May 11, The Honorable Robert Lighthizer United States Trade Representative th Street NW Washington, DC 20508

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1 The Honorable Robert Lighthizer United States Trade Representative th Street NW Washington, DC RE: Section 301: China s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation (Docket USTR ) Dear Ambassador Lighthizer, On behalf of the National Retail Federation, we are submitting these comments on behalf of our members in response to the Office of the U.S. Trade Representative s (USTR) request for public comment concerning proposed tariffs of 25 percent to be applied to selected products in response to Section 301: China s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation. 1 NRF is the world s largest retail trade association, representing discount and department stores, home goods and specialty stores, Main Street merchants, grocers, wholesalers, chain restaurants and Internet retailers from the United States and more than 45 countries. Retail is the nation s largest private sector employer, supporting one in four U.S. jobs 42 million working Americans. Contributing $2.6 trillion to annual GDP, retail is a daily barometer for the nation s economy. USTR is seeking comments about whether specific products on the proposed list should be retained or removed, or whether other products should be added; whether the proposed tariff level should be increased; and what amount of total trade is appropriate to be covered by additional duties. More specifically, USTR is seeking comments on whether imposing increased duties would be effective in eliminating the Chinese practices that are the subject of the Section 301 investigation, and whether imposing the duties would cause disproportionate economic harm to U.S. interests, including small- or medium-sized businesses and consumers. 1 Office of the U.S. Trade Representative, Notice of Determination and Request for Public Comment Concerning Proposed Determination of Action Pursuant to Section 201: China s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation, Federal Register, Vol. 83, No. 67, April 6, 2018.

2 Page 2 NRF strongly opposes any efforts to include or add consumer products to the list of products subject to additional tariffs. We do not recommend that any products be added to the proposed list, or that the proposed tariff rate be increased in any way, or that the level of trade affected be expanded. NRF cannot speak to the question about whether the products and the tariff chosen will motivate China to change its practices, but we can and do know how China will respond to the imposition of tariffs: based on history and current statements of government officials, all indications are that China will retaliate against U.S. exports. We also know the impact that the proposed tariff will have on U.S. retailers and their consumers. NRF s comments in this submission focus on USTR s request for information about the economic impact the proposed tariffs on U.S. interests the economy and jobs and on consumers. While we appreciate that the Administration s intent (as described in the Federal Register notice) was to minimize that consumer impact, 2 unfortunately many of the consumer goods chosen will have a significant negative impact on consumers. China Trade Issues: There is a Problem; Tariffs Are Not the Answer NRF joins the U.S. business community broadly in support of the conclusion by USTR through the Section 301 investigation that China maintains acts, policies and practices that infringe on U.S. intellectual property rights, that require or pressure U.S. companies seeking to maintain operations in China to transfer innovative technologies and intellectual property to Chinese companies, among other related practices. Unfortunately, these are measures that have been irritants to U.S. and, indeed, global companies for decades. Unfortunately, past promises by China to change many of these practices have been unfulfilled. The frustration with inaction that has given rise to the temptation to use the President s threat of the imposition of tariffs to force change in China is understandable. However, NRF s members fear that, if ultimately imposed, tariffs would prove to be a bludgeon not to Chinese companies and policymakers but to instead to U.S. companies, workers and consumers (we discuss this more fully below). In lieu of tariffs, NRF has been working closely with an ad hoc coalition of more than 100 organizations and companies to develop responses we believe would be more appropriate. 2 Trade analysts from several U.S. Government agencies identified products that benefit from Chinese industrial policies, including Made in China The list was refined by removing specific products identified by analysts as likely to cause disruptions to the U.S. economy, and tariff lines that are subject to legal or administrative constraints. The remaining products were ranked according to the likely impact on U.S. consumers, based on available trade data involving alternative country sources for each product. The proposed list was then compiled by selecting products from the ranked list with lowest consumer impact. FRN p

3 Page 3 We believe as a first order priority that any action the United States takes to incentivize China to modify its practices must be consistent with U.S. obligations as a member indeed, a founding member of the World Trade Organization (WTO). We must remember that the WTO has checked many countries from imposing protectionist policies and barriers that would have otherwise harmed U.S. exports of both goods and services. Joining with other WTO Members to challenge Chinese practices in that body is the best option. Where an act, policy or practices is not covered by WTO rules, any action the United States might impose to motivate change by China should be as targeted as possible in order to inflict the least possible damage to the U.S. economy. Unfortunately, the proposed U.S. tariffs on imports from China do not fit that bill, as we demonstrate more fully below. We Live in a New World To understand why tariffs are an imperfect tool with wide and unexpected consequences, the Administration must remember that we live today in a world of global supply chains, supported by millions of U.S. jobs. Retailers understand this perhaps better than any other sector, as we are the last link between producers and consumers. We source goods from U.S. manufacturers and from foreign suppliers. We know first-hand that, more often than not, parts and components are exported from the United States to other countries where they are combined with other parts and components and/or assembled, and then imported back into the United States. Also, more often than not, R&D, design, marketing and other high-wage activities happen in the United States, the value of which is embedded into the final retail price of the goods sold in our stores. According to the OECD/WTO Trade in Value Added database, 3 percent (2011, most recent year) of the value of goods imported into the United States from China represents U.S. content. For example, U.S. glass is used to make the screens of some of the televisions imported from China that would be subject to the proposed tariffs. For some products, like apparel, the U.S. content share is as much as 70 percent something to bear in mind if the Administration ever considers expanding the list of products proposed for tariffs to include other consumer goods. 3 A tariff on those goods is therefore a tax on U.S. exports and U.S. jobs. A tariff on imports from China that makes those goods less competitive to U.S. consumers or not available at all any more punishes U.S. exporters of the components and other raw materials, including 3 Analyzing the Value Chain for Apparel Designed in the United States and Manufactured Overseas. Prepared by Moongate Associates for the U.S. Global Value Chain Coalition -

4 Page 4 the R&D and design and other services that are also contained in the value of the product: U.S. exports are damaged as well. Impacts of Proposed Tariffs on U.S. Jobs and Consumers To help the Administration understand the full economic consequences of the imposition of U.S. tariffs on imports of the selected products from China, NRF joined with the Consumer Technology Association to commission research by Trade Partnership Worldwide using an economic model employed by the U.S. International Trade Commission and others to assess the economic effects of trade policy changes. This model takes into account the degree to which other countries can or cannot substitute supply for products otherwise sourced from China, as well as the degree to which the tariff costs are absorbed along the supply chain. A copy of the study is provided in Appendix A. The study s authors found that the imposition of the U.S. tariffs on $50 billion in imports from China (of the products proposed) would have a net negative impact on the U.S. economy and cost over 76,000 jobs for each year the tariffs are in effect initially (i.e., the first one to two years). China has already issued a retaliation list of $50 billion in U.S. exports: this action would double the net negative impact on the U.S. economy and nearly double the net negative impact on U.S. jobs to nearly 134,000 annually for the first one-two years. Most of these jobs are held by lower-skilled workers and can be found in every U.S. state. Finally, the authors of the study found that, if the President further imposed an additional $100 billion in tariffs on imports from China (as he threatened after China issued its retaliation list) and China responded in kind (a near certainty), the damage to the U.S. economy would be anything but insignificant (as some Administration officials have predicted). U.S. GDP of would decline by 0.3 percent annually, and nearly 455,000 workers would lose their jobs in each of the first one-two years of the trade war. In every instance, particularly hard hit would be workers in the agriculture sector, in key manufacturing sectors like motor vehicles, other transportation equipment, chemicals, rubber and plastics. In addition, workers in services sectors would be negatively impacted: as workers lose jobs, they spend less money at restaurants, on home improvement projects, on education, or even health care; as prices increase, households have less disposable income to use on new homes, or going out. In short, the ramifications of U.S. tariffs on imports of a select number of goods are farreaching.

5 Page 5 As noted above, Administration officials went to great lengths to selected products for the proposed tariffs that would minimize the impacts of the tariffs on consumers. Unfortunately, they still selected a number of goods for which the negative impact of tariffs would be significant. We provide a list of those items and their Harmonized Tariff System (HTS) numbers in Appendix B that we believe should be deleted from the list. Here, we briefly summarize the impacts for some products and the reasons, based on more in-depth analysis by Trade Partnership Worldwide (a copy of that analysis is included in Appendix C): Televisions The types of TVs currently imported from China that are on the proposed tariff list 4 differ markedly from TVs imported from other countries. In 2016, the average unit value of TVs imported from China was $192. The average unit value of TVs imported from Japan was $1,153; Korea, $939, and Mexico, $367. Clearly, a consumer shopping in the TV price point met by a Chinese-made TV is not going to switch to a TV in the price point of a Japanese-made TV, for example. Of the leading alternative suppliers, the only countries that produced TVs with an average unit value similar to that of China were Thailand, $145; Hong Kong, $206, and Taiwan, $134. As such, sourcing is not easily transferred to other countries, and if retailers continue to purchase televisions from China, their cost would increase by 23 percent. Overall, TV prices are expected to increase by 4.1 percent as a result of the tariffs, and U.S. consumers would cut back on purchases of TVs by 7.8 percent. The tariffs would force consumers to pay $711 million more than they otherwise would for the televisions they continue to buy. The net impact on the economy (the value of U.S. producer gains plus tariff revenues to the U.S. government, minus the value of consumer losses) would be a hit of $322 million. Monitors The tariffs would have a negative impact on U.S. consumers of monitors included on the proposed tariff list. 5 As with TVs, the unit values of monitors imported from China also differ considerably from those of other alternative suppliers, limiting the degree to which other sources of supply can compensate for losses of supply from China. In 2016, the average unit 4 HTS , , , , , , , , , , , HTS , , , , , , , , , , , ,

6 Page 6 value of monitor imports from China was $82, compared to $790 from Japan; $279 from Korea, $500 from Malaysia, and $310 from Canada. The average unit value of imports from Mexico was $148; Thailand, $117, and Indonesia, $65. Therefore, U.S. consumer prices for monitors imported from China would increase by 23.5 percent. Overall, monitor prices are estimated to increase by 2.8 percent, and U.S. consumers would cut back on purchases of monitors by 5.4 percent. The tariffs would force consumers to pay $172 million more than they otherwise would for the monitors they continue to buy. The net impact on the economy (the value of U.S. producer gains plus tariff revenues to the U.S. government, minus the value of consumer losses) is a hit of $36.7 million. Batteries The batteries on the proposed tariff list 6 are used by consumers and manufacturers. Tariffs would have a negative impact on U.S. battery consumers both households and U.S. producers of products that contain batteries in the form of higher prices. U.S. producer prices of batteries increase by 0.3 percent, and consumer prices for batteries imported from China increase by 23.8 percent. Consumer prices for batteries overall increase by 0.8 percent and, as a result, U.S. consumers cut back on purchases of batteries by 1.6 percent. The tariffs will force consumers to pay $24 million more than they otherwise would for the batteries they continue to buy. This is also a product that is exported to global consumer goods assemblers in supply chains that span several countries: higher costs would likely impact those exports negatively. Ink cartridges The imposition of tariffs on the list of ink and cartridge HTS items in the proposed list 7 would have a negative impact on U.S. cartridge consumers both households and U.S. producers in the form of higher prices. U.S. producer prices of ink and cartridges would increase by 1.0 percent, and consumer prices for ink and cartridges imported from China increase by 22.7 percent. Consumer prices for ink and cartridges overall would increase by 4.1 percent and, as a result, U.S. consumers would cut back on purchases of ink and cartridges by 7.8 percent. The tariffs would force consumers to pay $529 million more than they otherwise would for the ink and cartridges they continue to buy. The net impact on the economy (the value of U.S. producer 6 HTS , , , , , , , HTS , , ,

7 Page 7 gains plus tariff revenues to the U.S. government, minus the value of consumer losses) would be a hit of $180 million. Other consumer goods A number of other consumer goods are on the proposed tariff list, including in HTS line items with descriptions that suggest non-consumer use. These include, for example: speakers wire (HTS ); drinking water coolers and water dispensers, ice makers and mini refrigerators (HTS ); dishwashers (HTS ); gardening tools (HTS , , , , ); hand tools (HTS , , , , , , ); cassettes and optical media, Bluetooth transmitters (HTS , , , , ; remote controls (HTS ); Christmas lights (HTS , ); terrarium thermometer ( ); aquarium filters ( ) feeders ( ) water filters ( ); air purifiers ( ); icemakers ( ); and fishing tools and accessories (HTS ), among others. These goods are sourced from China for a variety of reasons, including quality, production scale capabilities, and unavailability of realistic alternative sources of supply. As discussed, it is not as simple as some may think for retailers to quickly change their supply chains. Here is a summary of what is involved: Sourcing decisions typically are made months ahead of delivery. Retailers are making their purchasing decisions anywhere from six to nine to 12 months in advance. So, making changes today to reflect the imposition of new tariffs would not be possible to affect those deliveries i.e., to find lower cost alternatives. Those goods, already ordered, will have to bear the added costs of the tariffs. We heard the following three examples from our members:

8 Page , supply chains cannot be shifted to different countries or facilities without compromising contracts, compliance, quality and value for our consumer. We typically work with our suppliers a year or more in advance and write purchase orders anywhere from six to nine months in advance. 2. Many goods sourced from China have, over time, become sophisticated production models where all of the producers of the parts needed for the product are located in the same place as the manufacturer of the finished product. This is one reason Chinese producers are so competitive. Finding similar integrated supply chains in other countries would be a challenge, especially in the short term. One of our members told us that, for one product on the Administration s list (refrigerators), 3. We buy directly from the OEM s (original equipment manufacturers) that produce in China. And there are only four mini-fridge manufacturers that can handle our scale. The manufacturer buys the compressors from a factory that specializes in that component. They purchase the steel from another manufacturer. The only action that the finishing supplier performs is bends the steel to create the outer housing and does some injection molding to create the inside of the unit. Screws, hinges, nuts and bolts are purchased from specialized manufacturers. There is one supplier that produces their own compressors, but they still outsource some of the product components. I can t think of a finished good that isn t dependent on a component or raw material manufacturer. Finding new vendors in other countries can take years for most retailers. There are a lot of steps involved in finding new vendors. Our members need to verify that new partners can produce the volume of products that are needed at the right quality for a price point the consumer is willing to pay. These vendor verifications also include a review to ensure that new (and existing) vendors meet all of the retailer s codes of conduct everything from corporate social responsibility, labor, environment and security requirements. This also includes all required testing to ensure that products meet all of the appropriate product safety requirements. According to one NRF member, We currently work on an 11-month lead time to identify and commercialize new supplier sources as we have many milestones in place to validate new factory sources meet our internal standards and external consumer expectations. These expectations include but are not limited to due diligence, 3rd party capability assessments, factory capacity studies, validation of testing and safety standards,

9 Page 9 supplier on-boarding, product development, sample validation, production, and transit lead times. In the short term if tariffs are increased we will be forced to pass on this expense to the consumer as we identify and validate alternative factories that can produce these products. This will also require that we allocate company resources to minimize the tariff expense instead of focusing on new and innovative ways to service our customer in an already challenging retail environment. Our early bench marking research tells us that in every scenario this will result in a higher price to the US consumer whether the duty is increased, or we move to higher cost of production countries. Shifting to new countries in concert with hundreds of other buyers presents still more challenges. One member noted:...if we have to try to shift production to different countries in concert with other manufactures, we will face capacity constraints and from our initial research prices that are at least 10% to 30% higher than what we currently pay. This will no doubt contribute to inflation for our customer many of which have limited or fixed income. In addition to the consumer products mentioned, we are also concerned about the impact of the tariffs on several high-tech and industrial products and inputs that retailers rely on for their operations. The tariffs will result in increased costs for these products. Imported hard drives ( ) and parts/accessories of printed circuit assemblies ( ) are essential components in technology products manufactured in the United States such as servers. The imposition of tariffs will represent a tax on these US manufacturers who rely on these inputs, their workers, and on the products they build and export. This will potentially make these products more expensive, raising the price of finished goods and negatively impacting US jobs as foreign competitors gain market share. Requested Action Because of their significant adverse impacts on U.S. consumers, NRF respectfully requests that all of the products on the list included in Appendix B be removed from the list of products proposed for 25 percent U.S. tariffs. We also respectfully request that the Administration refrain from adding any new consumer goods to the proposed list to take the place of goods that are removed from it. We further ask that in regard to a second tranche of potential tariffs on an additional $100 billion worth of imports, the Administration exclude consumer products such as apparel, footwear, toys, home goods, furniture and other goods that would directly impact U.S. consumers.

10 Page 10 NRF respectfully requests that the Administration reconsider altogether the tariff approach to incentivizing China to modify is acts, policies and practices affection U.S. intellectual property rights and investment barriers. The collateral damage to wide swaths of the U.S. economy would not be insignificant. We encourage the Administration to develop a comprehensive strategy in close consultation with the U.S. business community, including retailers, to effectively address the longstanding trade policy issues in China. This strategy must include clearly defined objectives, direct negotiating mechanisms with the Chinese, targeted deliverables, and deadlines with measurable results. This policy must be clearly communicated with stakeholders and must ensure mechanisms to hold China accountable for achieving the results. This must include a concrete list of binding commitments and actions that China can and should take. As another tool to pressure China by making it easier for companies to seek out alternative supply chains, we also recommend that you work with Congress to expand the scope of products eligible for benefits under the Generalized System of Preferences (GSP). China is not a GSP beneficiary. Expanding the products that get GSP eligibility to include apparel and footwear, in particular, would make it cost-effective for many U.S. companies to undertake the investments needed to divert sourcing of these goods from China to GSP-eligible countries. The Administration achieves two goals: exertion of effective pressure on China to change its IPR and other practices, and a decrease in the U.S.-China trade deficit. Conclusion We thank the Administration for the opportunity to testify on this important issue. We look forward to continuing the discussion on how best to address China s unfair trade practices in a manner that focuses on the specific issues without harming U.S. businesses, worker or consumers. Sincerely, David French Senior Vice President Government Relations

11 Page 11 HTS Code Product Description National Retail Federation Submission Docket USTR Appendix B Sterile surgical catgut, suture materials, tissue adhesives for wound closure, laminaria, laminaria tents, and absorbable hemostatics Tubes, pipes and hoses of vulcanized rubber other than hard rubber, not reinforced or combined w/other materials, with fittings Tubes, pipes and hoses of vulcanized rubber other than hard rubber, not reinforced Caps, lids, seals, stoppers and other closures, of noncellular vulcanized rubber other than hard rubber Aluminum (a/than alloy), wire, with a maximum cross-sectional dimension of 7 mm or less Aluminum alloy, wire, with a maximum cross-sectional dimension of 7 mm or less Calendering or other rolling machines, other than for metals or glass, nesi Rotary positive displacement pumps for liquids, not fitted with a measuring device, nesi Centrifugal pumps for liquids, not fitted with a measuring device, nesi Pumps for liquids, not fitted with a measuring device, nesi Parts of air or vacuum pumps and ventilating or recycling hoods Refrigerating or freezing equipment nesi Parts of calendaring or other rolling machines, other than for metal or glass Centrifugal clothes dryers Centrifuges, other than cream separators or clothes dryers Machinery and apparatus for filtering or purifying water Filtering or purifying machinery and apparatus for gases, other than intake air filters for internal combustion engines or catalytic convo Parts for filtering or purifying machinery or apparatus for liquids or gases Dishwashing machines of the household type Machinery for filling, closing, sealing, capsuling or labeling bottles, cans, boxes or other containers; machinery for aerating beverages; nesoi

12 Page Fire Extinguishers, whether or not charged Parts of simple piston pump sprays and powder bellows Winches nesi, and capstans, not powered by electric motor Winches nesi, and capstans, not powered by electric motor Self-propelled works trucks powered by an electric motor, rider type forklift trucks Self-propelled works trucks powered by an electric motor, fitted with lifting and handling equipment, nesi Self-propelled works trucks not powered by an electric motor, rider type forklift trucks Self-propelled works trucks not powered by an electric motor, fitted with lifting and handling equipment, nesi Snowplows and snowblowers Parts suitable for use solely or principally with the machinery of heading Plows for soil preparation or cultivation Disc harrows for soil preparation or cultivation Agricultural, horticultural or forestry machinery for soil preparation or cultivation, nesi; lawn or sports ground rollers Parts of agricultural, horticultural or forestry machinery for soil preparation or cultivation; parts of lawn or sports ground rollers Parts for agricultural, horticultural, forestry or bee-keeping machinery, nesi Parts for machinery used in making paper pulp, paper or paperboard, including cutting machines Parts of printer units of subheading specified in additional U.S. note 2 to this chapter Parts and accessories of printers, nesoi Parts and accessories of copying machines; nesoi Parts and accessories of other printing, copying or facsimile machines; nesoi Tool holders and self-opening dieheads for use solely or principally with machines of headings 8456 to 8465, nesoi Tools for working in the hand, pneumatic, rotary type, other than suitable for metal working Tools for working in the hand, pneumatic, other than rotary type, suitable for metal working

13 Page Parts of chainsaws Hand-held blow torches Cash Registers Optical scanners and magnetic ink recognition devices not entered with the rest of a ADP system ADP storage units other than magnetic disk, not in cabinets for placing on a table, etc., not entered with the rest of a system Industrial robots, not elsewhere specified or included Pressure-reducing valves for pipes, boiler shells, tanks, vats or the like Valves for oleohydraulic or pneumatic transmissions Check valves other than of copper or iron or steel for pipes, boiler shells, tanks, vat, or the like Electric generating sets with compression-ignition internal-combustion piston engines, of an output not exceeding 75 kva Flexible permanent magnets, other than of metal Electromagnetic or permanent magnet work holders and parts thereof Silver oxide primary cells and primary batteries having an external volume not exceeding 300 cubic em Silver oxide primary cells and primary batteries having an external volume exceeding 300 cubic em Lithium primary cells and primary batteries Air-zinc primary cells and primary batteries Parts of primary cells and primary batteries Nickel-cadmium storage batteries, other than of a kind used as the primary source of power for electric vehicles Parts of lead-acid storage batteries, including separators therefor Parts of storage batteries, including separators therefor, other than parts of lead-acid storage batteries Electric soldering irons and guns Electric machines and apparatus for resistance welding of metal, fully or partly automatic

14 Page Electric machines and apparatus for resistance welding of metal, other than fully or partly automatic Electric machines and apparatus for arc (including plasma arc) welding of metals, other than fully or partly automatic Unrecorded magnetic media Recorded optical media, nesoi Transmission apparatus for radiobroadcasting Transceivers Radio remote control apparatus other than for video game consoles Radio receivers, NESOI Incomplete or unfinished color video monitors, presented w/o a display device, incorpo VCR or player Incomplete or unfinished color video monitors, presented w/o a display device, not incorpo VCR or player Color video monitors w/flat panel screen, video display diagonal n/ov em, not incorporate VCR or player Non-high definition color video monitors, nonprojection, w/crt, video display diago ov em but n/ov em, not incorpo VCR or player Non-high definition color video monitors, nonprojection type, w/crt, video display diagonal over em, not incorporating VCR or player Non-high definition color video monitors, projection type, with cathode-ray tube, not incorporating VCR or player High definition color video monitors, non projection type, with cathode-ray tube, not incorporating VCR or player High definition color video monitors, projection type, with cathode-ray tube, incorporating VCR or player High definition color video monitors, projection type, with cathode-ray tube, not incorporating VCR or player Color video monitors w/flat panel screen, video display diagonal em, incorporating VCR or player, not subject US note 13 Color video monitors w/flat panel screen, video display diagonal n/ov em, not incorporate VCR or player

15 Page Color video monitors w/flat panel screen, video display diagonal em, not with VCR/player, not subj US note 13 Color video monitors nesoi, with video display diagonal not over em, not incorporating VCR or player Black and white or other monochrome video monitors, oth Reception apparatus for television, not designed to incorporate a video display or screen, incorporating video recording or reproducing appa TV reception printed circuit assemblies incorporating a tuner, of a kind used with ADP machines of heading 8471, nesoi Incomplete or unfinished color tv reception apparatus, presented w/o a display device, n/incorp. VCR or player Non-high def. color television reception app., nonprojection, w/crt, display diag. ov em but n/ov em, incorp. VCR or player Non-high definition color television reception apparatus, non projection, w/crt, video display diag. ov em, not incorp. a VCR or player High definition color television reception apparatus, nonprojection, with cathode-ray tube, not incorporating a VCR or player High definition color television reception apparatus, projection type, with cathode-ray tube, incorporating a VCR or player High definition color television reception apparatus, projection type, with cathode-ray tube, not incorporating a VCR or playe Color television reception apparatus w/flat panel screen, video display diagonal n/ov em, incorporating a VCR or player Color television reception apparatus w/flat panel screen, video display diagonal over em, incorporating a VCR or player Color television reception apparatus nesoi, video display diagonal over em, incorporating a VCR or player Color television reception apparatus nesoi, video display diagonal over em, not incorporating a VCR or player, nesoi Fuses, for a voltage not exceeding 1,000 V Fuses, for voltage not exceeding 1,000 V Switches nesoi, for switching or making connections to or in electrical circuits, for a voltage not exceeding 1,000 V

16 Page Electrical terminals, electrical splicers and electrical couplings, wafer probers, for a voltage not exceeding 1,000 V Electrical terminals, electrical splicers and couplings, wafer probers, voltage not exceeding 1,000 V Battery clamps used in motor vehicles of headings 8702, 8703, 8704, or Electrical filament lamps nesi, designed for a voltage not exceeding 100 V, excluding ultraviolet and infrared lamps Light-emitting diodes (LED's) Insulated ignition wiring sets and other wiring sets of a kind used in vehicles, aircraft or ships Insulated electric conductors nesi, not of copper, for a voltage not exceeding 1,000 V, not fitted with connectors Insulated electric conductors nesi, for a voltage exceeding 1,000 V, fitted with connectors Optical fiber cables made up of individually sheathed fibers Golf carts and similar motor vehicles Motorcycles (incl. mopeds) and cycles, fitted w/recip. internal-combustion piston engine w/capacity o/50 but n/o 250 cc Motorcycles (incl. mopeds) and cycles, fitted w/recip. internal-combustion piston engine w/capacity o/250 but n/o 500 cc Floating structures nesoi (for example, rafts, other than inflatable rafts, tanks, cofferdams, landing stages, buoys and beacons) Lasers, other than laser diodes Surveying, hydrographic, oceanographic, hydrological, or geophysical instruments and appliances, nonoptical Catheters, cannulae and the like nesi, used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof Hygrometers and psychrometers, non-electrical, non-recording Combinations of thermometers, barometers, and similar temperature and atmosphere measuring and recording instruments, non-electrical Instruments and apparatus, other than electrical, for measuring or checking the pressure of liquids or gases Instruments and apparatus, other than electrical, for measuring or checking the pressure of liquids or gases

17 Page Other instruments and apparatus, nesi, for measuring or checking electrical voltage, current, resistance or power, without a recording device Other optical measuring or checking instruments, appliances and machines, nesoi Measuring and checking instruments, appliances and machines, nesoi Automatic thermostats Parts and accessories for articles of headings 9301 to 9304, nesoi Parts of seats (o/than of 9402) nesoi, of cane, osier, bamboo or similar materials