Clear Signals

 

HIC Clear Signals Briefs

April 10, 2026


The Hobby Industry Coalition (HIC) has prepared a ready-to-file submission for members in response to the USTR Section 301 investigation (Docket No. USTR-2026-0067).

This is a time-sensitive opportunity to ensure the hobby industry is clearly represented in the official record.

Deadline: Wednesday, April 15, 2026 - 11:59 PM EST


Why This Matters

HIC has submitted its formal position:

 

HTSUS 9503 products should be excluded from any Section 301 remedy. 

There is no domestic manufacturing base for these products to protect. Tariffs will not re-shore production—they will only increase costs and accelerate contraction across retailers, distributors, and end users.

USTR weighs individual submissions.

The strongest outcome comes from broad participation across the industry.

Simple Participation — Two Steps

HIC has already done the work. Your submission takes only a few minutes.

Step 1 — Fill in your information

  • Name

  • Title

  • Company

  • City / State

Step 2 — Write one opening sentence

Describe your business in your own words.

Examples:

  • “My name is John Smith. I have owned a hobby shop in Illinois for 20 years.”

  • “My name is Susan Lee. I manage a distribution company serving independent retailers.”

Do not change anything else.

The legal argument and structure are intentional and aligned across all submissions.

How to Submit

  • Go to: comments.ustr.gov/s/

  • File under: Docket No.       USTR-2026-0067

  • No account required

After submitting:

Final Checklist

☐Name and title completed (top)

☐Opening sentence added

☐Signature block completed (bottom)

☐Filed under correct docket

☐Copy sent to HIC

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Reference: HIC Submission 

Below are sample comments submitted by HIC. Member submissions should align with this position while adding your own opening statement.

COMMENT OF THE HOBBY INDUSTRY COALITION

I. Introduction

The Hobby Industry Coalition is a § 501(c)(6) trade association whose members manufacture, distribute, and retail products classified under HTSUS heading 9503—scale-model locomotives and rolling stock, track systems, radio-controlled vehicles, and static model kits. HIC submits this comment to oppose any Section 301 remedy covering those goods.

The Administration’s concern about structural excess capacity is sound. This comment does not challenge it. The argument here is narrower: HTSUS 9503 goods do not belong in this proceeding.

II. The Core Problem

A Section 301 remedy works when it changes behavior. That mechanism does not apply here.

There are no domestic producers of HTSUS 9503 goods. A tariff cannot shift demand toward domestic alternatives that do not exist. It can only raise prices.

III. Legal Framework

Section 301 allows USTR to tailor or withhold remedies where they do not serve the statute’s purpose.


This investigation targets sectors where U.S. production exists or is developing. HTSUS 9503 is not such a sector. A remedy here would not correct any identified foreign practice—it would only tax imports.

IV. The Facts

A. These products cannot be made here.


HTSUS 9503 goods require specialized tooling, supply chains, and labor expertise that do not exist in the United States at commercial scale.

B. Existing duties are already doing damage.

The Section 122 surcharge and existing duties have resulted in:

  • Reduced inventory

  • Cancelled purchases

  • Margin pressure

  • Continued closure of specialty retail stores

C. End users cannot absorb higher prices.

Customers include hobbyists, educators, veterans, and nonprofit programs. When prices rise, purchases decline or stop.

V. Prior Practice Supports Exclusion

HTSUS 9503 was excluded from prior Section 301 tariff lists. No new domestic production or trade practice justifies a different result.


VI. Requested Relief

HIC requests:

  1. Exclusion of HTSUS 9503.00.0090 and related subheadings; or

  2. Reinstatement and expansion of administrative exclusions

VII. Conclusion

The remedy must match the problem. There is no domestic production to protect. Tariffs will only raise prices and harm small businesses and institutional buyers. USTR should exclude HTSUS 9503 from any remedy.

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Bottom Line

HIC has made the case. The industry must now reinforce it.

This is a high-impact, low-effort action.

Please take a few minutes to submit your comment before the April 15 deadline.

Disclaimer

The  information contained in this article is believed to be accurate as of the date  of publication and is provided for informational purposes only. It should not  be construed as legal, financial, or business advice. Readers should consult  their customs broker, legal advisor, or other qualified professional and  independently verify relevant information before making business decisions.