Tuesday night U.S. Trade Representative Robert Lighthizer released a proposed list of $200 billion in Chinese goods that will be subject to a 10% tariff. This tariff is in retaliation to the tariffs China recently leveraged on U.S. goods in response to previous tariff impositions.

The list of tariff classifications published by USTR identifying merchandise potentially subject to a 10% section 301 duty covers three tariff classifications that directly impact the cabinet industry – although the USTR list only provides classifications out to the eight-digit level. Classification codes include:

  1. Kitchen cabinets – HTS subheading 9403.40.90.60
  2. Modular vanities – HTS subheading 9403.60.80.81
  3. Component parts of cabinets – HTS subheading 9403.90.70.80

The USTR notice identifies several key dates for the public comment process regarding these potential additional, new tariffs. The key dates are as follows:

  • July 27 – Deadline to submit written request to USTR to testify at hearing
  • August 17 – Deadline to submit written comments addressing product listing
  • August 20 – Public hearing to address product listing
  • August 30 – Deadline for submitting post-hearing written rebuttal comments 

Given that the civil servants were tasked with coming up with a list of tariff headings involving $200 billion in Chinese imports, our attorneys suspect that they included any tariff classification with a significant volume/value of imports.
We do not believe that this will preclude any potential future action against Chinese unfairly imported cabinets.

It would also be helpful to know what other individual companies may do on their own. If your company plans to engage in the #301 process kindly reach out to Betsy Natz at bnatz@kcma.org or (703) 264-1690.

Click here to read the full announcement and here for a snapshot of the wood products included.