The existing Section 122 tariffs that had assessed a 10% duty on imports expired Friday, July 24, resulting in the Trump Administration imposing new tariffs under Section 301 of the Trade Act of 1974 for 60 economies over alleged forced-labor violations. The affected countries include many of the optical industry’s largest sourcing markets.
The Office of the United States Trade Representative (USTR) has issued country-specific duty determinations that will affect optical imports.
“This latest round of Section 301 duties adds another layer of complexity for members of the optical industry already navigating a shifting tariff landscape,” said Rick Van Arnam, Regulatory Affairs Counsel for The Vision Council. “We are working to help members understand exactly which rates apply to their imports and where exemptions may be available.”
NEW SECTION 301 DUTY RATES BY COUNTRY
The new duties are tiered by country, affecting several countries that are critical to the optical supply chain. China, Vietnam, Thailand and Cambodia — all significant sources of frames, sunglasses and lens components — now face a new 12.5% duty on top of existing rates. India and Indonesia face a 10% duty. The European Union and Japan receive more favorable capped treatment.
A full list of country-specific rates is below, and members of The Vision Council can model the cost impact for their own product mix using The Vision Council’s Tariff Dashboard.
- 10% duty: Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Sri Lanka, Trinidad and Tobago and the United Kingdom
- Capped at 10% combined with existing duty rates: European Union and Taiwan
- Capped at 12.5% combined with existing duty rates: Japan, South Korea and Switzerland
- 12.5% duty: Algeria, Angola, Australia, Bahamas, Bahrain, Brazil, Chile, China, Colombia, Costa Rica, Dominican Republic, Egypt, Guyana, Hong Kong, Iraq, Israel, Kazakhstan, Kuwait, Libya, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, Thailand, Turkiye, United Arab Emirates, Uruguay, Venezuela and Vietnam
Countries not identified in USTR’s determinations are not subject to the new Section 301 duties.
EXEMPTIONS AND TRANSITION PROVISIONS
- A narrow in-transit exception applies to goods loaded on their final vessel by 12:01 a.m. EDT on July 24 and arriving by July 28.
- The new duty does not stack with Section 232 tariffs, and goods qualifying as Canadian or Mexican origin under USMCA remain exempt.
- Certain Harmonized Tariff Schedule (HTS) codes are exempt, largely covering products that cannot be sourced in the U.S. None of the traditional HTS codes associated with eyewear products qualify for this exemption.
- The UK, EU, and Switzerland have additional exemptions, but none are expected to affect eyewear.
CHINA TARIFFS STACKING
USTR’s announcement of the new 12.5% forced-labor Section 301 duty on Chinese-origin goods does not state that it supersedes the existing Section 301 tariff already in place on most Chinese-origin merchandise — 7.5% for some products, including eyewear, and 25% for others. As such, The Vision Council advises members to plan for the two Section 301 duties to stack.
ADDITIONAL TARIFF ACTIONS AFFECTING THE OPTICAL INDUSTRY
A separate 25% Section 301 duty took effect July 22 on certain Brazilian goods. The Vision Council has determined that optical products, as well as equipment typically used to produce optical products, will be subject to this additional tariff when of Brazilian origin.
A proposed 50% penalty on certain Canadian goods has not yet taken effect and will not be enforced for at least another month, leaving room for negotiation. The Vision Council has not identified any optical products currently on the affected list but will continue to monitor developments.
The USTR is also investigating structural excess capacity in more than a dozen nations, which is expected to result in a second round of Section 301 tariff announcements. The Vision Council will provide an update once further details are available.
“Between these latest 301 tariffs, the stacking China tariffs, the Brazil and Canada actions, and the excess-capacity investigation, there’s a lot in motion at once,” said Omar Elkhatib, Director of Government Relations at The Vision Council. “Our Government and Regulatory Affairs team is closely tracking these developments, and we’re prioritizing the pieces most likely to affect optical imports. We will keep members informed as we receive more clarifying information from USTR.”
RESOURCES
The Vision Council offers a suite of resources to help members respond to the ongoing impacts of trade and tariff policy.
- Latest Tariff Developments: Ongoing updates on policies and actions affecting the optical industry.
- Tariff Dashboard: A simulator available to members of The Vision Council that models the financial implications of tariffs on imports.
- Industry Resources & Guidance: Country-specific duty explanations, archived webinar recordings and more.
