The American Mold Builders Association filed formal comments with the Office of the U.S. Trade Representative on Nov. 29, asking it to bring back the 25 percent tariff on Chinese injection molds.
AMBA also asked USTR to reject a proposal to extend the exclusion for another year.
Importers and manufacturers had until Nov. 30 to register their support or opposition for extending the suspension the 25 percent China mold tariff or reinstating the levy.
AMBA said that more than 150 U.S. mold builders have filed comments opposing an extension of the tariff suspension and demonstrating that sufficient production capacity exists in the United States to meet the demand from importers.
On Dec. 28 last year, the U.S. government unexpectedly put a hold on the tariff on Chinese molds, which had been enacted in mid-2018 as part of the first round of $34 billion in duties on Chinese imports. The government suspended the tariff after hearing from processors, including some big automotive molders, who argued that the 25 percent tariffs would be difficult for them to absorb, causing major problems in their already price-sensitive markets.
The mold tariff was suspended for at least one year, but it can be extended beyond that period.
Some of the plastics processors said higher mold costs that would result from the 25 percent tariff would make their U.S. manufacturing operations less competitive and would cause job losses. The processors had also claimed the U.S. mold sector does not have enough capacity and lead times were being stretched out for U.S.-made molds. China could make molds quicker, the processors claimed.
"AMBA members report they have the capacity, capabilities, and willingness to meet current and future mold building demand," said Kym Conis, AMBA managing director, wrote in a letter to U.S. Trade Representative Robert Lighthizer.
The letter follows AMBA's announcement Nov. 7 that it hired a Washington lobbying group, The Franklin Partnership, to push its case to the White House, Congress and policymakers. AMBA is giving out more details about the industry as it tries to bring back the China mold tariffs.
To counter the lack-of-supply argument presented by some importers, AMBA demonstrated to the government that the United States has 1,439 mold building establishments and has nearly $500 million in open mold building capacity.
"Mold capacity utilization rate in the U.S. is currently around 75 percent, putting American companies in a strong position to meet current and future domestic demands," Conis said.
Those mold makers, with more than $6.4 billion in annual sales, employ 35,000 Americans earning an average annual salary of $56,203, the Indianapolis-based trade association said
AMBA said U.S. mold makers can match China delivery times while exceeding quality. U.S. molds also are critical to national and economic security, AMBA argued.
"We believe the sheer number of mold manufacturing establishments in the U.S. clearly counters any arguments made by those requesting an exclusion extension that no domestic alternative to Chinese mold imports exist," Conis said.
Another point made by Conis: Molds also are available from other countries, with Canada as the largest importer.
The formal submission to the trade office mentioned a survey by Harbour Results, Inc. that showed that 60 percent of mold builders reported losing more business in 2019 to low-cost countries compared to previous years.
Conis said AMBA understands the challenges seeking reforms in China "and applaud USTR for working to address these issues long overlooked by previous administrations," Conis said in the letter. "However, we remain concerned too many (import exclusion) requesters are using price as their primary motivation for requesting a 301 tariff exclusion extension and have not made significant efforts to identify U.S. or third-country alternatives, which are readily available."
