NAMM Files Two Formal Comments With U.S. Trade Representative Seeking Tariff Relief for Musical Instruments

The National Association of Music Merchants (NAMM), the leading nonprofit trade association for the global music products industry, this week filed two formal written comments with the Office of the United States Trade Representative (USTR), continuing the association’s sustained advocacy for tariff relief on behalf of music makers, music retailers, American instrument manufacturers and school music programs nationwide. 

The filings, submitted in response to Federal Register notices published by USTR, address two separate federal trade proceedings and build on the detailed economic record NAMM established in its April 15, 2026, comment and May 8 hearing testimony in USTR’s Section 301 investigations. 

Supporting Reciprocal Tariff Relief Through the U.S.–China Board of Trade 

In comments filed under Docket No. USTR-2026-0430, NAMM expressed strong support for the establishment and stated objectives of the U.S.–China Board of Trade and urged USTR to place musical instruments, accessories and related products on the initial list of non-sensitive products eligible for reciprocal tariff modification. The filing asks USTR to eliminate or substantially reduce the Section 301 additional duties on products classified under HTS Chapter 92 — duties that currently range from 7.5-25% depending on the applicable tariff list — and to pursue reciprocal reduction of Chinese retaliatory tariffs on American-made professional instruments. 

The comment documents the burden current tariffs place on the industry. In 2025, American music product companies paid approximately $1.34 billion in tariffs, and independent analysis by the Peterson Institute for International Economics found that the average effective tariff rate on U.S. musical instrument imports reached 15.9% in 2025 and 16.6% in the first quarter of 2026. In 2025, U.S. imports of wind instruments fell 27%, and piano imports fell 20.3% — declines concentrated in the student-grade instruments purchased by school districts, community music programs and families. 

Seeking an Exemption in the Section 301 Forced Labor Investigations 

In separate comments filed under Docket No. USTR-2026-0265, NAMM affirmed its support for the Administration’s goal of eliminating forced labor from global supply chains, while urging USTR to add HTS Chapter 92 products — musical instruments, parts and accessories — to the exemptions in Annex A of the proposed action. The filing explains that additional duties on musical instruments would not contribute substantially to eliminating the practices under investigation, and would instead impose further costs on American students, schools, retailers and manufacturers already bearing a severe and compounding tariff burden. NAMM also requested that raw material inputs used in American instrument manufacturing be included within the exemption. 

The Pipeline That Sustains American Manufacturing 

Both filings emphasize the market structure that distinguishes the music products industry: Affordable, entry-level instruments — most of them imported — are the pipeline that develops the students, players and future professionals who sustain demand for American-made premium instruments. Tariffs that price entry-level instruments out of reach for the approximately 25 million children participating in school music programs do not protect American manufacturing jobs; they narrow the pipeline that creates those customers in the first place. 

The music products industry is a $19.5 billion global business supporting more than 475,000 workers in the United States and abroad. NAMM’s full comments are publicly available on the USTR comment portal at comments.ustr.gov. 

For more information and to stay involved, consider joining NAMM’s monthly tariff webinars.