Tariffs Affecting the Mold Building Industry

Urgent - Submit Comments to Keep 25 Percent Tariffs on Chinese Molds, Tooling and Dies in Place!

The AMBA needs its members to contact Washington, D.C. one more time to keep in place the 25 percent tariffs on Chinese molds, tooling and dies.

This summer, AMBA members generated almost one-in-five of all comments filed with the U.S. Trade Representative (USTR) to retain tariffs on Chinese imports. USTR is conducting a full review RIGHT NOW to decide whether to keep tariffs on China or give importers a pass. To help keep the tariffs in place, U.S. mold manufacturers need to fill out a short questionnaire and answer ten questions

AMBA will file comprehensive comments filling out  ALL sections of the questionnaire, but is asking members to focus on filling out the fifth step, which is the most critical of the three areas. This section is titled in the progress bar at the top of the page and is titled, "C. Comments on Tariffs Headings."

When you begin, you will see several sections in the progress bar at the top of the page. The section you will be focused on addressing is the fifth page, and it is titled, "C. Comments on Tariff Headings." In order to advance to that step, follow the below instructions. 

  1. Click "Submit Comment" in the top right-hand corner of the screen.
  2. On the first screen, fill in the company’s information.
  3. On the second screen, review and advance past the Introduction section.
  4. On the third and fourth screens, answer "No" to each question and continue. If you answer yes to either, additional questions will appear below and you will need to answer them before you can advance.
  5. On the fifth screen, titled, "C. Comments on Tariff Headings," answer yes, indicate your position on specific HTS codes and include the HTS codes for applicable products (see link below for full list; plastic injection molds HTS is 8480.71.80. (Do not enter the periods in the HTS code - the form will not accept them.). 
  6. On the following question, select that the tariffs should “remain” in place (if this correlates with your position). 
  7. Answer the following questions, a-e. 
  8. Submit!

AMBA has included a link below to a PDF of Section C of the Questionnaire and a link to HTS codes for the industry that can be included in Question 18. To assist with filing, FIA is including a link to the main questions of interest for reference, and highlighted in red the critical questions along with a link to the list of Harmonized Tariff Codes from which you can select your product when answering Question 18.

This is a critical call to action for all AMBA members, please file your comments NOW. Feel free to answer any and all questions in support of efforts to keep the tariffs in place, but keep in mind USTR is posting the forms filed online for public review.

  • Click HERE to fill out the form (click the blue "Submit Comment" button)
  • Click HERE for the HTS code sample list
  • Click HERE for the "How-To" guide

History

In July 2018, the U.S. implemented a 25% tariff on $34 billion worth of Chinese imports, including molds and mold bases. This tariff was subsequently suspended at the end of December, a decision that is ultimately hurting U.S. mold builders as it is now significantly cheaper to source and build tools in China. This means that in the U.S., mold shops are forced to reduce their workforces and, in some cases, close their doors. 

The mold building industry is vital to the U.S. economy - molds are a critical part of tooling and tooling is essential for the manufacturing of all durable goods in the country. For this reason, the American Mold Builders Association has engaged with Washington, D.C.-based lobbying firm, The Franklin Partnership, to speak for the industry in the nation's capital and help policymakers make informed decisions about imposing tariffs on imported plastic injection molds from China. Together, these organizations will lobby the White House, Congress and policymakers to support U.S. manufacturers against low-cost imports from China. 

To visit AMBA's members-only tariff updates, resources and any current call-to-action, visit here.

China Mold Tariff Facts

On July 6, 2018, the U.S. government implemented a 25% tariff on $34 billion worth of Chinese imports (Tranche 1), including molds and mold bases. The tariff was subsequently suspended in December 2018. 

Why was the tariff lifted? The tariff was lifted because it was cited that there was a lack of U.S. mold shop capacity. This is inaccurate, as U.S. mold capacity in 2018 ranged from a high of 81% to a low of 77%, demonstrating that capacity is not the issue.

Key Issues 

Dumping - Chinese-owned shops sell molds to U.S. manufacturers up to 40% below the cost of molds produced in a domestic shop.

Progressive Payments - Most Chinese-owned shops receive progressive payment terms from U.S. manufacturers with 90% of the tooling cost paid prior to tool shipment. This compares sharply with the 55% of U.S.-based mold builders receiving progressive payments.

Intellectual Property Infringement - The mold is the science behind the part. By quoting molds in China, U.S. companies are sending detailed drawings of parts/products, creating an opportunity for IP infringement.

AMBA Mold Builder Call to Action

In November 2019, AMBA submitted a call-to-action for members of the mold manufacturing community to file comments, explaining why they were for or against the exclusion of tariffs on Chinse plastic injection molds. Subsequent announces and calls-to-action have led to the continued reinstatement of U.S. tariffs on Chinese molds, for the purpose of protecting the interests of the U.S. mold manufacturing industry. 

To see past and current messaging, documents to submit, press releases, publicity and more, visit this members-only page

Interested in having your voice heard regarding the tariff issue? Email info@amba.org or call the AMBA offices at 317.436.3102.