The Honorable Robert Lighthizer

United States Trade Representative

600 17th St. NW
Washington, DC 20006

October 15, 2019

Dear Ambassador Lighthizer:

We the undersigned organizations and businesses write in response to the “Notice of

Determination and Action Pursuant to Section 301: Enforcement of U.S. WTO Rights in Large
Civil Aircraft Dispute” published October 9, 2019. We will be directly impacted by the October
2 decision of the United States to impose 25 percent tariffs on European Union products as
retaliation for EU subsidies in the Large Commercial Aircraft decision by the World Trade
Organization (WTO). We recognize the right of the United States under the WTO agreements to
implement the WTO Arbitrator’s award announced on October 2, 2019, but ask that you take
appropriate technical steps to minimize the impact of the tariffs on American buyers of affected
products.

By imposing tariffs beginning October 18, 2019, the United States will be exacting new and
unplanned costs on goods that were shipped from subject countries prior to October 2 but which
will arrive at U.S. ports after the tariffs take effect. These new duties will not be borne by the EU
producer or manufacturer of those now-dutiable goods, but by the American importers which
have already purchased the products and, very quickly, by American consumers. Nearly every
product impacted by these tariffs transits to the United States from Europe by sea. In order to
arrive in Washington State or Alaska before October 18, shipments of these products would have
had to depart Europe in the first half of September or earlier.

To prevent the cost of the tariffs from falling entirely on American businesses and consumers,
we ask that all goods exported from Europe October 2 or earlier be exempt from tariffs. USTR
made a similar accommodation on May 31, 2019, for goods impacted by List 3 tariffs on China,
extending the deadline for entry from June 1 to June 15 for goods exported from China before
May 10, the day the List 3 tariffs were announced. This was an appropriate technical
accommodation. We ask for its use again in this case.

Thank you for consideration of this request. We look forward to working with you to make
appropriate technical accommodations that address our pressing concern.

Sincerely,

American Cheese Society Association of Food Industries

American Craft Spirits Association
American Distilled Spirits Association
(ADSA)
Associated Equipment Distributors
Association of Equipment Manufacturers
Cheese Importers Association of America
Distilled Spirits Council of the United States
National Association of Beverage Importers
National Coffee Association, USA
National Council of Chain Restaurants
National Restaurant Association Retail Industry Leaders Association
National Retail Federation Specialty Food Association
North American Olive Oil Association

A. V. Olsson Trading Co., Inc. Coffee By Design

Old Greenwich, CT Portland, ME

Acesur North America culinarycollective

Purchase, NY Lynnwood, WA

Acme Food Sales, Inc. DFI Organics Inc.

Seattle, WA Webster, TX

Acme Import Co. Di Bruno Bros.

New York, NY Philadelphia, PA

Agro Sevilla - U.S.A., Inc. D'Olivo

Herndon, VA Wenatchee, WA

Agrusa, Inc. Epiros USA LLC

Totowa, NJ Bonita Springs, FL

Arguimbau Company Euro-American Brands, LLC

Greenwich, CT Paramus, NJ

Babcock & Miles FOODMatch, Inc.

Red Lodge, MT New York, NY

Bella Italia Inc. Forever Cheese Inc.

Las Vegas, NV Long Island City, NY

Borges USA Fortune Fish & Gourmet

Fresno, CA Bensenville, IL

British Wholesale Imports Fresca Italia Inc.

Westlake Village, CA Brisbane, CA

Carl Brandt, Inc. Gourmet International

Fairfield, CT Grand Rapids, MI

Certified Origins Inc. H.E.B.

Port Chester, NY San Antonio, TX

City Olive ItalFoods Inc.

Chicago, IL South San Francisco, CA
ITP Sourcing LLC Olive Oil & Beyond Inc.
Boca Raton, FL Newport Beach, CA

Jack Foods Pastene Companies, Ltd.

Fort Lee, NJ Canton, MA

Jophil Food Corp. Pondini, Inc.

Maspeth, NY Somerset, NJ

Jorday Foods REMA FOODS, INC

Hackensack, NJ Englewood Cliffs, NJ

Kaune’s Neighbor Market Rogers Collection

Santa Fe, NM Yarmouth, ME

Lamex Foods Schreiber Foods International, Inc.

Bloomington, MN Saddle River, NJ

Lesley Elizabeth Seacrest Foods

Lapeer, MI Lynn, MA

Loumidis Foods, Inc. Simple Girl LLC

Lyndhurst, NJ Ofallon, MO

Maestri d’Italia Inc. SOURCE ATLANTIQUE, INC

Lakewood, NJ Englewood Cliffs, NJ

Mamtakim Inc. Stevie’s Italian Foods, Inc.

Staten Island, NY Greenville, SC

Mario Camacho Foods Surdy’s, Inc.

Plant City, FL Minneapolis, MN

MCT Dairies, Inc. Taste

Chatham, NJ Virginia Beach, VA

Mesogeo Imports, Inc. Tekla, Inc.

Antioch, IL Chicago, IL

MJ Kellner Testa's Pantry

Springfield, IL Schenectady, NY

Monini North America,Inc. The Ambriola Company, Inc.

Shelton, CT Caldwell, NJ
The French Farm Voyage-Marché Inc.
Houston, TX Key Biscayne, FL

The Peterson Company Walkers Shortbread Inc.

Auburn, WA Hauppauge, NY

ThinkFood Group LLC Zelos Authentic Greek Artisan

Washington, DC Mason, OH

Vin Colorado Imports LLC Zingerman's Community of Businesses

Denver, CO Ann Arbor, MI