As you are aware, the administration recently proposed 25 percent tariffs on $300 billion worth of goods imported from China. This is the fourth proposed list of tariffs, and includes brewing machinery (Harmonized Tariff Schedule 8438.40.00).
This is not the first time that brewing machinery has been on a proposed tariff list. It was initially included in the first round of tariffs on China, but was removed from the final list.
Companies and businesses are welcome to submit comments to the United States Trade Representative (USTR) requesting subheadings be excluded from this action. Written comments are due by June 17 and can be submitted online.
USTR will hold a public hearing on this proposal on June 17, and requests to appear at this hearing are due June 10. If you are interested in participating in the hearing you can submit that request on their website.
Recommendations for Submitting Your Comments
Small and independent breweries purchase machinery from around the world. If you feel that your business will be impacted by a 25 percent tariff on brewing machinery imported from China and would like to submit comments, we recommend that you:
- Share pertinent information
- How long have you been open?
- How many people do you employ?
- Share any information on your decision to purchase goods from China
- Share how a 25 percent tariff on brewing machinery could impact your business:
- Could it keep you from expanding?
- Could it keep you from hiring new employees?
- Propose extending the effective date as a matter of fairness to companies that are committed to purchases of goods that require longer lead times
- All comments submitted are public and accessible online — Be courteous, professional, and avoid personal political preferences
The Brewers Association does not provide legal or business advice. If you have any legal questions and want to ensure you aren’t sharing any proprietary information you should consult with an attorney.
The final list of tariffs could be implemented any time after June 24, in any amount up to 25 percent, on top of the regular rate of duty. If brewing machinery is included in the final list of tariffs, companies may request exclusions which will be reviewed on a case-by-case basis. You can learn more about the exclusion process by clicking here.