NAFEM successful in advocating for removal of 40% of member components and finished goods from original tariff list

As part of its Section 301 investigation into Chinese intellectual property and technology transfer issues, the U.S. Trade Representative (USTR) released one list of products (list 1) on which 25 percent tariffs will be immediately imposed, beginning July 6. USTA also announced a second, proposed list of products (list 2) on which public comment would be sought before U.S. tariffs are imposed. List 1 includes tariffs valued at $34 billion, and list 2 includes tariffs valued at $16 billion.

During the comment period for list 1, NAFEM conducted a comprehensive assessment of members’ products targeted with the proposed increased tariffs. NAFEM found that the clear majority are material inputs, tools and equipment members use to produce domestic foodservice equipment and supplies, as well as finished goods manufactured in China for the U.S. domestic market. NAFEM submitted comments to USTR and was successful in removing 60 percent of materials, parts and components, and 42 percent of finished commercial foodservice equipment, from the original, proposed list. These items will not be subject to the 25 percent import tariff.

The new, list 2 products will undergo a public notice and comment process, with a public hearing, to allow feedback. NAFEM will continue to aggressively participate in the public comment and hearing processes.

Members should also review both lists and evaluate the impact to their businesses, which may include increased costs, supply chain disruptions, and/or more. List 1 outlines products on which 25 percent tariffs will be imposed beginning July 6.

Comments on the second, proposed list of products (list 2) will be accepted through July 23 and public testimony can be provided at a hearing on July 24. Instructions for submitting written comments or providing public testimony are included here. Once comments are heard and reviewed, USTR will finalize list 2 and impose tariffs on these items as well.

All members are encouraged to contact Charlie Souhrada –;– with input on list 2 by July 6. This input will be included in written comments NAFEM will submit to the USTR on the association’s behalf.

We also recommend members reach out to their elected officials to explain how list 1 and additional tariffs on proposed list 2 negatively impact their businesses. To support this outreach, NAFEM has developed an Advocacy Toolkit for members to use in their outreach efforts.