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NAMM Encourages Members to Chime in on Tarrifs

by Christian Wissmuller • in
  • MMR Global
  • Upfront
• Created: June 11, 2019

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NAMM‘s June 6 conference call/webinar to review the current status and state of play of Chinese import tariffs with a timeline and direction on how to submit comments, request exemptions, and register to testify at public hearings has been recorded for your review here. NAMM received many more questions than they were able to address during our 60-minute webinar and are compiling a comprehensive FAQ document to be posted at www.namm.org in the next few days.

As mentioned in our webinar:

Timelines For Action

To submit a comment to the Office of the U.S. Trade Representative:

  1. As soon as possible (don’t wait until the deadline) visit www.regulations.gov (June 10, 2019 was the deadline for submitting a request to testify in Washington D.C. / June 17, 2019 is the deadline for submitting written comments)
  2. Enter Docket Number USTR-2019-0004 and click ‘Search’
  3. Find a reference to this notice and click on the link titled ‘Comment Now!’
  4. Although you may submit comments through the web-based text box, USTR prefers that comments be submitted by attachment. You may submit in Microsoft Word (.doc) or searchable Adobe Acrobat (.pdf)
  5. Please reference specific tariff subheadings—in this case, Harmonized Tariff Schedule (HTS) category 9200 merchandise (musical instruments and related accessories)
  6. Please send a copy of your comment or your decision to withhold comments, to MaryL@namm.org

Requirements for Written Comments

Comments should set forth arguments addressing USTR key issues for exemptions:

  • The product is available only from China or predominantly from China or other foreign countries (percentage of foreign-made vs. domestic)
  • Tariffs on these specific goods would cause “disproportionate economic harm to U.S. interests, including small – or medium-size businesses and consumers”

Additional arguments for exemptions: 

  • Music education programs in K-12 schools nationwide and the musical life of every family would suffer from a proposed 25% tariff on imported musical instruments and equipment from China
  • With new tariffs, students/families in urban and rural communities would have greater difficulty purchasing or renting instruments and equipment; school districts, faced with greater costs, could shrink or even eliminate music education programs
  • Many affordable beginner instruments are made in China and young students quickly outgrow their instruments; young violinists will go through as many as four different sizes of violin by the time they get to high school
  • Musical instruments are a discrete consumer product with high inherent commercial/retail value: a 25% tariff would decrease access and musical opportunities
  • Tariffs on musical instruments and the imposition of greater costs to consumers would impact the musical and cultural life of all communities in the U.S.

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