NAACC | Vehicles

The National Association of Automobile Clubs of Canada
L’Association nationale des clubs automobiles du Canada

From John Carlson, President/CEO (NAACC) National Association of Automobile Clubs of Canada Corporation

The proposal below will affect every collector car imported into the USA by an additional 25% i.e. cars exported from Canada and Europe will cost the buyer in the USA an extra 25%. This will seriously affect the sale of collector cars from Canada! In my opinion sellers in Canada will have a difficult time selling their vehicles outside of Canada if this Bill passes. USA buyers will be forced to sell and purchase internally or pay an additional 25% purchase price!

I urge you to voice your opinion at www.regulations.gov/docket?D=DOC-2018-0002 no later than June 22, 2018.

Thank you,

John Carlson

President.CEO NAACC

www.naacc.ca

From Mark Hyman.

It has been brought to our attention by Marshall Miller of Miller & Company P.C. that on May 23, 2018, the Department of Commerce published a Notice of Request for Public Comment regarding Section 232, investigation into the importation of automobiles and their effect on National Security. Details of which can be found HERE.

Simply put, President Trump is considering action by Proclamation to apply an import duty of 25% on ALL automobiles (this includes cars, SUVs, vans and light trucks), AND parts, regardless of age or origin. This would mean a 25% duty on ANY car – whether it be brand new or 100 years old. As automobile enthusiasts and professionals in the industry, we strongly urge you to vehemently oppose this unfair, dubious tax.

America currently applies a 2.5% duty on imported cars, which is waived on those of American origin. Under Trump’s proposal, we face a tenfold increase will surely cause retaliation from the European Union in the same manner the recent steel tariffs has proven.

Clearly, the importation of classic and collectible vehicles has absolutely no impact on our National Security, and these proposed tariffs would only serve to harm the countless individuals and independent businesses who buy, sell, restore and transport cars. The collector car hobby is a multi-billion dollar-per-year business, and we must work together to fight this ludicrous proposal. Washington bureaucrats have no understanding of the impact such a political stunt would cause, therefore it is our responsibility to educate them.

The purpose of this letter is to ask you all to join us in appealing to officials to remove any and all language related to “Used Automobiles and Parts”, and separate any content that could be perceived as pertaining to the collector car hobby from this proposed 25% tariff.

The process for commenting is simple:

Go to https://www.regulations.gov/docket?D=DOC-2018-0002 www.regulations.gov/docket?D=DOC-2018-0002 and click the COMMENT NOW button on the right of the page. It takes no more than a few minutes to support the separation of all language related to “used vehicles and parts” from the proposed tariff. The deadline for submitting comments is June 22, 2018.

In addition, we urge you to contact your Senators and Representatives to warn them of the adverse effects these proposed tariffs will have not only our beloved hobby, but more importantly the risk they pose to the thousands of passionate and hard-working Americans who make their living in the business of collector vehicles.

We send our sincerest thanks to Attorney Marshall Miller of Miller & Company P.C. for bringing this critical matter to our attention. Miller & Company are highly respected experts in all matters of international trade, and they can be contacted at www.millerco.com We thank you for your support and encourage you to act swiftly and share this letter on social media and among your friends in the hobby.

Sincerely,

Mark and The Team at Hyman Ltd.

=========================================================

Example of a response courtesy of the NAACC:

June 7, 2018 Via Electronic Mail

Honorable Wilbur L. Ross, Jr. Secretary U.S. Department of Commerce (DOC) Herbert Clark Hoover Building 1401 Constitution Avenue, NW Washington, D.C. 20230

Re: Notice of Request for Public Comments and Public Hearing on Section 232 National Security Investigation of Imports of Automobiles, Including Cars, SUVs, Vans and Light Trucks, and Automotive Parts; 15 CFR Part 705.

Dear Mr. Secretary:

Late last month, the Department of Commerce published a notice requesting comment and setting a hearing date on the above-mentioned matter. 83 Fed. Reg. 24735-7 (May 30, 2018). The notice provided interested parties with a 23-day period in which to file initial written comments, data, analyses, and other information pertinent to the investigation. Due to the vast and varied nature of the potential “articles” involved, this arguably will be the most complex Section 232 investigation ever conducted. A 23-day comment period likely will be insufficient to allow interested parties to conduct appropriate analyses and to submit well-reasoned comments; thus, 23 days is not a “reasonable” amount of time as required by the Department’s procedural rules. 15 CFR 705.7(a). Moreover, a review of prior Section 232 investigations suggests that the Department typically provides for 45- to 60-day Section 232 comment periods, with a range of between 30 and 90 days. Consequently, the undersigned trade associations request that the Department revise and extend until July 20, 2018 the deadline by which initial written comments, data, analyses, and other information pertinent to the investigation must be submitted, and revise and extend until August 20, 2018 the deadline for rebuttal comments.

Respectfully Submitted,

• National Automobile Dealers Association 8400 Westpark Drive, Tysons, VA 22102

• Alliance of Automobile Manufacturers 803 7th St NW #300, Washington, DC 20001

• Motor & Equipment Manufacturers Association 1030 15th Street, NW, Washington, DC 20005

cc: Daniel Hill, Acting Under-Secretary for Industry and Security, DOC Sahra Park-Su, Office of the Chief of Staff, DOC

• The NAACC in Canada fully supports this request and will assist in any way possible.

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