U.S. Considering Tariffs on European Aircraft and Aircraft Parts

The Office of the U.S. Trade Representative has announced a preliminary proposal to implement new tariffs on a range of European products with a significant focus on the civil aviation sector, including both parts and completed aircraft.  The proposed tariffs arise as a result of a long-running WTO case brought by the U.S. against the EU and France, Germany, Spain, and the UK.  The WTO found that the EU provided substantial “launch aid” to Airbus and that those subsidies both helped Airbus launch its commercial aircraft and cost Boeing market share.

The purpose of the tariffs (or countermeasures) is to offset the estimated $11 billion per year in trade harm the USTR estimates result from EU subsidies.

It is unclear at this point at what rate tariffs would be imposed on the particular goods identified.  The proposed HTS numbers affected include numbers that are very familiar to the distribution community, including 8803.20.0030, 8803.30.0030, and 8803.90.9030, however, the scope appears to be limited to parts imported “for use in new civil aircraft, not for use by the Department of Defense or the U.S. Coast Guard, of an unladen weight exceeding 15,000 kg provided for in statistical reporting numbers 8802.40.0040, 8802.40.0060 and 8802.40.0070.” Thus from the language it appears the countermeasures target the importation of parts used in the manufacture of new aircraft, but not for the maintenance of the existing fleet.  Anyone supporting the production of new civil aircraft would be well advised to review the HTS numbers proposed for countermeasures.  They can be found here.

The USTR has requested public comments on the proposed action.  Comments can be submitted through http://www.regulations.gov under docket number USTR-2019-0003.  Any comments must be submitted by May 28, 2019.

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Have You Encountered Trade Barriers?

The U.S. International Trade Commission (USITC) wants to solve your trade problems!

On July 30, the USITC announced that they are putting together a report that will identify trade-related barriers affecting U.S. small and medium-sized enterprises (SMEs).  The focus is on trade with the European Union (EU).  As part of the information-gathering process, they will be conducting an October 8 hearing on these issues.

This is our opportunity to identify anything that adversely affects trade between the US and Europe.  The United States is negotiating a trade agreement with the EU so this hearing is an excellent opportunity to get our concerns addressed (before it is too late!).

Pre-hearing written comments are due by September 20, 2013.  ASA plans to submit a filing addressing our members’ concerns to please get your comments into ASA not later than September 13, so we can make sure your comments are reflected in our filing.

Full text of Federal Register Notice:

https://www.federalregister.gov/articles/2013/07/30/2013-18272/trade-barriers-us-small-and-medium-sized-enterprises-perceive-as-affecting-exports-to-european-union

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