March 20, 2020

By Samir Kapadia, The Vogel Group


Dear Member:

As an update to government policy on trade and tariffs, the US Trade Representative is now evaluating the merits of individual exemption filings on the basis of companies responding to the COVID-19 pandemic.

On March 20th, the Office of the U.S. Trade Representative announced that it would receive comments on potential modifications to existing Section 301 tariffs in line with COVID-19 pandemic. Here are key highlights:

  • The submissions would be limited to comments on products subject to the tariff actions.
  • Products must fit into relevant categories linked to the medical response to the coronavirus.
  • Any changes to tariff policy would likely be modifications to existing tariff lists, as opposed to exclusions.
  • Public comments via the docket would be taken until at least June 25, 2020.

If ACMA members have any arguments they would like to make about their imports being relevant within these parameters, do not hesitate to reach out to ACMA’s Lynn Noble ( or me directly (



About the Author:
Mr. Kapadia heads The Vogel Group’s trade practice. His work has included pursuing exemptions for clients that import commodities, components and/or finished products into the United States. Additionally, he has led foreign direct investment campaigns for large multinational clients totaling over $1.2 billion in new capital expenditure over the past two years. His extensive relationships with federal and state government officials has provided clients a pathway to both identify and manage government risk. With a bipartisan background, his previous policy experience includes working for former Congressman Frank Wolf (R-VA) and Senator Mark Warner (D-VA). He can be reached at


ACMA Contacts:
Paul Miller, vice president & deputy director, 914-669-8391,

Hamilton Davison, president & executive director, 800-509-9514,

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