Arlington, Va. — The Air-Conditioning, Heating, and Refrigeration Institute (AHRI) today submitted comments to the Office of the United States Trade Representative (USTR) in opposition to a fourth round of Section 301 tariffs on Chinese imports. The comments, which were in response to a May 17 Federal Register notice, echoed AHRI's previous opposing comments (Round 1, Round 2, Round 3), re-emphasizing that the tariffs limit member company access to a global supply chain for components, while bringing about the following harmful economic consequences:

• Increased costs for manufacturers and expected negative cost impacts on consumers.


• A dampening effect on the industry's efforts to make more energy efficient equipment available in the marketplace.


• An unintended hampering of industry's ability to address climate change because of higher than necessary demand on the electric grid due to reduced access to energy efficient equipment.

"For many of our members, the uncertainty of the exclusion process combined with the continued threat of tariffs creates a business climate that stymies their ability to continue to create jobs that power the U.S. economy," said AHRI President & CEO Stephen Yurek. "We will continue to interact on behalf of our negatively affected member companies in hopes that the injurious tariff situation is resolved quickly," he added.

AHRI's comments also expressed its disappointment with a lack of a tariff exclusion process in the May 17 Federal Register notice. Although AHRI has indicated its displeasure and dismay at a slow and burdensome the exclusion request process, it nevertheless requested in its comments that the USTR should be sure to make available a process for exclusions if the fourth round of tariffs go into effect.

AHRI members are concerned that since the beginning of the Section 301 exclusion process (including $34 billion and $16 billion), the exclusion approval rate for the HVACR and water heating industry is 39.5 percent lower than it is for all industries combined. In fact, only 11 percent (200 unique requests) of the requested AHRI member products and equipment have thus far been granted an exclusion. Of the 1,877 exclusion requests AHRI members have made to the USTR, 858 still await a decision (in review stages 1-3), with some having been pending for as long as 312 days (since August 8, 2018).