trade Resources Page.

About MEMA
The Motor & Equipment Manufacturers Association (MEMA) and its four specialized divisions comprise a leading international trade association in the fast-changing mobility industry. Representing vehicle suppliers that manufacture and remanufacture components, technologies, and systems for use in passenger cars and heavy trucks, MEMA serves as a critical bridge between high-tech capabilities in new vehicles –such as autonomous vehicles and vehicle connectivity—and the “nuts and bolts” of vehicle manufacturing. MEMA works at state, federal, and international levels to ensure that the marketplace and public policy support the development of advanced, transformative technologies that enable safer, smarter, and more efficient vehicles. MEMA’s members are represented through four divisions: Automotive Aftermarket Suppliers Association (AASA), Heavy Duty Manufacturers Association (HDMA), Motor & Equipment Remanufacturers Association (MERA), and Original Equipment Suppliers Association (OESA). For more information on how MEMA is leading transformation in the mobility industry, visit

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