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