The Office of the United States Trade Representative (USTR) has released a list of products imported from China subject to additional tariffs as part of the U.S. response to China’s unfair trade practices related to the forced transfer of American technology and intellectual property. Every single product that is imported into the US is assigned a code called Harmonized Tariff Schedule (HTS). Section XVI, chapter 85 defines the HTS codes for every piece of electrical equipment/machinery/accessory. The HTS code for LED drivers/power supplies is 8504.40.95.
Based upon their respective HTS codes, LED drivers/power supplies from ERP Power are NOT included in the first and second lists of products and, therefore, are NOT subject to the China tariff increase which took effect on July 6, 2018.
Here is a USTR fact sheet regarding the tariffs.
On July 10, 2018 the Office of the United States Trade Representative announced a third group of products for public comment. LED Drivers are included in this third product list.
On September 17, 2018, the USTR announced a final third group of products tariffs will go into effect as of September 24, 2018 as a 10% tariff, which could increase to a 25% tariff for LED Drivers at a future unspecified date. The HTS code 8504.40.95 for LED drivers/power supplies appears in the final version of this third product list.
On December 1, 2018 the implementation of the 25% tariff was delayed until March 1, 2019.
On February 24, 2019, it was announced implementation of the March 1, 2019 tariff increase to 25% has been delayed.
Effective October 15, 2019 ERP Power products were scheduled to be subject to a 30% import tariff when being shipped to the USA. On October 13, President Trump announced the planned tariff increase from 25% to 30% would not go into effect on October 15th.
ERP Power is not increasing our DDP Los Angeles INCOTERMS of 15% of gross purchase price for all purchase orders received in September or October 2019 which are scheduled to have product delivered in Los Angeles prior to December 31, 2019. Effective January 1, 2020, the DDP Los Angeles INCOTERM may increase to 20% of gross purchase price if the USTR increases the tariff from 25% to 30%.
Since May 15, 2019, ERP Power has been offering a new INCOTERMS option called “DDP Los Angeles” for incoming purchase orders. DDP is an abbreviation for “Delivered Duty Paid”. ERP Power products will be available for pickup in Los Angeles, CA delivered duty paid to the United States from ERP’s point of manufacture with up to an additional 4-week (30 days) lead time reflective of sea shipment transit time.
ERP Power is encouraging all direct purchase customers to review your LED driver demand forecast for Q3 and Q4 2019 to consider the savings opportunity of the 15% shipping and handling fee associated with “DDP Los Angeles” INCOTERMS as compared to the 25% import tariff associated with “EXW ERP China Factory” or “FCA Hong Kong”.
Customers may continue to purchase products from ERP Power with Ex Works “EXW ERP China Factory” or “FCA Hong Kong” INCOTERMS, and the customer will be responsible for payment of the import tariff in effect at the time of shipment as the importer of record to the United States.
ERP Power will continue to monitor the situation and keep you informed with any updates. More information from the USTR is available online at: https://ustr.gov/