Apple’s letter to the U.S. Trade Representative

Two million jobs in 50 states, investments worth $350 billion, billions more in taxes paid.

June 17, 2019

The Honorable Robert Lighthizer
United States Trade Representative
600 17th Street NW
Washington, DC 20508

Re: Docket Number USTR-2019-0004 — Comments Concerning Proposed Modification of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation

Thank you for this opportunity to comment on USTR’s proposal to impose tariffs up to twenty-five percent duty on a fourth set of products imported from China.

The proposed tariff list covers all of Apple’s major products, including iPhone, iPad, Mac, AirPods, and AppleTV, as well as the parts and batteries used to repair products in the United States. The proposed tariffs also cover accessories that Apple makes for these devices, such as monitors and keyboards. A list of the proposed tariff codes that cover Apple’s products is attached at Annex A. We urge the U.S. Government not to impose tariffs on these products.

Apple’s Economic Contribution

Apple is a proud U.S. company and one of the largest job creators in the United States. We are responsible for over 2 million jobs across all 50 states, including Apple’s direct employees, employees at our manufacturing and retail partners, and Americans who make their living in the vibrant and growing app economy.

In 2018, after the passage of tax reform in the U.S., we announced our intention to make a total direct contribution to the U.S. economy of over $350 billion over 5 years and we are pleased to report that we are on track to achieve this contribution. We are opening several new sites and adding new jobs to our U.S. employee base.

Apple is also the largest U.S. corporate taxpayer to the U.S. Treasury and pays billions more each year in local property, sales, and employee taxes.

Finally, Apple’s products are used by American families, students, businesses, government agencies, schools, and hospitals to communicate, teach, improve health outcomes, and enhance creativity and enterprise.

The Impact of Tariffs

U.S. tariffs on Apple’s products would result in a reduction of Apple’s U.S. economic contribution.

U.S. tariffs would also weigh on Apple’s global competitiveness. The Chinese producers we compete with in global markets do not have a significant presence in the U.S. market, and so would not be impacted by U.S. tariffs.1 Neither would our other major non-U.S. competitors.2 A U.S. tariff would, therefore, tilt the playing field in favor of our global competitors.


We urge you not to proceed with these tariffs. Thank you for your consideration of our comments.

apple letter trade representative

My take: Firm. Polite. Unsigned. Wish I could see what’s in Annex B.


  1. Gregg Thurman said:
    Washington isn’t going to listen, and for good reason: China’s “trade” activities are negatively impacting the whole of the US economy via IP theft or forced IP transfers. These acts not only weaken the US’s ability to compete globally, they also weaken our military.

    I would rather put up with a short term hardship now, than a much longer hardship later when we can’t be assured of military superiority and our economy has been weakened by China selling our IP back to us for less.

    Make no mistake about it Xi Jinping is a dictator with global conquest ambitions. He had the Chinese Constitution rewritten in 2018 so that he would remain Paramount Leader of China indefinitely. As such he is the leader of China with no checks or balances. He answers to no one. Chinese friends of mine (from the days I maintain offices in Beijing and Chengdu) tell me that the populace refers to the National People’s Congress as the “rubber stamp” congress. Xi proposed a law and the Congress approves it. There is no debate. It’s as though Mao has risen from the dead (he and Xi are the only leaders authorized to serve more than two terms. Li is a strong nationalist and has reorganized (through purges of opposition) the Chinese government, consolidating power in the Paramount Leader’s office.

    This is not a man that is going to negotiate because he’s is willing to compromise. There is no compromise in his leadership. As coarse as Trump may be he’s probably the best person to take Li on, and win.

    June 20, 2019
  2. Fred Stein said:
    Jeff: Just saw your comment re Iran. Agree as well. On the surface one would say Iran is nuts to provoke us. Russia in nuts to play chicken on the high seas. But then one has to ask, can we escalate a war half way across the globe. We have a lot of forward deployed military and commercial assets. And having broken treaties and agreements, it’s tough to get allies to join forces with a leader proudly declares himself “unpredictable”.

    June 21, 2019
  3. Gregg Thurman said:
    “Meanwhile, we’re losing farms to the disastrous trade policy, ”

    Why is it that people argue disaster for our farming industry when it employs less than 2% of our total workforce, and completely ignore the impact of China’s IP theft and forced IP transfers on our tech industry that employs far, far more than the farming industry (over 500,000 tech jobs are unfilled as of today).

    Our farms’ exist because of federal subsidies. Without them, Iowa, Nebraska, North/South Dakota, Oklahoma, Montana, Kansas, and California farms return to native lands, and we end up buying cheaper foodstuffs from overseas.

    Without our tech industry, even if much (most?) of the products are manufactured in Asia the US economy shrinks like a dried out prune.

    The future of the US economy is not farming, it is tech.

    June 21, 2019

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