AMBA Files Comments Against Lifting Chinese Mold Tariffs

On May 7, the American Mold Builders Association (AMBA) filed formal comments with the Office of the U.S. Trade Representative (USTR) asking that it not lift Section 301 tariffs related to the COVID-19 pandemic for HTS 8480.71.8045, plastic injection molds imported from China.

“We believe the sheer number of mold manufacturing establishments in the U.S. clearly counters any arguments made by those requesting an exclusion that no domestic alternative to Chinese mold imports exists,” states AMBA Managing Director Kym Conis. To counter the lack of supply argument presented by some importers, AMBA demonstrated to the federal government that the U.S. has 1,439 mold building establishments; has nearly $500 million in open mold building capacity and has a current utilization rate of 68%.

The AMBA maintains a public member directory at https://amba.org/resources/directory, which identifies 138 U.S. mold building manufacturers listed as suppliers to the medical industry.

“Even prior to the pandemic, the American mold building industry had sufficient capacity to meet the demand needed to address pre- and post-coronavirus demand,” says Conis. “As an integral part of the medical device and PPE supply chains, mold builders across the country remain open and continue to produce the vital equipment and devices needed.”

In July 2018, the U.S. Government imposed a 25% tariff on imported plastic injection molds from China; however, granted a twelve-month exclusion from the tariffs for U.S. importers on December 28, 2018. In December 2019, USTR permitted the exclusion to expire, reinstating the 25% tariff on the molds, which appear on List 1.

American mold builders are committed to helping ensure that physicians and other health professionals on the front lines have the PPE and medical devices and equipment needed in the battle against COVID-19. The AMBA looks forward to working with the Trump administration to strengthen manufacturing in the U.S. and to ensuring American mold builders continue to provide thousands of jobs across this country - supplying plastic injection molds for decades to come.