Creeper
Husqvarna
AA Class
Here's a copy of the letter sent by Harley-Davidson Motor Co.
Remember that they recently bought MV Agusta and have every intention of importing motorcycles made in Italy.
Remember that they recently bought MV Agusta and have every intention of importing motorcycles made in Italy.
December 2, 2008
Office of the United States Trade Representative
Attention: Ms. Sandy McKinzy Fax 202-395-3640
cc: www.regulations.gov
Re: Docket No. USTR-2008-0036
Review of Action Taken in Connection with WTO Dispute Settlement Proceedings on the European Communities’ Measures Concerning Meat and Meat Products
Harley-Davidson Motor Company (“Harley”) appreciates the opportunity to comment on possible modifications to action taken by the United States Trade Representative in the EC-Beef Hormones dispute. With these comments, we are registering our opposition to the inclusion of motorcycles (HTS 87112000 and HTS 87113000) in Annex II in any revised list for the imposition of increased duties. We do not believe any class of motorcycles manufactured in any member state of the European Communities should be subjected to increased rates of duties on account of the beef hormones dispute.
Of the approximately 80 product classifications listed in Annex II, all but 5 are related to agriculture and/or food. Of the remaining 5 classifications, 2 are motorcycles. Lumping motorcycles together with 75 agricultural and food product categories politicizes and draws unneeded attention to motorcycles as a special class of goods. In our opinion, doing so only invites European regulators to consider targeting U.S.-manufactured motorcycles for punitive duties in the next major trade dispute between the United States and the European Communities, regardless of the issue under dispute.
We are concerned because this has happened before. In 1999, USTR placed European-made motorcycles on the list of goods potentially subject to punitive duties, in response to Europe’s continuing refusal to allow the import of American beef treated with growth hormones. The appearance of European-made motorcycles on USTR’s sanction list caused a stir in our industry and was widely reported in the media. Although European motorcycles were eventually dropped, their initial inclusion on USTR’s retaliation list was not forgotten by European trade officials. In the next major Trans-Atlantic trade dispute, namely over steel tariffs, the EU specifically targeted American-made (read, Harley-Davidson) motorcycles for punitive levies up to 30%. It was only through an extraordinary effort that Harley was successful in having its motorcycles removed from the EU’s retaliation list. Harley’s effort consumed countless hours and substantial resources in mustering European motorcycle enthusiasts, dealers, suppliers and industry allies to help it convince Brussels that Harley-Davidson motorcycles should not be drawn into the steel tariff dispute. Accordingly, we request that the motorcycle categories identified in Annex II not be included in any revised list for additional duties. With all due respect, we do not believe the motorcycle industry on either side of the ocean should be drawn into a Trans-Atlantic fight over beef hormones.
There are additional reasons for not subjecting European-made motorcycles to additional duties in the beef hormone dispute. In August of this year, Harley-Davidson, Inc., the parent company of a group of motorcycle companies including Harley, completed the purchase of the privately-held Italian motorcycle manufacturer, MV Augusta Group (“MVAG”). Besides producing large displacement, high performance sport motorcycles, MVAG also produces lightweight motorcycles sold under the Cagiva brand name. These include three models powered by a 125 cc engine and thus covered under HTS 87112000 in Annex II. While no final decision has been made, it is abundantly clear that bringing these or similar Cagiva models to the United States would not be feasible for Harley-Davidson, Inc. or U.S. dealers handling MVAG products if additional duties were imposed.
It is also important to note that Harley-Davidson motorcycles in the United States are sold through a network of approximately 680 dealers. These dealerships are independently owned and operated and some are multiline, in that they also sell other brands of motorcycles including European-made motorcycles identified in Annex II. In these recessionary times, it is important that all of Harley’s dealers, including those handling competitive products, maintain their financial health. Imposing additional tariffs on European-manufactured motorcycles would be detrimental to the financial wellbeing of those multiline Harley dealers carrying them.
In conclusion, we wish to thank you for giving us the opportunity to explain why Harley-Davidson Motor Company opposes the inclusion of motorcycles on a revised list for the imposition of increased duties in the beef hormone dispute.
Sincerely,
Timothy K. Hoelter
Vice President, Government Affairs