September 6, 2018
ESA Comments on USTR Sec 301 Proposed Tariffs on Batteries and Inverters from China
The Energy Storage Association (“ESA”) submitted a comment requesting the removal of static converters (HTSUS 8504.40.95), which includes inverters, and certain batteries (HTSUS 8507.20.80) from the Section 301 China import product list proposed for 25% tariffs. ESA argues that the 25% tariffs proposed for inverters included under tariff provision HTSUS 8504.40.95 would raise undue uncertainty and costs for inverter-based resources on the electric system, which include all battery storage facilities regardless of chemistry. ESA also argues that the 25% tariffs proposed for batteries included under tariff provision HTSUS 8507.20.80 have the effect of distorting optimal battery technology choices in electric grid applications. Additionally, given that the proposed tariffs have no termination date, innovative companies seeking to commercialize newer forms of battery technologies for electric grid functions will face greater uncertainty and ultimately lead to reduced investment and hiring in these domains.