Dear Mr. President/The Honorable Ron Kirk.
This is from China Chamber of Commerce of Metals, Minerals&ChemicalsImporters&Exporters ("CCCMC") and China Rubber Industry Association("CRIA"), whorepresent Chinese tire producers and exporters. The U.S. InternationalTrade Commission ("ITC") held that Chinese tire imports created market disruption,and proposed a remedy of 55% to 35% special import duties on Chinese-made tires.
We regret that holding and believe that it lacks factual and objective basis.We have filed much evidence demonstrating that Chinese tire imports do notinjure the U.S. tire industry. The restriction of Chinese tires cannot solve any problemfaced by the U.S. tire industry, and further would hurt U.S. tire distributors andconsumers. We hope that as President /UST you will give prudent consideration anddecide against special safeguard measures.
1 .Firstly, Mr. President/Mr. Kirk, we respectfully request that you pay attentionto the fact that the petition raised by the United Steelworkers is only supported by lessthan half of the tire workers and no U.S. tire manufacturer has claimed (much less,itself documented) harm from Chinese tire imports. The U.S. Tire IndustryAssociation, which represents enterprises and workers in the manufacturing,wholesale, retail, after-sale services, retreading and recycling segments of the U.S. Tireindustry, has firmly opposed any special safeguard measure, as not helping to protect
U.S. manufacturing jobs and harmful to U.S. distributors and consumers. Respectedresearch institutes such as the U.S. think tank Cato Institute also state that anysafeguard measure would do more harm than good.
2. The facts also demonstrate that Chinese-made tires largely do not compete withU.S.-made tires in the U.S. Rather, they serve different market segments. Again,Chinese tire imports did not injure the U.S. tire industry. Specifically in this regard,
(a) The U.S.-made tires are largely sold to car manufacturers (OEMs) assembledin new cars and in the premium branded replacement market. In contrast, theChinese-made tires are mainly sold in a different market segment一i.e., the budget,no brand replacement tire market for U.S. consumers with severe budget constraints.Even before any significant Chinese entry into the U.S. market, U.S. Tiremanufacturers were in the process of abandoning this particular market segment inorder to concentrate on the more profitable segments where supply from U.S.production was viable. Again, the subject Chinese-made tires do not injure U.S.producers.
(b) Chinese tire imports to the U.S. have not experienced rapid growth of late.The subject Chinese tire imports into the U.S. only increased by 2.7 percentage pointsfrom 2007 to 2008 as a percent of U.S. consumption. And, in the first quarter of 2009,Chinese imports actually significantly dropped.
(c) Significantly, four major U.S. tire manufacturers said "No" to the ITCquestion "Have the involved Chinese tire imports been a reason for the substantialharm to the U.S. market?" and the other four said they could not answer the question.
3. Lastly, while there are 20, 000 tire manufacturing workers in the U.S., there areabout 200 U.S. tire distributors, 43,100 retailers engaged in sales of Chinese-madetires and about 100, 000 workers involved in tire import and sales. The compulsoryrestriction of Chinese tire imports would only force the enterprises to choose similarproducts from other countries. This would do nothing for the U.S. Manufacturingindustry but would bring adverse effect to U.S. consumers and the U.S. Carmanufacturing industry. If the import of Chinese-made tires is restricted, somedistributors and retailers could be in danger of losing their jobs or have to find a newposition. The consequences could be relatively serious.
Mr. President/Mr. Kirk, we look forward to your fair and final decision not toadopt the special safeguard measure.
Sincerely,
Xu Xu. Chairman
China Chamber of Commerce of Metals Minerals&Chemicals Importers&
Exporters
(China Chamber of Commerce of Metals Minerals&Chemicals Importers&
Exporters Tire Branch)
Fan Rende, Chairman
China Rubber Industry Association
(China Rubber Industry Association Tire branch.)