Wine & Spirits colleagues and friends, amid the global Covid-19 pandemic and the United States’ epidemic of racism, we have not forgotten to keep our ears to the ground and our eyes on the prize when it comes to U.S. tariffs on imported wine. The 25% percent tariffs instituted in October 2019, still remain. Small, family-owned, businesses have been paying these tariffs ever since. On June 23, 2020, the Office of the U.S. Trade Representative (USTR) published the awaited Federal Register Notice announcing the review of action on the WTO / Airbus tariff list. The comment portal will be opened June 26 and will close on July 26. USTR should publish the results of this review on August 12. Unfortunately, wine tariffs could increase and also expand to include wines from more European Union countries. Here is an Excerpt from the Federal Register Notice listing only Annex I (currently tariffed items) and Annex II (proposed items) that pertain only to wine.
Our goal, at Circo Vino, in partnership with the U.S. Wine Trade Alliance, is to ask the USTR to “carousel-off” the current tariffs on imported wine and remove from consideration the wine products introduced during December, 2019 in Annex II of tariff decision.
You may recall from the several special reports that we previously sent out, the USTR has allowed for public comment on this exact tariff list before. On account of the Trade and Development Act of 2000, the USTR is required to periodically examine and revise products on the tariff list. The last public comment period ended mid-January, 2020 and due, in large part, to mobilization from the Wine & Spirits Industry, over 20,000 public comments were posted to the USTR’s public comment portal. Due to the volume of comments, the USTR has resolved to make new, public, comments on the August 12 carousel more difficult to submit, threatening to make it an hours long process, yet, we must not let our voices be subdued by the machinations of bureaucracy. Circo Vino and the USWTA will be here to guide you.
The USWTA will help coordinate email campaigns to consumers and others around the country, but it is critical that the USTR hear from affected businesses. A well-written letter from a business is one of the most valuable pieces of communication in our war chest. While form letters can be helpful, there is no substitute for telling your individual story, and communicating personally to the USTR how tariffs are negatively impacting you, your employees, and your businesses. Other members of the wine trade can relay these messages from a range of perspectives. I will follow up with more guidance shortly, but I urge every member of the wine trade to prepare remarks for submission to the USTR. – Ben Aneff, President of the USWTA
Here are the questions for which USTR is seeking answers through the public comment process:
USTR invites interested persons to address:
[1.] Whether maintaining or imposing additional duties on a specific product of one or more current or former EU member States would be appropriate to enforce U.S. WTO rights or to obtain the elimination of the EU’s WTO-inconsistent measures, and/or would likely result in the implementation of the DSB recommendations in the Large Civil Aircraft dispute or in achieving a mutually satisfactory solution.
[2.] Whether maintaining or imposing additional duties on specific products of one or more current or former EU member States would cause disproportionate economic harm to U.S. interests, including small or medium-size businesses and consumers.
The new USTR comment portal is different and a little more complicated than the portal we used in January. In addition to leaving comments and/or leaving a personal letter, you can also fill out a product detail questionnaire. The specific products detailed in the questionnaire can be found in our excerpt above. The questionnaire is optional.
As you write your letter, please consider adding the following:
- Ask the USTR to carousel off the current tariffs on imported wine, and remove from consideration the wine products on Annex II.
- Tariffs on wine do more damage to businesses in the U.S. than they do their targets in the EU.
- Tell the USTR about where your company or job sits within the three-tier supply chain and how wine tariffs effect your tier yet also have cascading effects in other tiers of the industry.
- Your own personal stories can help expand on the real-life damage these tariffs do to U.S. businesses, and on the small-business nature of the U.S. wine industry. TELL YOUR STORY.
- Tariffs on wine are an extremely ineffective lever in influencing the behavior of the EU with respect to Airbus, or any other matter.
- There are range of products at the USTR’s disposal that would both be more effective at influencing the EU, and less damaging to businesses here at home.