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Changes to US’ China Tariffs, But Little Relief for Aircraft Parts

The US-China trade conflict, and the negotiations seeking to settle it, remain as front-page news. But there are some quiet behind-the scenes changes that are creating narrow exclusions for certain types of goods. Just not for aircraft parts.

Although the United States has imposed duties on aircraft parts from China, the United States Trade Representative (USTR) initiated a product exclusion process in June 2019. This permitted “interested persons” to request exclusion of specific products from the tariff schedules. On Monday, the government announced new exclusions.

The government created new exceptions for valve lifter (for piston engines) but specifically excluded valve lifters for aircraft engines. This shows us that aviation parts remain a focus for the USTR.

Details of the ‘Phase One” trade deal between the US and China have not yet been released, but it appears likely that aircraft parts will not be given relief under that “phase one” trade deal.

Meanwhile, China appears to be reducing certain duties charged for imported US goods. They’ve announced targetted tariff reductions and published a list of 859 products for which the duties are being lowered in 2020. Some of the key aviation-related tariffs listed in this table include these five:

Chinese Tariff Code Chinese Good Description Google translation – the original Chinese takes precedence! Most favored nation tax rate in 2020 (%) Provisional tax rate in 2020 (%)
7007 1110 ????25??????????? Windshield of aircraft with an unladen weight of 25 tons and above 2 1
8412 2990 ????20MPa??????????? Hydraulic actuators for aircraft with pressures above 20 MPa 14 1
8482 1040 ????????30CM?????? Thrust ball bearings with an outer diameter of 30CM for aircraft engines 8 1
9032 8990 ????????(??????????????????????????????????????????) Aircraft autopilot system (including autopilot, electronically controlled flight, automatic fault analysis, warning system trim system, thrust monitoring equipment and related instruments) 7 1
9032 9000 ????????(??????????????????????????????????????????)??? Aircraft autopilot system (including autopilot, electronically controlled flight, automatic fault analysis, warning system trim system, thrust monitoring equipment and related instruments) 5 1

Note that based on the translations, the Chinese Tariff Codes do not appear to line-up with the corollary tariff codes in the US Harmonized Tariff Schedule.