MEMA Trade Resources

North American Free Trade Agreement (NAFTA)

Section 232 Tariffs on Steel and Aluminum

China Section 301 Investigation 

How You Can Get Involved


North American Free Trade Agreement (NAFTA)

MEMA Staff Contacts: Ann Wilson and Leigh Merino

Take Action

MEMA One Pagers


Additional NAFTA Resources

Media Coverage

Driving American Jobs Coalition 

Section 232 Tariffs on Steel and Aluminum

  1. Are NAFTA countries and other countries exempted; if so, for how long? Steel and aluminum tariffs on imports from non-exempted countries are effective today, March 23. However, the USTR announced temporary exemptions only until May 1, 2018 are granted to: Canada, Mexico, Australia, Argentina, Brazil, South Korea, and the European Union – pending ongoing discussions with the USTR. White House officials have been clear that there will likely need to be some “rebalancing” of the tariff number or implementation of quotas to ensure that imports from the exempted countries do not “undermine” the national security objectives of the tariffs. Therefore, the current 25%/10% tariff levels may go up for the remaining countries and country quota, even for exempt countries, may be introduced at any time.  

  2. Exclusions versus Exemptions: Under the Section 232 tariffs, exclusions are for products, exemptions are for countries.

  3. How will US Customs handle imports from the temporarily exempted countries? See instructions to US CBP and the March 22 proclamations adjustments for temporary exemptions modifications.

  4. Which HTS codes are impacted and when? All of the HTS codes listed in the Proclamation are subject to the tariffs as of March 23 (except for the temporarily exempted countries). We urge companies to thoroughly review the HTS codes to assess your company’s exposure.


China Section 301 Investigation and Actions to Address Intellectual Property Violations


  • MEMA Staff Contacts: Ann WilsonCatherine Boland, and Leigh Merino

  • On March 22, President Donald Trump announced actions against China to impose tariffs on billions of dollars’ worth of imports. These tariffs are based on findings of IP theft and technology transfer in the Office of the U.S. Trade Representative’s (USTR) Section 301 investigation report. These tariffs will be on a list of products to be unveiled within 15 days and are one of a set of proposed remedies that also included planned restrictions on Chinese investment in U.S. high-tech industries and a World Trade Organization (WTO) case against discriminatory licensing practices.

  • Presidential Memorandum “Actions by the United States Related to the Section 301 Investigation of China’s Laws, Policies, Practices, or Actions Related to Technology Transfer, Intellectual Property, and Innovation” (as published in the Federal Register)

  • The USTR identified potential targets based on their investigation’s report: 1,300 product lines worth about $48 billion.

  • Additionally, Treasury Secretary Mnuchin was directed to deliver a list of restrictions on Chinese investment, including state-sponsored investment funds, acquiring American companies to gain access to their technology.

  • ​MEMA issued a statement applauding the focus on intellectual property but questioning the remedy.  In part, the statement read, “MEMA applauds the administration’s continued focus to protect intellectual property and stop IP abuses in China. Suppliers have long advocated for strong global protections of IP investments. However, we do not support using tariffs to curb intellectual property theft.” You can find the entire statement here. MEMA has a lengthy history of pushing for greater protections of intellectual property, including submitting comments to USTR last year outlining specific challenges in China.​

  • Following President Trump’s Section 301 decisions, on March 23, the USTR launched a new WTO challenge against China.

  • On April 3, the USTR released its Notice of Proposed Determination (NPRM) regarding actions related to trade practices of China. Contained in the notice is the list of possible HTS codes for over 1300 products imported from China with a 25% tariff.

    • Several vehicle parts and components are listed (examples include: seat parts, tires, wire harnesses, batteries, bearings, turbocharger fans). Additionally, many of the HTS codes overlap the Sec. 232 steel and aluminum products, such that the Sec. 301 tariffs would be on top of the Sec. 232 tariffs.

    • The USTR will take public comments through May 11 and will hold a public hearing on May 15 before making a final determination. Parties interested in testifying must notify the USTR by April 23. Rebuttal comments to the hearing are due May 22.

    • USTR has created and made available a form they are encouraging companies filing comments to use. Instructions on how to file comments are included in the NPRM.

    • MEMA will be submitting comments and requesting to testify during the USTR hearing. MEMA is also asking members to review USTR’s proposed list and let us know of any other componentry or subcomponents that your company may utilize that are shown on the list and what affect this may have.

  • On April 12, Ann Wilson, MEMA’s Vice President of Government Affairs, testified before the House Ways and Means Committee on the negative impact of both the Section 232 and 301 tariffs.

How You Can Get Involved

  • Visit the MEMA Action Center to contact the members of Congress representing you and your facilities and educate them on the impact trade policy could have on your business

  • Schedule a meeting with your members of Congress, in D.C. or their local office; or invite them to tour your manufacturing facilities. Find your members of Congress and their contact info here

  • Participate in the MEMA Trade Working Group or the MEMA Government Affairs Committee, which help develop policy and strategy positions, by contacting

  • Register for MEMA’s Legislative Summit and tell your story on Capitol Hill, April 10-11, 2018

  • Subscribe to MEMA’s Washington Insider newsletter by contacting

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