Gemini Shippers Group joined almost 200 Trade Associations to urge the Office of the U.S.
Trade Representative (USTR) to move expeditiously to extend exclusions for products covered
by the Section 301 China tariffs before they expire on December 31, 2020.
A copy of the letter is noted below.
November 5, 2020
The Honorable Robert E. Lighthizer
United States Trade Representative
600 Seventeenth Street, N.W.
Washington, D.C. 20508
Dear Ambassador Lighthizer:
On behalf of the Americans for Free Trade coalition, we write to urge the Office of the U.S.
Trade Representative (USTR) to move expeditiously to extend exclusions for products covered
by the Section 301 China tariffs before they expire on December 31, 2020. Doing so would
provide certainty for American businesses already struggling with the economic fallout from
COVID-19 and avoid doing additional harm to the U.S. economy.
Our coalition represents every part of the U.S. economy including manufacturers, farmers and
agribusinesses, retailers, technology companies, service suppliers, natural gas and oil companies,
powersports manufacturers, importers, exporters, and other supply chain stakeholders.
Collectively, we support tens of millions of American jobs through our vast supply chains.
While we continue to advocate for the full elimination of the Section 301 tariffs, we recognize
the important role that the product exclusion process has played in alleviating the burden of
additional tariffs for some American businesses. So long as Section 301 tariffs remain in place,
having a predictable, fair, and transparent product exclusion process is vital to creating a
modicum of certainty for American businesses. That certainty, however, is in jeopardy as all
remaining product exclusions are set to expire at the end of this year. As American businesses
continue to recover from the COVID-19 pandemic, they should not have to face the uncertainty
of tax increases on January 1 because of a reimposition of tariffs on previously excluded
products. It remains unclear whether USTR intends to offer additional product exclusion
extension opportunities for the remaining exclusions. We believe it is crucial for USTR to do so.
More specifically, we urge USTR to automatically extend existing product exclusions for at least
six months. This move would be welcome news to the American businesses, workers,
consumers, and farmers who have paid nearly $60 billion in taxes to the federal government in
the form of tariffs since the trade war with China began. It would also provide certainty for
American businesses trying to recover from the economic harm caused by the COVID-19
pandemic. Alternatively, we urge USTR to issue a Federal Register Notice announcing a new
public comment period to extend expiring exclusions as soon as possible. This should also
include an opportunity to submit comments for products covered by exclusions that were not
extended by USTR earlier this year.
Extending product exclusions is a straightforward and efficient way for the administration to
provide certainty and relief to American businesses during this difficult economic time. Until the
Section 301 tariffs are fully eliminated, we urge USTR to maintain a robust, predictable, and
transparent product exclusion process.
Thank you for your consideration of this request.
Sincerely,
Accessories Council
ACT | The App Association
Agriculture Transportation Coalition (AgTC)
ALMA, International (Association of
Loudspeaker Manufacturing and Acoustics)
American Apparel & Footwear Association
(AAFA)
American Association of Exporters and
Importers (AAEI)
American Association of Port Authorities
American Bakers Association
American Bridal & Prom Industry Association
(ABPIA)
American Chemistry Council
American Coatings Association, Inc. (ACA)
American Down and Feather Council
American Fly Fishing Trade Association
American Home Furnishings Alliance
American Lighting Association
American Petroleum Institute
American Pyrotechnics Association
American Rental Association
American Specialty Toy Retailing Association
American Wind Energy Association
Arizona Technology Council
Arkansas Grocers and Retail Merchants
Association
Association For Creative Industries
Association for PRINT Technologies
Association of American Publishers
Association of Equipment Manufacturers
(AEM)
Association of Home Appliance Manufacturers
Auto Care Association
Beer Institute
BSA | The Software Alliance
California Retailers Association
Can Manufacturers Institute
Carolina Loggers Association
Chemical Industry Council of Delaware (CICD)
Coalition of New England Companies for Trade
(CONECT)
Coalition of Services Industries (CSI)
Colorado Retail Council
Columbia River Customs Brokers and Forwarders Assn.
Computer & Communications Industry
Association (CCIA)
Computing Technology Industry Association (CompTIA)
Consumer Brands Association
Consumer Technology Association
Council of Fashion Designers of America (CFDA)
CropLife America
Customs Brokers & Freight Forwarders Assn.
of Washington State
Customs Brokers & Freight Forwarders of
Northern California
Distilled Spirits Council of the United States
Electronic Transactions Association
Fashion Accessories Shippers Association (FASA)
Fashion Jewelry & Accessories Trade Association
Flexible Packaging Association
Florida Ports Council
Florida Retail Federation
Footwear Distributors and Retailers of America (FDRA)
Fragrance Creators Association
Game Manufacturers Association
Gemini Shippers Association
Georgia Retailers
Global Chamber®
Global Cold Chain Alliance
Greeting Card Association
Halloween Industry Association
Home Fashion Products Association
Home Furnishings Association
Household and Commercial Products
Association
Idaho Retailers Association
Illinois Retail Merchants Association
Independent Office Products & Furniture
Dealers Association (IOPFDA)
Indiana Retail Council
Information Technology Industry Council (ITI)
International Association of Amusement Parks
and Attractions (IAAPA)
International Bottled Water Association
(IBWA)
International Foodservice Distributors
Association
International Housewares Association
International Warehouse and Logistics
Association
International Wood Products Association
ISSA – The Worldwide Cleaning Industry
Association
Jeweler’s Vigilance Committee
Juice Products Association (JPA)
Juvenile Products Manufacturers Association
Leather and Hide Council of America
Licensing Industry Merchandisers’ Association
Los Angeles Customs Brokers and Freight
Forwarders Assn.
Louisiana Retailers Association
Maine Grocers & Food Producers Association
Maine Lobster Dealers’ Association
Maritime Exchange for the Delaware River
and Bay
Maryland Retailers Association
Methanol Institute
Michigan Chemistry Council
Michigan Retailers Association
Minnesota Retailers Association
Missouri Retailers Association
Motor & Equipment Manufacturers Association
Motorcycle Industry Council
NAPIM (National Association of Printing Ink
Manufacturers)
National Association of Chain Drug Stores (NACDS)
National Association of Chemical Distributors (NACD)
National Association of Foreign-Trade Zones (NAFTZ)
National Association of Home Builders
National Association of Music Merchants
National Association of Trailer Manufacturers (NATM)
National Confectioners Association
National Council of Chain Restaurants
National Customs Brokers and Freight
Forwarders Association of America
National Electrical Manufacturers Association (NEMA)
National Fisheries Institute
National Foreign Trade Council
National Grocers Association
National Lumber and Building Material Dealers
Association
National Marine Manufacturers Association
National Restaurant Association
National Retail Federation
National Ski & Snowboard Retailers Association
National Sporting Goods Association
Natural Products Association
New Jersey Retail Merchants Association
North American Association of Uniform Manufacturers
and Distributors (NAUMD)
North Carolina Retail Merchants Association
Ohio Council of Retail Merchants
Outdoor Industry Association
Pacific Coast Council of Customs Brokers and Freight
Forwarders Assns. Inc.
Pennsylvania Retailers’ Association
PeopleforBikes
Personal Care Products Council
Pet Industry Joint Advisory Council
Petroleum Equipment & Services Association
Plumbing Manufacturers International
Power Tool Institute (PTI)
Promotional Products Association International
Recreational Off-Highway Vehicle Association
Retail Association of Maine
Retail Council of New York State
Retail Industry Leaders Association
Retailers Association of Massachusetts
RISE (Responsible Industry for a Sound
Environment)
San Diego Customs Brokers and Forwarders
Assn.
SEMI
Snowsports Industries America
Society of Chemical Manufacturers &
Affiliates
Software & Information Industry Association
(SIIA)
South Dakota Retailers Association
Specialty Equipment Market Association
Specialty Vehicle Institute of America
Sports & Fitness Industry Association
TechNet
Telecommunications Industry Association
(TIA)
Texas Retailers Association
Texas Water Infrastructure Network
The Airforwarders Association
The Fertilizer Institute
The Hardwood Federation
The Toy Association
The Vinyl Institute
Travel Goods Association
Truck & Engine Manufacturers Association (EMA)
United States Council for International Business
United States Fashion Industry Association
US Global Value Chain Coalition
US-China Business Council
Virginia Retail Merchants Association
Virginia-DC District Export Council (VA-DC DEC)
Washington Retail Association
Window and Door Manufacturers Association
World Pet Association, Inc. (WPA)
CC: Secretary Steven Mnuchin, U.S. Department of Treasury
Secretary Wilbur Ross, U.S. Department of Commerce
Secretary Sonny Perdue, U.S. Department of Agriculture
Director Larry Kudlow, National Economic Council of the United States
Members of Congress
