Today the president announced that the United States will be imposing new tariffs on China (under Section 301 of the Trade Act of 1974) and is exempting the European Union, Brazil, Australia, South Korea and Argentina from the previously announced tariffs on steel and aluminum.

With the tariffs on steel and aluminum scheduled to go into effect on March 23, the BA has released its findings on the anticipated impact on imported stainless steel kegs and fabricated steel items:

Based on preliminary research, finished, stainless steel kegs and containers appear to be outside the scope of the tariffs that the White House announced last week, and therefore will not be subject to any additional duties. We believe that stainless steel kegs and containers are imported under two Harmonized Tariff Schedule (HTS) codes below:

7310.10.0010 covers tanks, casks, drums, cans, boxes and similar containers for any material … of iron or steel, of a capacity not exceeding 300 liters, whether or not lined or heat insulated, but not fitted with mechanical or thermal equipment, of a capacity of 50 liters or more, empty steel drums and barrels. The duty rate for products imported under this tariff is zero; and

7309.00.0090 covers larger-capacity stainless steel containers (i.e., those greater than 300 liters). They are already subject to a duty rate of 2.6 percent.

The presidential proclamation announcing the tariffs on steel products does not include these products.

Instead, the tariffs are focused on “upstream products,” some of which may be used in making brewery equipment:

7206.10-7216.50 (ingots, flat-rolled steel, bars and rods, other shapes)

7216.99-7301.10 (wire, stainless steel ingots and other primary forms, semi-finished stainless steel products, bars, rods, wire, and flat-rolled stainless steel products, alloys, sheet piling)

7302.10 (rails)

7302.40-7302.90 (fish-plates and sole plates)

7304.10-7306.90 (tubes and pipes)

The tariffs will begin on March 23, 2018, for any goods entered or withdrawn from a customs warehouse for consumption.

As mentioned above, the Trump Administration also announced another $60 billion in new tariffs on certain goods coming from China. The product scope of these tariffs has not yet been released, but is not expected to include kegs and other products related to brewery equipment. We will update you if relevant products are unexpectedly included on the list.

The Brewers Association will continue to monitor this issue and update our members on any new developments regarding tariffs.