Additional EU Origin Products Proposed for Section 301 by USTR

The U.S. Trade Representative (USTR) proposed a supplemental list that may potentially be subject to Section 301 duties for European Union (EU) origin products, unless the EU removes their subsidies on large civil aircraft to Airbus. This is a result of the ongoing dispute with the EU over aircraft subsidies at the World Trade Organization (WTO).

This supplemental list adds 89 Harmonized Tariff Schedule (HTS) subheadings, with a trade value of approximately $4 billion, to their initial list published on April 12, 2019.

(For details on the initial list, please see our previous Trade News article USTR Proposes Section 301 Duties on EU Products, Including Aircraft.)

Public comments are being sought by the USTR on the specific products added to the list; the level of increase, if any; and whether increased duties on a particular product may have an adverse effect on U.S. stakeholders.

Comments may be filed on-line at using docket number USTR-2019-0003.

Below are the due dates for the proposal:

  • July 24, 2019 – Due date for requests to appear at the public hearing
  • August 5, 2019 – Public hearing by Section 3-1 Committee in Washington, DC
  • August 5, 2019 – Due date for submission of written comments
  • August 12, 2019 – Due date for submission of post-hearing rebuttal comments

If the USTR decides to take action, a final list of product subject to additional duties, of up to 100 percent, would be drawn from both this and previous lists.  The final list will take into account the report of the WTO Arbitrator on the level of countermeasures.

If you have any questions regarding USTR’s proposal to subject EU supplemental tariffs to Section 301 duties, Livingston can help!  Please contact either your Livingston account manager or our regulatory affairs group at