The National Electrical Manufacturers Association (NEMA) has responded to the U.S. Trade Representative’s (USTR) request for comments on the proposed modifications and exclusion process of Section 301 tariffs. NEMA supports the Administration’s goals of addressing concerning policies and practices from China but emphasizes the need for a balanced approach to safeguard the competitiveness of the domestic electrical manufacturing industry.

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As pioneers in the transition to an all-electric future, NEMA members have invested over $12 billion since 2021 to boost U.S. production of clean energy-focused electrical goods. This investment has contributed to a 6.7 percent reduction in U.S. imports of electroindustry goods from China between 2018 and 2023, with China’s share of U.S. electroindustry imports declining from 28.2 percent in 2018 to 17.9 percent in 2023.

NEMA highlights the complexity of global supply chains within the electrical manufacturing sector and cautions against a uniform tariff policy that could hinder manufacturers’ competitiveness. The proposed increase in Section 301 tariffs on $20.5 billion worth of imported goods from China would disproportionately affect the electroindustry, as these goods represent 71.3 percent of the higher tariffs. Additionally, the withdrawal of tariff exclusions on 26 electrical products would impose an extra $1.6 billion in duties annually on the industry.

While NEMA supports the new product-specific exclusion process, it urges the USTR to broaden its focus to include electrical goods. This consideration is crucial for supporting the production of clean energy and advanced technology goods in the U.S.

“Electrical manufacturers are working hard to strengthen U.S. manufacturing of critical clean energy goods by reshoring, new-shoring, near-shoring, and friend-shoring critical supply chains,” said NEMA President and CEO Debra Phillips. “We share the Administration’s goal to enforce compliance on international trade, and we encourage USTR and the Administration to review our recommendations and consider the impacts of Section 301 tariffs on competitiveness and the energy transition, particularly as they relate to products that cannot be sourced elsewhere.”

NEMA’s recommendations to USTR include expanding the tariff exclusion process to cover electrical goods, establishing an appeal and rectification process for non-extended tariff exclusions, publishing a consolidated list of Section 301 tariff lines, and initiating an independent investigation of the economy-wide impacts of the Section 301 tariff regime. Additionally, NEMA calls on the President and Congress to provide incentives for investment in the production of stationary lithium-ion batteries in the U.S. and to base Section 301 tariff rate increases on empirical data and market realities.

NEMA’s full comments can be found here.