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	空载重量25吨及以上飞机的挡风玻璃	Windshield of aircraft with an unladen weight of 25 tons and above	2	1
8412 2990	压力值在20MPa以上的飞机用液压作动器	Hydraulic actuators for aircraft with pressures above 20 MPa	14	1
8482 1040	飞机发动机用外径30CM的推力球轴承	Thrust ball bearings with an outer diameter of 30CM for aircraft engines	8	1
9032 8990	飞机自动驾驶系统（包括自动驾驶、电子控制飞行、自动故障分析、警告系统配平系统及推力监控设备及其相关仪表）	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	飞机自动驾驶系统（包括自动驾驶、电子控制飞行、自动故障分析、警告系统配平系统及推力监控设备及其相关仪表）的零件	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.