In a time of expanding global trade, NAMM monitors and advocates for trade policies and regulations that affect NAMM members who import and export musical products. Please check here often for updates and new resources.
NAMM Supports Free Trade
On behalf of 10,400 global members, NAMM believes that a strong and vibrant music and pro audio products and event technology industry is important to the educational and cultural vitality, as well as economic prosperity, of all countries. As a trade association, NAMM will continue in our efforts to proactively engage elected officials to keep the lines of dialogue and trade open and urge U.S. and world leaders to reaffirm a commitment to such.
Ongoing updates and resources will continue to be posted to this page. Resources below include policy updates from the U.S. Trade Representative, The U.S. Chamber of Commerce, and The National Retail Federation.
Latest Update, August 23, 2019: U.S. Proposes Additional Tariffs on Imports from China
Aug. 23, 2019: Late this afternoon President Trump posted a series of tweets announcing the next wave of Tariffs on goods coming from China: Starting on October 1st, the $250 billion of goods and products from China, currently subject to a 25% tariff, will now incur a 30% tariff. The remaining $300 billion of goods and products from China subject to a 10% tariff from September 1st, will now incur a 15% tariff.
The September 1st 15% tariffs will be in effect on consumer products, including musical instruments as outlined in the Musical Instruments HTS list 4A linked below. Tariffs have been delayed to Dec. 15, 2019, on certain products including cell phones, laptop computers, video game consoles, certain toys, computer monitors, and certain items of footwear and clothing, including some musical instruments as outlined in the Musical Instruments HTS list 4B linked below.
- Lists 1, 2, and 3, all currently tariffed at 25%, will rise to 30% on October 1, 2019
- List 4A, set to take effect on September 1 at 10%, will now be 15% on September 1, 2019
- List 4B, set to take effect on December 15 at 10%, isn’t mentioned to date
Call to Action: NAMM will continue to provide details as they become available. In the meantime, concerned NAMM members are encouraged to contact their member of congress today. Link here for your congressional representative contact information
- HTS Code Lists 4A and 4B Here
- NAMM's June 14 Letter to USTR
- Music Product Imports to the United States. Source: NAMM 2018 Global Report.
- Official notice of the implementation of the 10% tariff on Chinese-made products on 9/1 and 12/15.
Update: Tariffs Could be ‘Really Tough’ for Retailers Supplying School Music Programs
National Retail Federation- Jimmy Edwards president of Marshall Music Co. in Lansing, Mich., says new U.S. tariffs on imports from China have already begun to affect a handful of the small items he sells like instrument cases or mouthpieces. But what has him worried is what will happen if the tariffs are expanded to include musical instruments themselves. Read the full article here.
- Update, August 6, 2019: U.S. to Impose 10% Tariff on Musical Instruments from China
Update, August 6, 2019: U.S. to Impose 10% Tariff on Musical Instruments from China
There will be additional tariffs on Chinese imports, including music products, on September 1st, absent any mitigating actions by either the U.S. or Chinese governments, which are not anticipated before that date. According to a tweet from the President on August 1st, the tariffs on $300 billion in imports will start at “small” 10%, however, the President added that he could raise the rate to “well beyond 25%.” The final tariffs list, as well as a procedure to grant exceptions, is expected to be formally published in days. There is no definitive word on whether exemptions may be available on this group (List 4) at this rate (10%).
China allowed its currency to slide past what had been an important psychological threshold of 7 yuan (officially known as the renminbi) to the dollar. That marked an 11-year low for the currency, a development that will make Chinese exports less expensive in the U.S., thereby mitigating a portion of the new 10% tariff. In response, the President formally labeled China a currency manipulator. The President’s action was supported by Senator Democratic Leader Chuck Schumer (NY). The practical effect of the designation is to initiate bilateral negotiations or talks through the International Monetary Fund over the coming months.
Despite these actions, the Administration still plans to host Chinese trade officials in Washington in early September for another round of talks. There is not likely to be any meeting between President Trump and General Secretary Xi until November at the earliest. Please check here often for updates and new resources.
- Update, July, 2019: U.S. Threatens Tariffs on $4B of EU Goods
U.S. threatens tariffs on $4B of EU goods
Source: Rebecca Falconer, AXIOS
On July 1, the Office of the U.S. Trade Representative published a supplemental tariff list of $4 billion of imports from the European Union, the latest development in the longstanding U.S.-EU trade dispute over Airbus. Both the U.S. and the EU have filed disputes with the WTO alleging that the other has provided an aircraft manufacturer—Boeing in the U.S. and Airbus in the EU—with unfair subsidies. The WTO is still considering the case and may approve tariffs proposed by both countries.
The U.S. previously proposed tariffs on $21 billion of EU goods in April; it is awaiting a WTO decision to impose those tariffs. The office of the USTR is set to hold a hearing on the supplemental list on Aug. 5.
- Update, June 2019: NAMM Joins 661 U.S. Companies and Associations to Urge Administration to Avoid Tariff Escalation, Reach Resolution with China
Update: June, 2019 - NAMM Joins 661 U.S. Companies and Associations to Urge Administration to Avoid Tariff Escalation, Reach Resolution with China
Tariffs Hurt the Heartland, the national campaign against tariffs supported by more than 150 trade associations representing retail, tech, manufacturing and agriculture, sent a letter signed by 661 American companies and associations urging the administration to avoid additional tariffs and reach a resolution with China. The letter comes as the Office of the United States Trade Representative is set to begin hearings considering 25 percent tariffs on $300 billion in goods, 60 percent of which are consumer products. 520 companies signed the letter, including some of the nation’s most recognizable brands, and 141 trade associations at the national and state level.
- Update, June, 2019: The US and China Tentatively Agree to a Trade War Truce
Update, June, 2019: The US and China Tentatively Agree to a Trade War Truce
The United States and China have tentatively agreed to another truce in the trade war, sources said, a move that would avert an additional $300 billion of U.S. tariffs on Chinese imports. President Donald Trump and Chinese President Xi Jinping are set to meet this week at the Group of 20 summit in Japan, and a source said Trump's decision to delay additional tariffs was Xi's price for holding the meeting. Read the full Politico article here.
- Update: Tariff Webinar Recording
Tariff Webinar Recording
“411” On Submitting Comments, Requesting Exemptions and Registering to Testify.
June 6, 2019: NAMM's 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. We received many more questions than we were able to address during our 60-minute webinar and are compiling a comprehensive FAQ document to be posted here 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:
- As soon as possible (don’t wait until the deadline) visit www.regulations.gov (June 10, 2019 is the deadline for submitting a request to testify in Washington D.C. / June 17, 2019 is the deadline for submitting written comments)
- Enter Docket Number USTR-2019-0004 and click 'Search'
- Find a reference to this notice and click on the link titled ‘Comment Now!’
- 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)
- Please reference specific tariff subheadings—in this case, Harmonized Tariff Schedule (HTS) category 9200 merchandise (musical instruments and related accessories)
- 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.
- NAMM's Letter to Ambassador Robert Lighthizer, United States Trade Representative
- Link to June 6 PPT Deck (no audio)
- Link to June 6 Audio Only
- Link to June 6 Webinar - PPT and Audio
- List of Congressional Trade Subcommittee Member Contacts
- Link to Office of U.S. Trade Representative Comment Page
- Federal Register Notice - Proposed Modification of Action Pursuant to Section 301 which includes the Proposed Product List #4
- "Tariffs Hurt the Heartland" Americans for Free Trade Website
- National Retail Federation's Tariff Information Website
- Update, June 6: Tariff Webinar Recording and Resources
661 U.S. Companies and Associations Urge Administration to Avoid Tariff Escalation, Reach Resolution with China
WASHINGTON — Tariffs Hurt the Heartland, the national campaign against tariffs supported by more than 150 trade associations representing retail, tech, manufacturing and agriculture, today sent a letter signed by 661 American companies and associations urging the administration to avoid additional tariffs and reach a resolution with China. The letter comes as the Office of the United States Trade Representative is set to begin hearings considering 25 percent tariffs on $300 billion in goods, 60 percent of which are consumer products. 520 companies signed the letter, including some of the nation’s most recognizable brands, and 141 trade associations at the national and state level.
“We remain concerned about the escalation of tit-for-tat tariffs," the letter states. “We know firsthand that the additional tariffs will have a significant, negative and long-term impact on American businesses, farmers, families and the U.S. economy. Broadly applied tariffs are not an effective tool to change China’s unfair trade practices. Tariffs are taxes paid directly by U.S. companies, including those listed below - not China.”
"We urge your administration to get back to the negotiating table while working with our allies to develop global, enforceable solutions. An escalated trade war is not in the country’s best interest, and both sides will lose,” the companies and associations added.
Tariffs Hurt the Heartland recently released estimates prepared by Trade Partnership Worldwide that showed that imposing new tariffs on an additional $300 billion in goods (combined with the impacted of previously implemented tariffs and retaliation) would result in the loss of more than 2 million U.S. jobs, add more than $2,000 in costs for the average American family of four and reduce the value of U.S. GDP by 1.0 percent.
Below is the full text of the letter. Read a copy online and the list of signers here:
June 13, 2019
President Donald J. Trump
The White House
1600 Pennsylvania Avenue
Washington, DC 20500
Dear Mr. President,
On behalf of the undersigned companies below and the millions of workers we employ, we are writing regarding the ongoing trade dispute between the U.S. and China. We agree that our trading partners must abide by global trade rules, and we support the administration’s efforts to address unfair trading practices, including intellectual property violations, forced technology transfer and more. We encourage the administration to negotiate a strong deal with China that addresses longstanding structural issues, improves U.S. global competitiveness and eliminates tariffs. We believe this goal can be achieved without taxing Americans.
We remain concerned about the escalation of tit-for-tat tariffs. We know firsthand that the additional tariffs will have a significant, negative and long-term impact on American businesses, farmers, families and the U.S. economy. Broadly applied tariffs are not an effective tool to change China’s unfair trade practices. Tariffs are taxes paid directly by U.S. companies, including those listed below— not China. According to Trade Partnership Worldwide LLC, 25 percent tariffs on an additional $300 billion in imports (combined with the impact of already implemented tariffs and retaliation) would result in the loss of more than 2 million U.S. jobs, add more than $2,000 in costs for the average American family of four and reduce the value of U.S. GDP by 1.0 percent. Furthermore, we have seen repeatedly that tariff increases and uncertainty around these trade negotiations have created turmoil in the markets, threatening our historic economic growth.
Mr. President, we support your efforts to hold our trading partners accountable, level the playing field for American businesses and forge enforceable trade agreements. We urge your administration to get back to the negotiating table while working with our allies to develop global, enforceable solutions. An escalated trade war is not in the country’s best interest, and both sides will lose. We are counting on you to force a positive resolution that removes the current tariffs, fosters American competitiveness, grows our economy and protects our workers and customers.
CC: Ambassador Robert Lighthizer, United States Trade Representative
Secretary Steven Mnuchin, Department of the Treasury
Secretary Wilbur Ross, Department of Commerce
Secretary Sonny Perdue, Department of Agriculture
Director Larry Kudlow, National Economic Council
- Update, June, 2019: NAMM joins 661 businesses and organizations in tariff letter to President Trump
Chinese Trade Tariff Updates
Tariff List #4 - Inclusion of Musical Instruments
May 13, 2019: USTR has posted the draft Federal Register notice announcing the proposed HTS lines and the process for the proposed List 4 China 301 tariffs. The proposed 25% tariffs cover approximately $300 billion worth of imports from China. This includes just about everything that isn’t already subject to the additional 301 tariffs such as apparel, footwear, toys, consumer electronics and musical instruments. Note: the list includes everything in HTS category 9200 (musical instruments and related accessories) Link to the list here.
USTR will hold a public hearing on June 17 on the proposed List 4 tariffs. All requests to testify must be submitted by June 10. Final comments must be submitted seven days after the final hearing date. Considering the List 3 tariffs ($200 billion) was six days long, this hearing process may go longer. President Trump plans to meet with President Xi during the G-20 Summit at the end of June. It is unlikely that a final decision on the List 4 tariffs will be made before that meeting.
Questions/Comments: For questions about this proposed action, to submit public comment, or to request to testify at the June 17 public hearing, contact USTR Assistant General Counsels Arthur Tsao or Megan Grimball, or Director of Industrial Goods Justin Hoffmann at USTR (202) 395–5725. For questions on customs classification, contact email@example.com.
Notice of Modification of Section 301 Action
May 10, 2019
The United States Trade Representative's office has published an official notice implementing President Trump's announced plan to increase tariffs on some $200 billion worth of Chinese imports from 10% to 25%, effective at 12:01 a.m. on May 10. While musical instruments are not directly affected by this increase, the list of affected products includes musical instrument cases, certain stands used for guitars and other musical instruments and some circuit board components of electronic instruments. Note: Products which left China prior to May 10 must arrive into the United States no later than June 1 to avoid the 25% tariff.
Comments: For NAMM members wishing to express concern, please see the option to participate in the National Retail Federation’s “call to action” at the link here.
- Update, May, 2019: Tariff List # 4 Inclusion of Musical Instruments
Update: September 17, 2018
The Office of the United States Trade Representative (USTR) released today, a list of approximately $200 billion worth of Chinese imports that will be subject to additional tariffs. In accordance with the direction of President Trump, the additional tariffs will be effective starting September 24, 2018, and initially will be in the amount of 10 percent. Starting January 1, 2019, the level of the additional tariffs will increase to 25 percent. In response to the USTR's action, China retaliated with its own increased tariffs, also effective September 24, 2018, on a list of products covering $60 billion in U.S. exports, at additional duty rates of 5% to 10%. This adds to China's retaliatory tariffs already in place on approximately $50 billion in U.S. exports. Currently, HTS (Harmonized Tariff Schedule) Chapter 92 (Musical Instruments) and HTS Chapter 49 (Printed Music, Music Books, Sheet Music) are not listed; however, some products and component parts within HTS Chapter 85 (Electrical Machinery and Equipment and Parts Thereof) are listed.
Find out if your products or component parts are on the current list:
Step 1: Lookup your product/component HTS Code here (U.S. International Trade Commission HTS Search)
Step 2: Cross-reference your HTS Code on the final tariff list here (USTR.gov as of Sept.17, 2018)
- Update, September, 2018: Chinese Import Tariffs
China Retaliates with Tariffs on $60B of U.S. Goods
More than 5,000 types of goods listed by HS code face tariffs from 5 to 10 percent
By Taylor Miller Thomas, POLITICO Pro DataPoint
Following President Donald Trump’s Sept. 17 announcement that the U.S. would set tariffs on an additional $200 billion of Chinese goods, the Chinese government announced it would set tariffs of 5 percent or 10 percent on roughly $60 billion worth of U.S. exports to the country. The goods targeted by the Chinese government are the same it threatened tariffs on earlier in 2018. At that time, the Chinese Ministry of Commerce threatened tariffs as high as 25 percent on some of these goods.
The U.S. government is planning to set tariffs at 10 percent on the latest set of Chinese goods but will raise that rate to 25 percent in 2019. The Chinse tariffs may also be increased at a later date, to coincide with the U.S. tariff rate hike. The latest tariffs from both countries go into effect on Sept. 24
Sources: Chinese Ministry of Commerce, USA Trade database, U.S. Census Bureau, USITC, Harmonized Tariff Schedule China will set tariffs based on the eight-digit HS code level.
Disclaimer: The data in the graph reflects U.S. exports at the six-digit level, the closest available, and may not completely reflect the value of goods facing tariffs.
- Update, Sept. 2018: China Retaliates with Tariffs on $60 Billion of U.S. Goods
USTR Finalizes Tariffs on $200 Billion of Chinese Imports in Response to China’s Unfair Trade Practices
Posted by the Office of the United States Trade Representative on 9/18/18
Washington, DC – As part of the United States’ continuing response to China’s theft of American intellectual property and forced transfer of American technology, the Office of the United States Trade Representative (USTR) today released a list of approximately $200 billion worth of Chinese imports that will be subject to additional tariffs. In accordance with the direction of President Trump, the additional tariffs will be effective starting September 24, 2018, and initially will be in the amount of 10 percent. Starting January 1, 2019, the level of the additional tariffs will increase to 25 percent.
The list contains 5,745 full or partial lines of the original 6,031 tariff lines that were on a proposed list of Chinese imports announced on July 10, 2018. Changes to the proposed list were made after USTR and the interagency Section 301 Committee sought and received comments over a six-week period and testimony during a six-day public hearing in August. USTR engaged in a thorough process to rigorously examine the comments and testimony and, as a result, determined to fully or partially remove 297 tariff lines from the original proposed list. Included among the products removed from the proposed list are certain consumer electronics products such as smart watches and Bluetooth devices; certain chemical inputs for manufactured goods, textiles and agriculture; certain health and safety products such as bicycle helmets, and child safety furniture such as car seats and playpens.
- Update-Sept. 2018: USTR Finalizes Tariffs on $200 Billion of Chinese Imports
Source: Politico Pro Datapoint
On Aug. 23, the U.S. and China each set tariffs on $16 billion of each other’s goods. China announced and imposed these tariffs after the U.S. announced its own tariffs. This is the second time China has followed U.S. actions in setting tariffs.
Texas, California and South Carolina led states by the total value of these goods that were exported to China in 2017. Washington, Illinois and Pennsylvania will see tariffs on more than $400 million in exports to China — and are facing key midterm races in November
U.S. exports to China hit by Aug. 23 tariffs, by state Infographic
- Update, Aug. 2018: China Sets Tariffs on $16B in U.S. Goods
USTR Finalizes Second Portion of Tariffs on Chinese Products
Posted by the Office of the United States Trade Representative on 8/7/18
The Office of the United States Trade Representative (USTR) today released a list of approximately $16 billion worth of imports from China that will be subject to a 25 percent additional tariff as part of the U.S. response to China’s unfair trade practices related to the forced transfer of American technology and intellectual property. This second portion of additional tariffs under Section 301 follows the first portion of tariffs on approximately $34 billion of imports from China, which went into effect on July 6.
The list contains 279 of the original 284 tariff lines that were on a proposed list announced on June 15. Changes to the proposed list were made after USTR and the interagency Section 301 Committee sought and received written comments and testimony during a two-day public hearing last month. Customs and Border Protection will begin to collect the additional duties on the Chinese imports on August 23.
In March 2018, USTR released the findings of its exhaustive Section 301 investigation that found China’s acts, policies and practices related to technology transfer, intellectual property and innovation are unreasonable and discriminatory and burden U.S. commerce.
Specifically, the Section 301 investigation revealed:
- China uses joint venture requirements, foreign investment restrictions, and administrative review and licensing processes to require or pressure technology transfer from U.S. companies.
- China deprives U.S. companies of the ability to set market-based terms in licensing and other technology-related negotiations.
- China directs and unfairly facilitates the systematic investment in, and acquisition of, U.S. companies and assets to generate large-scale technology transfer.
- China conducts and supports cyber intrusions into U.S. commercial computer networks to gain unauthorized access to commercially valuable business information.
A formal notice of the $16 billion tariff action will be published shortly in the Federal Register. NOTE: As in the case of the first portion of additional tariffs, the notice will announce a process by which interested persons may request the exclusion of particular products covered by a tariff line subject to the additional duties.
- Update, Aug. 2018: USTR Finalizes Second Portion of Tariffs on Chinese Products
The U.S. Chamber of Commerce (USCC) is the world’s largest business organization representing the interests of more than 3 million businesses of all sizes, sectors, and regions. USCC members range from mom-and-pop shops and local chambers to leading industry associations and large corporations.
- Update: U.S Chamber of Commerce Resources
The National Retail Federation is the world’s largest retail trade association. Based in Washington, D.C., NRF represents discount and department stores, home goods and specialty stores, Main Street merchants, grocers, wholesalers, chain restaurants and internet retailers from the United States and more than 45 countries.
- Update: National Retail Federation Resources
Take 2 minutes to let your representatives know that you have concerns with the proposed tariffs on products, materials and component parts from China.
- Update, August 15, 2018: Call To Action - NRF's Letter Template Tool
Tracking Tariffs on US Goods
August 15, 2018. By Taylor Miller Thomas, Politico Datapoint
Multiple countries have set tariffs on US goods in the fallout after president Donald Trump's steel and aluminum tariffs. China set the earliest tariffs, on April 2, in the midst of a series of trade threats exchanged with the U.S. Other countries set tariffs as they were affected by the US tariffs, including Canada, the EU, and Mexico, which announced tariffs on the US after the steel and aluminum tariffs went into effect on their exports on May 31. All told, more than $70 million in US exports are affected by these retaliatory tariffs. View this infographic to learn more.
- Update: Tracking Tariffs on U.S. Goods
- Update: Forms and Instructions for Submitting Requests for Product Exclusions
Instructions for submitting Public Comments
- Link here to display the Comment form.
- Enter your comments, attach files (up to 10MB each), as well as your personal information when applicable. Complete all the required fields.
- Tips for submitting effective comments
- Please note that information entered on the web form may be viewable publicly. These fields are identified by the globe icon.
- Once you reach the "Your Preview" screen, the information that will be viewable publicly is displayed directly on the form under the section titled: "This information will appear on Regulations.gov."
- To complete your comment, you must first agree to the disclaimer and check the box. This will enable the "Submit Comment" button.
- Upon completion, you will receive a Comment Tracking Number for your comment.
- Update, June 14, 2019: NAMM's Letter to Ambassador Robert Lighthizer, United States Trade Representative
UPDATE: June 14, 2019 - NAMM highlights the negative impact of proposed tariffs on our industry, US consumers, and the short and long-term implications for music education. Read the full letter here.