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PESA Works with Member Companies on 301 Exclusion Process

The United States Trade Representative (USTR) has listed a number of products imported from China that are scheduled for an additional 10-25% duties on a staggered schedule in the coming months. (See previous PESA coverage)

Many of these products are used by multiple PESA Member Companies. USTR has developed a product exclusion process that allows individual companies and/or trade organizations to file product exclusion requests. This process allows interested parties to request that a particular product be excluded from the additional duties (exclusions are valid for one (1) year).

Exclusion requests are granted based on product description, rather than by HTS part number. Since we understand that some PESA Members import similar products, there is an opportunity for PESA to file several exclusion requests, one per product, on behalf of all PESA Members which import that product. PESA believes that a product exclusion request filed by a trade association on behalf of many companies may be more compelling to USTR than a request filed by an individual company.

There is still much uncertainty regarding this exclusion process, so we do not yet know how many exclusion requests will ultimately be accepted,. However, we have found commonality among multiple PESA Member Companies on the following products:

  • Casing Hangers
  • Casing Heads
  • Barium Sulfate
  • Artificial Lift

We will continue to work with Member Companies on identifying additional products which share commonality among Members. Additionally, if your company imports any of the above products and did not participate in our initial survey, please reach out to VP Government Affairs Tim Tarpley as soon as possible to participate in the process.