SIA USTR Letter
August 19, 2018

The Honorable Robert Lighthizer
United States Trade Representative
600 17th Street NW
Washington, DC 20508


Dear Ambassador Lighthizer:

As the trade association for the US snow sports industry that generates $72 billion in retail spending annually, we are writing to express our concerns over the recently announced tariffs on $200 billion on consumer goods from China.

This action concerns us for a number of reasons:

• The products of our concern are ski gloves (HTSUS subheadings 4203.21.55 and 4203.21.60), knit hats (HTSUS subheadings 6505.00.50 and 6505.00.60), safety headgear (HTSUS subheadings 6506.10.30 and 6506.10.60) and sports bags (HTSUS subheadings 4202.92.31, 4202.92.39, and 4202.92.45). It is our understanding that the proposed additional duties are intended to pressure the Chinese government to eliminate certain acts, policies, and practices that the United States has determined to be harmful to its economic interests such as industrial policies in support of China’s efforts to rely exclusively on high tech goods manufactured in China, theft of intellectual property from U.S. companies, and related acts, policies, and practices. The products of interest to SIA are not the type of products that are the targets of the Chinese acts, policies, and practices of concern to the United States and imposition of additional duties on these products therefore would not aid the goal of China eliminating such acts, policies, and practices.

• The USTR has specifically asked for comments on whether imposing additional duties on a particular product would cause disproportionate harm to U.S. economic interests, including small or medium-sized businesses and consumers. We are an industry selling widely recognized brands through specialty, community-based retail shops that are the backbone of our industry. Our economic vitality depends on tight margins throughout our supply chain and selling our products at a fair price each season. With even a slight increase in prices, the economic viability of our industry is in jeopardy and the impacts will be felt across our local communities and tourist-dependent resort towns, as well as by individual consumers in the United States.

• We understand that there is no U.S. production of the products of interest. Thus, there would be no harm to U.S. interests in removing the products from the USTR list.

Snowsports Industries America (SIA) strongly opposes the tariffs on ski gloves, safety headgear, knit hats and sports bags, and we urge you to remove these products from the USTR list. Doing so will protect U.S. jobs and benefit consumers.

Thank you for your consideration.


Sincerely,

Nick Sargent, President
Snowsports Industries America

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