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National Association of Dental Laboratories (NADL)
News Alert – April 9, 2018
Proposed Tariffs on Imported Dental Laboratory Restorations
Preliminary analysis of USTR-2018-0005 applicability to dental laboratories
On April 3, 2018, the Office of the U.S. Trade Representative (USTR) Notice proposed imposing an additional duty of 25 percent on a list of products from China.
Read the notice at: https://ustr.gov/sites/default/files/files/Press/Releases/301FRN.pdf
The notice sets a public comment period through May 11, 2018 and a public hearing is to be held on May 15, 2018.
The products that will be subject to the 25% additional duty are listed using subheadings of the Harmonized Tariff Schedule of the United States (HTSUS).
The subheadings 90212140 and 90212180 are included in the list of products. (See USTR 2018-0005 at page 54)
Subheadings 90212140 and 90212180 include dentures, crowns, abutments, implants, fixed bridges, temporary inlays, onlays, veneers.
NADL's analysis of applicability to dental laboratory products is based on the outcomes of a prior Tariff Classification Ruling.
That ruling can be viewed at https://rulings.cbp.gov/detail.asp?ru=800171&ac=pr.
If the USTR’s proposal becomes effective, then dentures, crowns, abutments, implants, fixed bridges, temporary inlays, onlays, veneers that come from China will be subject to an additional 25% tariff.
What is the impact on the actual cost of imported restorations, if the tariffs become effective?
If a dental laboratory or other purchasing entity pays $20.00 for a Chinese crown currently, then if the tariff becomes effective they will now pay $25.00.
The duty is levied at the time of import and is paid by the importer of record.
The Tariff is calculated on the transaction value which would typically be the price the importer is paying.
Definition of Transaction Value located at https://en.wikipedia.org/wiki/Customs_valuation#Transaction_value
What is the effective date of the Tariff? Could the proposed Tariff be repealed before it goes into effect?
No tariffs take effect until USTR issues a Final Determination. The USTR’s Final Determination could change the amount of the tariff to be charged, or if they are using this as some bargaining chip to reach some another agreement, they could back off of the China tariff entirely.
Since May 22, 2018 is the due date for submission of post-hearing rebuttal comments, presumably USTR would wait until after they reviewed those comments before issuing a Final Determination.
If the USTR does go forward with the China tariff, the USTR’s Final Determination wouldn’t come out till probably June 2018 at the earliest and then may allow some number of days from when the Final Determination is issued before the effective date when any tariffs needs to start being paid. This means any proposed tariffs likely wouldn’t take effect until mid-June or early July.
What is NADL’s position on the proposed tariffs?
NADL’s Board of Directors meets later in April and will be discussing the proposed tariffs. The Board of Directors will determine any position it may take and consider any public comments it may submit for the public comment process at its upcoming Board meeting.
The NADL will continue to release updates to its membership and interested parties based on future USTR actions.
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