On April 3, 2018, the United States Trade Representative (“USTR”) published a proposed list of imported products that it intends to subject to an additional 25% tariff if those products originate from China. The proposed action is the outgrowth of the USTR’s investigation into China’s treatment of foreign intellectual property and the Chinese requirement that U.S. investor companies transfer their intellectual property and trade secrets to Chinese companies in return for market access.

While eyeglasses, optical frames, lenses, plano sunglasses, reading glasses and parts of these medical devices are not on the proposed list, certain optical manufacturing machines, ophthalmic instruments and electro-diagnostic equipment, however, are included on the proposed list. This includes lensmeters, tonometers, ophthalmometers, slit lamp microscopes, retinal cameras and optical lens grinding and polishing machinery. Other products may also be implicated. A copy of the complete list can be found here.

The list is subject to a public comment process and a hearing. All hearing appearance requests must be filed by April 23, 2018, and all written comments must be submitted by May 11, 2018.

The Vision Council advises, “Those who import these Chinese-origin devices should immediately determine whether their products are covered by the proposed tariff and consider your options.” For more information, contact Rick Van Arnam, The Vision Council regulatory counsel, at


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