IN Brief:
- USTR is considering additional tariffs of 10% or 12.5% on goods from 60 trading partners.
- More than 1,500 stakeholders have requested further exemptions for products and industrial inputs.
- Companies cite insufficient domestic capacity, specialist specifications, qualification requirements, and climatic limits on food production.
Ford Motor Company, Nestlé, and other manufacturers and retailers are seeking additional exemptions from proposed US tariffs covering goods imported from 60 trading partners.
The Office of the United States Trade Representative has been holding hearings on measures developed through Section 301 investigations. The proposals include additional duties of 10% or 12.5% linked to allegations that trading partners have not effectively prevented products made with forced labour from entering their markets.
More than 1,500 stakeholders submitted written responses before the hearings, requesting protection for products ranging from industrial machinery and automotive inputs to food ingredients, water-filtration equipment, household goods, toys, and seasonal merchandise.
USTR has already proposed exclusions for selected categories, including qualifying trade under the United States–Mexico–Canada Agreement and goods subject to certain existing Section 232 measures. Businesses are pressing for the exemption lists to be widened before final decisions are made.
Food manufacturers have concentrated on ingredients that cannot be produced domestically in adequate volumes because of climate, geography, or agricultural capacity. Mars has requested protection for palm oil, while McCormick has sought exemptions covering numerous spices and herbs used within US food manufacturing.
Nestlé and other food producers have raised the broader difficulty of substituting imported ingredients without altering recipes, processing performance, quality, availability, or cost. A different origin can require technical assessment, supplier qualification, allergen review, packaging changes, and revised customer documentation before it enters production.
Industrial requests cover specialised motors, compressors, electronic controls, semiconductors, wire harnesses, moulds, automation equipment, injection-moulding machinery, and other capital goods. GE Appliances has argued that tariffs on equipment used inside US factories would divert investment from production capacity and employment.
Automotive manufacturers are seeking additional protection for inputs connected with advanced technology, batteries, and electric vehicles. Domestic production is expanding, yet selected components and materials remain unavailable at the scale, quality, or price required to sustain current assembly programmes.
A supplier capable of producing a component is not automatically capable of replacing national import demand. Available tooling, certification, engineering tolerances, intellectual property, raw-material access, and production capacity all determine whether an apparently domestic alternative can enter a manufacturer’s bill of materials.
Qualification periods can extend for months or years in automotive, food, medical, electrical, and safety-critical applications. Changing supplier may require testing, customer approval, regulatory submissions, line trials, warranty assessment, and inventory run-down before the replacement becomes commercially usable.
Tariffs imposed during that transition leave importers with limited immediate choices. They can absorb the duty, pass it through to customers, reduce margins elsewhere, delay production, or carry larger stocks while alternative sources are developed.
The consultation has parallels beyond the United States because tariff policy now reaches deep into manufacturing supply chains. The Manufacturing Technologies Association has warned that further duties could weaken British equipment exporters already facing energy, tax, and skills pressures, as detailed in its assessment of tariff exposure across UK manufacturing technology.
Steel users face a similar imbalance when raw materials attract duties but finished imported equipment does not carry an equivalent burden. Thorworld Industries has argued that such a structure can raise costs for domestic manufacturers while improving the relative position of overseas finished goods, a concern explored in the company’s intervention on steel tariffs and downstream production.
Even successful exemptions create additional compliance work. Importers must classify products accurately, demonstrate that the goods meet the exclusion terms, retain origin and supplier evidence, and monitor changes to customs codes, country coverage, and implementation dates.
Larger companies can assign specialist trade teams to that process, whereas smaller manufacturers may depend on brokers and external advisers. Uneven access to compliance resources can leave smaller businesses paying duties that a larger competitor is better equipped to challenge or avoid.
The proposed measures will also influence sourcing strategies beyond the products receiving immediate exemptions. Dual sourcing, regional production, larger safety stocks, and earlier customs review can reduce exposure, although each adds cost, working capital, and supplier-management complexity.
The decisive policy question is whether a tariff can stimulate domestic production within a commercially useful period. Where factories, raw materials, tooling, skills, or certification do not exist, the duty raises the cost of US manufacturing before it creates any credible substitute supply.
USTR’s final scope will determine whether the exemption process protects those constrained inputs or leaves manufacturers carrying another layer of cost and uncertainty. Procurement plans built around stable origin and duty assumptions are increasingly giving way to product-level customs analysis before a purchase order is placed.
