9405.40.60 Makes the Tariff List

ON 13 APR, EdisonReport first reported about the unintended consequences of the proposed tariffs and how they would penalize U.S. manufacturers while giving companies that import complete fixtures (with no U.S. labor) an even greater advantage.

With the next round of Tariffs, LED Luminaires are on the proposed list.  The newly released list shows Harmonized System (HS) code of 9405.40.60:  Electric lamps and lighting fixtures Not Elsewhere Specified Or Included  (NESOI), of base metal other than brass.

Our friends at NEMA are on top of this as always.  Craig Updyke sent the following email yesterday.  The list is open for public comment.

Developing…

 

From: “Updyke, Craig” <[email protected]>
Date: July 11, 2018 at 4:58:43 PM EDT
To: “Updyke, Craig” <[email protected]>
Subject: NEMA Lighting: China Tariff Updates and Request for Feedback/Input

To:          NEMA Light Source Section

NEMA Luminaire Section

NEMA Ballast and Driver Section

NEMA Lighting Controls Section

 

Re:         Updates and Overview of U.S. Tariff Initiatives re China

 

  1. On July 6, the United States implemented additional 25 percent customs tariffs on a range of Chinese-made products, including inputs to manufacturing such as capacitors and resistors, the following items of direct or adjacent interest to Members of these Sections.

 

HS Code Product Description

 

8539.41.00

 

Arc lamps

 

8539.90.00

 

Parts of electrical filament or discharge lamps

 

   
8541.40.20

 

Light-emitting diodes (LEDs)

 

8541.90.00

 

Parts of diodes, transistors, similar semiconductor devices, photosensitive semiconductor devices, LED’s and mounted piezoelectric crystals

 

 

The list of products targeted on July 6 was developed following a public comment period on an April 6 proposed target list. On July 6, USTR announced a process to request exclusion of specific products from the tariffs.

 

How are these tariffs impacting your business? Please let us know.

 

  1. A second target list (for 25 percent tariffs) was announced on June 15. Based on a review by NEMA Government Relations staff and input received so far from Members, the following products of direct or adjacent interest of Section Members appear on the list. However, if you find there are additional products of interest, please let me know as soon as possible. The second target list is open for public comment by July 23 (rebuttals until July 31), with a public hearing scheduled for July 24-25. NEMA will testify and provide longer written comments by July 23, so please provide any input or questions you may have.

 

 

HS Code Product Description

 

8536.50.70

 

Certain specified electronic and electromechanical snap-action switches, for a voltage not exceeding 1,000 V

 

   
8541.10.00

 

Diodes, other than photosensitive or light-emitting diodes

 

   
8542.31.00

 

Electronic integrated circuits: processors and controllers

 

   
8542.90.00

 

Parts of electronic integrated circuits and microassemblies

 

 

 

  1. Yesterday (July 10), a third target list was announced by USTR, with 10 percent tariffs in the offing. This list is open for public comment until August 30.  NEMA GR staff’s review of the list 200-page list found the following products of direct interest to Section Members. In addition, the list does include a wide range of industrial metals, compounds and materials, including copper, nickel, aluminum, zinc, tin, tungsten, molybdenum, tantalum, cobalt, cadmium, industrial diamonds, ceramics, some mixtures of rare earth materials, and permanent magnets.

 

HS Code Product Description

 

8504.10.00 Ballasts for discharge lamps or tubes
8533.39.00 Electrical wirewound variable resistors, including rheostats and potentiometers, for a power handling capacity exceeding 20 W
8536.61.00 Lampholders for a voltage not exceeding 1,000 V
8539.10.00

 

Sealed beam lamp units

 

8539.21.20

 

Tungsten halogen electrical filament lamps, designed for a voltage not exceeding 100 V

 

8539.21.40

 

Tungsten halogen electrical filament lamps, designed for a voltage exceeding 100 V

 

8539.31.00

 

Fluorescent, hot cathode discharge lamps, other than untraviolet lamps

 

8539.32.00

 

Mercury or sodium vapor discharge lamps or metal halide discharge lamps (other than ultraviolet lamps)

 

8539.39.90

 

Other electrical discharge lamps, other than fluorescent (hot cathode), mercury or sodium vapor, metal halide or ultraviolet lamps

 

8539.49.00 Ultraviolet or infrared lamps

 

9405.10.40

 

Chandeliers and other electric ceiling or wall lighting fittings (o/than used for public spaces), of brass

 

9405.10.60

 

Chandeliers and other electric ceiling or wall lighting fixtures (o/than used for public spaces), of base metal (o/than brass)

 

9405.10.80

 

Chandeliers and other electric ceiling or wall lighting fixtures (o/than used for public spaces), not of base metal

 

9405.40.40

 

Electric lamps and lighting fixtures nesoi, of brass

 

9405.40.60

 

Electric lamps and lighting fixtures nesoi, of base metal (o/than brass)

 

9405.40.84

 

Electric lamps and lighting fixtures nesoi, not of base metal

 

 

Section Members are encouraged to review the list and advise NEMA staff of any concerns as soon as possible.

Thank you for your consideration, assistance and support for NEMA.