On September 5, 2018, lawyer Shen Wenwen, apartner of Zhejiang Wulian Law firm, and director of the International TradeProfessional Committee of the Hangzhou lawyers Association, and China Chamberof International Commerce (CCOIC) Zhejiang Chamber of Commerce, jointlysubmitted to the office of the United States Trade Representative, a publiccomment of the $200 billion list. This public comment has helped three Zhejiangenterprises successfully remove the products of the two tariff codes from the$200 billion list.

On September 17, 2018, USTR announced thefinal list of 200 billion tariffs after the public review period. The final$200 billion tariff list removes 297 tariff codes from the original 6031 tariffcodes, including the two tariff codes in the public review opinions submittedby lawyer Shen and CCOIC Zhejiang, the two tariff codes are 5402.20.60(Multiple (folded) or cabled high tenacity yarn (except sewing thread) ofpolyesters, not put up for retail sale) and 2903.392.00 (refrigerant R32, R125,R143a).

Lawyer Shen assisted the CCOIC ZhejiangChamber of Commerce in writing a public comment on the 200 billion tariff list,mainly on the detailed reasons for the removal of 12 tariff products from 5industry products of 6 representative enterprises in Zhejiang. Mainly from theirreplaceability of goods, the collection of goods will cause serious economicdamage to the US industry, American consumers and the goods are not included inthe strategic plan of “Made in China 2025” for comprehensively upgrading theChinese industry.

Since the removal of the tariff code in thetax list is for all products under this tariff code, the removal of these twotariff codes not only helped the three Zhejiang enterprises, but also helpedall Chinese companies exporting these two products to the United States. It isunderstood that in 2017, Zhejiang exported to the United States about $140million 5402.20.60 (Multiple (folded) or cabled high tenacity yarn (exceptsewing thread) of polyesters, not put up for retail sale) coded goods; morethan $100 million 2903.39.20(refrigerant R32, R125, R143a) coded goods.

So far, all the $250 billion tax lists ofthe US Section 301 investigation on Chinese imports have been confirmed, andthe procedures for public comment to remove the tariff code from the list haveall been completed. However, if there is still objection to the goods in thetariff list, Chinese exporters should immediately contact the US importers andrelevant US industry associations to initiate the exemption procedures forindividual goods. According to the latest situation, the deadline for theexemption process for the $34 billion tariff list is October 9, 2018, and theexemption procedure for the $16 billion tariff list is December 18, 2018. Thespecific exemption procedures deadline and application details for the $200billion tariff list have not been announced. The majority of Chinese exportenterprises should actively encourage the US related parties to initiate theexemption application process and seek exemption for additional tariffs onproducts.