Comment Period Ending July 30 for Possible Extension of Exclusion for China 301 Duties on Spectacle Frames

The U.S. Trade Representative’s (USTR) office issued a Federal Register notice announcing it is considering a possible extension for up to 12 months for certain product exclusions, including eyeglass frame exclusions. Public comments on this proposed action have been requested, with the comment period running from July 1–July 30, 2020.

Eyeglass frame companies should consider filing comments if they support the extension of the existing exclusions on plastic and non-plastic spectacle frames. The option to file comments will close July 30 at 11:59 EDT. To access the filing portal to make a comment, click here.

The Vision Council will submit comments in favor of the extensions, but it is extremely important for individual companies to file comments as well. Economic injury attributable to the China 301 duties is a key factor in favor of extending the exclusions and the USTR benefits from hearing how various individual companies were negatively impacted by the tariff on Chinese spectacle frames. If you file comments, you will need to provide data on your 2018 and 2019 purchases of Chinese-origin, third-country origin, and U.S. origin frames as well as your 2018 and 2019 gross revenue, all of which is treated confidentially. The process requires companies to provide information about steps they have taken to find non-Chinese sources and whether the resumption of the China 301 duties on spectacle frames will result in severe economic harm to their company.

Any questions about this issue, or how to complete the comment template, can be directed to Rick Van Arnam, The Vision Council’s regulatory affairs counsel, at rvanarnam@barnesrichardson.com, or to Michael Vitale, The Visions Council’s Senior Technical Director and Lens, Lab and Lens Processing & Technology Division Liaison, at mvitale@thevisioncouncil.org.