China 301 Duties Exclusion Process Revived for Certain Items, But Not Optical Products at this Time

Based on recent news, there is an opportunity for The Vision Council and our members to advocate for relief from China 301 duties. In a speech given at the Center for Strategic and International Studies on October 4, 2021, U.S. Trade Representative (USTR) Katherine Tai announced the Biden administration’s strategic vision regarding trade with China. One of the main takeaways from the speech was that the U.S. will revive a targeted tariff exclusion process for specific products and industries currently subject to China 301 duties and keep open the potential for additional exclusion processes.

On October 5, 2021, the USTR’s Office clarified which products and industries would benefit initially from a revived exclusion process and opened a comment period to discuss extending the exclusions for products where the exclusion had previously been given an extension before being sunset.

Product exclusions were for a specific period, typically one year. At the end of the period, affected parties could request an extension to the exclusion. More than 2,200 exclusions were granted, including ones covering spectacle frames and reading glasses, but only 549 of them were extended and the extension requests for spectacle frames and reading glasses were denied. Now, companies affected by the 549 product extensions are invited to provide reasons why they should benefit from a new China 301 duties exclusion period going forward.

While this round of exclusions will not benefit members of The Vision Council, the inclusion of optical products in a reconstituted China 301 tariff exclusion process is a top priority for The Vision Council. Toward that goal, The Vision Council will be meeting with Congressional representatives to explain why the full range of optical products, many of which are Class I medical devices and made exclusively in China, should be within the next grouping of products that could be subject to tariff exclusions.

The Vision Council is eager to add members’ voices to our outreach and will follow up with opportunities to engage as the situation evolves. The Vision Council will continue to update the membership on this important topic.

For questions and concerns, please contact:

Ashley Mills, CEO
Maureen Beddis, Vice President of Marketing and Membership

FDA Agent Program
Government and Regulatory Affairs
Sunglass & Reader Division
Lens Division
Lab Division
Lens Processing Technology Division
Low Vision Division
Optical Retail Division
Eyewear & Accessories Division