ALA Details Section 301 Tariffs for Members

In a message to its membership, the ALA highlighted key points in the latest (Section 301) tariffs affecting 60 U.S. trading partners.

Following the White House’s announcement on July 20 that new tariffs will begin on August 24, effectively continuing the conditions of the previous tariffs on the day they expired, the American Lighting Association (ALA) alerted its membership about the potential effect.  

“The United States Trade Representative (USTR) has finalized a new tariff framework under Section 301 targeting 60 trading partners over forced labor enforcement,” the message to ALA members read. “These new duties take effect immediately and are intended to replace the expiring 10% Section 122 tariffs with a more durable legal framework. The Federal Register notice, including annexes, is available here.”

The ALA listed the key changes:

• New tariff rates – Imports from the 60 affected countries will face either a 10% or 12.5% Section 301 tariff, depending on whether the exporting country has adopted or committed to stronger forced labor import prohibitions through Agreements on Reciprocal Trade (ARTs) or similar measures. Countries without those commitments generally fall into the 12.5% category.

• Effective date – Tariffs apply to goods entering the U.S. beginning 12:01 a.m. ET on July 24, with limited relief for qualifying shipments already in transit before the deadline.

• Exemptions – Products excluded from the new tariffs include items already subject to Section 232 duties, qualifying USMCA goods, Chapter 98 entries, and exempted products identified by USTR.

 ALA’s announcement stated that many decorative lighting products, LED fixtures, portable lamps, ceiling fans, fan accessories, and related electrical components imported from major sourcing countries (including China, Vietnam, Cambodia, Malaysia, Taiwan, and other Asian manufacturing hubs) will continue to face additional import duties if sourced from countries covered by the new Section 301 action.

The exact duty will depend on the country of origin, applicable Most Favor Nations (MFN) rate, and whether the product qualifies for any listed exemption.

ALA noted that for its manufacturer and importer members, the new tariff “largely maintains the elevated cost environment rather than creating a significant new increase. Companies should anticipate a continuation of broad-based tariff exposure under different legal authorities.”

According to ALA and its government affairs consultant Palmer Schoening:

“With [the] expiration of the 150-day Section 122 tariffs (initially put in place to replace the struck down IEEPA tariffs), USTR is now moving towards utilizing the more well-established Section 301 and Section 232 authorities.

• Existing tariff planning strategies remain important, as broad duties continue on imports from many key sourcing countries.

• Product classification and country-of-origin reviews remain critical to determine whether any product-specific exclusions apply.

• Businesses importing qualifying products from USMCA partners or products already covered under Section 232 or Chapter 98 provisions should review eligibility, as those goods are not subject to these new Section 301 duties.”

Looking forward, ALA’s note to membership also cautioned: “The USTR is still conducting ongoing Section 301 investigations into manufacturing overcapacity involving key manufacturing economies, including China and several other major exporters. These investigations are examining whether government policies have created unfair production advantages in sectors that compete with U.S. manufacturing. While much of the public discussion has centered on steel, semiconductors, batteries, solar products, and electric vehicles, the investigations could ultimately affect additional manufactured goods depending on the final determinations. ALA members should consult with their brokers and suppliers about price changes to their specific imported products. [ALA] will continue to keep you updated on the latest tariffs developments.”

ALA members are welcome to contact Palmer Schoening or ALA CEO Jon Melchi with questions and concerns.

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