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USTRNonrulemakingUSTR-2018-0005

Notice of Determination and Request for Public Comment Concerning Proposed Determination of Action Pursuant to Section 301

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Advanced Medical Technology Association filings
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Advanced Medical Technology Association filed 2 comments on this docket between Apr 25, 2018 and Apr 26, 2018. 263 other organizations filed here. The comment window closed 2989d ago.

What Advanced Medical Technology Association filed (2)

Apr 26, 2018· Comment from Ralph Ives, Advanced Medical Technology Association· USTR-2018-0005-0312

SUMMARY OF KEY ELEMENTS OF TESTIMONY OF THE ADVANCED MEDICAL TECHNOLOGY ASSOCIATION BY RALPH F. IVES BEFORE THE COMMITTEE ON SECTION 301 UNITED STATES TRADE REPRESENTATIVE MAY 15, 2018 The Advanced Medical Technology Association (AdvaMed), with headquarters in Washington DC, represents about 350 manufacturers of the full range of medical technology cardiovascular and orthopedic implants, in vitro diagnostics, surgical devices, and medical imaging and radiation therapy equipment that improve and save patients lives around the world. While AdvaMed represents large well-known manufacturers, about 75 percent of our members are small and medium size enterprises (SMEs). We have 9,800 manufacturing facilities spread throughout the 50 states and are responsible for 2 million high-paying jobs. AdvaMed shares the Administrations opposition to Chinese policies that serve to discriminate against US firms. We are concerned that the goals of the Made in China: 2025 policy could lead to additional or strengthened discriminatory practices. However, we believe the Action Plan we developed, in consultation with key US Government agencies, to address our industrys specific issues should be the basis for the Administrations engagement in China on medical technology. We do not endorse using USTRs proposed tariff increases on products affecting our industry but urge negotiations based on our Action Plan. We ask that HTS codes for medical technology products and components be removed from USTRs final list of products that would be subjected to an additional 25 percent tariff because: our industry was not included in the Section 301 investigation or report; our industry did not participate in the Section 301 process, for reasons we will describe in our formal written submission; a large share of the imports on the list are components, which are used by US medical technology manufacturers to make products that are competitive in a global market; the medical technology products on the USTR list account for over half of all medical technology imports from China; our industry enjoys a nearly balanced trade relationship with China; USTRs tariff increases would disproportionately impact US companies, the worlds leaders in medical technology undermining our ability to compete against China; US tariffs would leave the highly regulated medical technology industry particularly vulnerable to Chinese retaliation using tariffs and nontariff measures; US trade retaliation and sanctions measures historically have not included medical products due to humanitarian reasons.

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Apr 25, 2018· Comment from Ralph Ives, Advanced Medical Technology Association· USTR-2018-0005-0258

SUMMARY OF KEY ELEMENTS OF TESTIMONY OF THE ADVANCED MEDICAL TECHNOLOGY ASSOCIATION BEFORE THE COMMITTEE ON SECTION 301 UNITED STATES TRADE REPRESENTATIVE MAY 15, 2018 The Advanced Medical Technology Association (AdvaMed), with headquarters in Washington DC, represents about 350 manufacturers of the full range of medical technology cardiovascular and orthopedic implants, in vitro diagnostics, surgical devices, and medical imaging and radiation therapy equipment that improve and save patients lives around the world. While AdvaMed represents large well-known manufacturers, about 75 percent of our members are small and medium size enterprises (SMEs). We have 9,800 manufacturing facilities spread throughout the 50 states and are responsible for 2 million high-paying jobs. AdvaMed shares the Administrations opposition to Chinese policies that serve to discriminate against US firms. We are concerned that the goals of the Made in China: 2025 policy could lead to additional or strengthened discriminatory practices. However, we believe the Action Plan we developed, in consultation with key US Government agencies, to address our industrys specific issues should be the basis for the Administrations engagement in China on medical technology. We do not endorse using USTRs proposed tariff increases on products affecting our industry but urge negotiations based on our Action Plan. We ask that HTS codes for medical technology products and components be removed from USTRs final list of products that would be subjected to an additional 25 percent tariff because: our industry was not included in the Section 301 investigation or report; our industry did not participate in the Section 301 process, for reasons we will describe in our formal written submission; a large share of the imports on the list are components, which are used by US medical technology manufacturers to make products that are competitive in a global market; the medical technology products on the USTR list account for over half of all medical technology imports from China; our industry enjoys a nearly balanced trade relationship with China; USTRs tariff increases would disproportionately impact US companies, the worlds leaders in medical technology undermining our ability to compete against China; US tariffs would leave the highly regulated medical technology industry particularly vulnerable to Chinese retaliation using tariffs and nontariff measures; US trade retaliation and sanctions measures historically have not included medical products due to humanitarian reasons.

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Abstract

Lead Attorney: Arthur Tsao

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Co-filers (263)

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