China 301 Duties

China 301 Duties

On May 10, 2019, the Trump administration raised China 301 duties from 10 to 25 percent, impacting The Vision Council's member companies importing Chinese-origin hand-held and stand magnifiers, eyeglass cases and cleaning solutions. The increase was originally scheduled for Jan. 1, 2019 but was held in abeyance while the United States and China negotiated on trade issues. In the following days, the fourth list of tariff numbers—which could become subject to China 301 customs duties—was published in the Federal Register on May 17, 2019.

This fourth tranche includes all remaining tariff numbers not previously subjected to China 301 duties with limited exceptions, and thus captures all optical products that to date have remained outside of the trade war. Lenses, frames, sunglasses, reading glasses and low vision devices originating in China will be subject to additional duties, up to 25 percent, when this fourth tranche is implemented.

After the G20 summit concluded on June 29, President Trump announced that the United States would not assess additional customs duties on the remaining $300 billion in Chinese imports at this time. Instead, the United States and China agreed to restart talks toward achieving a negotiated settlement to the ongoing trade war.

On Aug. 13, 2019, the Trump administration set forth two sub-lists of tariff numbers included in the fourth tranche of China 301 tariffs scheduled to go into effect on Sept. 1, 2019, and Dec. 15, 2019. These two lists—4A and 4B—include optical products and are scheduled to be subject to an additional 10 percent tariff. Read the full press release from the Office of the U.S. Trade Representative (USTR), here. See below for the two divisions of list four.

List 4A (Effective September 1): see Annex B page 43330

  • 9001.40.00 - Spectacle lenses of glass, unmounted
  • 9001.50.00 - Spectacle lenses of materials other than glass, unmounted
  • 9003.11.00 - Frames and mountings, of plastics, for spectacles, goggles or the like
  • 9003.19.00 - Frames and mountings, other than of plastics, for spectacles, goggles or the like
  • 9003.90.00 - Parts of frames and mountings for spectacles, goggles or the like
  • 9004.10.00 - Sunglasses, corrective, protective or other
  • 9004.90.00 - Spectacles, goggles and the like, corrective, protective or other, other than sunglasses
  • 9005.10.00 - Binoculars

List 4B (Effective December 15): see Annex D page 43450

  • 9005.80.40 - Optical telescopes, including monoculars

The September 1 and December 15 dates do nothing to alter the China 301 tariffs currently in effect. Any Products impacted by those tariffs corresponding with the first, second and third China 301 lists will continue to be assessed an additional 25 percent tariff on Chinese-origin goods.

Earlier this summer, The Vision Council advocated for the removal of optical products from this fourth list of tariff numbers. That process included:

  • Submitting comments with the USTR opposing the inclusion of optical products on the fourth list because they are medical devices
  • Testifying before the USTR by The Vision Council Chairman Ken Bradley in support of our comments and concerns
  • Creating an ad hoc coalition of optical and eyecare related trade associations and other groups, which in turn submitted its own comments opposing the proposed inclusion of optical products
  • Circulating The Vision Council’s comments on Capitol Hill as well as within the White House

For more information on the China 301 duties, please listen to The Vision Council's town hall informational sessions, which were held on May 28, 2019. The full conversations can be found here.

To review the joint comments in opposition of China 301 duties on optical products, click here.

Any questions about this issue can be directed to Rick Van Arnam, The Vision Council's regulatory counsel, at rvanarnam@barnesrichardson.com.