The Office of the U.S. Trade Representative (USTR) has released instructions for submitting exclusion requests for products subject to List 3 of the Section 301 duties. Included on this list of items are many products of concern to the RV industry, including tires, wheels, propane tanks, fabrics, carpet, plywood, refrigerators, appliances and parts, plumbing goods and accessories, and various raw metals.
USTR’s exclusion web portal is scheduled to open at 12 p.m. ET on Sunday, June 30. The deadline for submitting exclusion requests is Sept. 30. All product exclusions will be retroactive to the implementation date of the initial action, Sept. 24, 2018, for these products, and will extend for one year following publication of the exclusion determination in the Federal Register.
While the process resembles that of Lists 1 and 2, there are some noteworthy modifications to the List 3 form that will affect USTR’s analysis of requests. One new addition allows companies to explain the impacts previous Section 301 actions have had on their operations. Additionally, it asks whether the company meets the standard to be classified as a small business as established by the Small Business Administration.
Interested parties have 14 days following submission of an exclusion request to submit their own comments in support or opposition to any request. Parties will have seven days after either the closing of the 14-day comment period or the posting of a comment (whichever is later) to respond to any comments related to their request.
USTR intends to periodically announce decisions on pending requests and has stated that it expects to receive approximately 60,000 product exclusion requests.