Our Directors have confirmed that the tariffs and other trade restrictions arising from recent geopolitical tensions between China and the United States have not had any material adverse impact on our business operations or financial performance during the Track Record Period, reflecting: (i) a significant portion of our products sold overseas are exempt from such tariffs and other trade restrictions; (ii) the limited proportion of our revenue derived from direct exports to the United States; (iii) the relatively substantial contribution of our overseas markets in Asia, the Americas, and Europe, rather than the United States; (iv) the principal sourcing of our core raw materials and production equipment from suppliers within the PRC and other non-U.S. jurisdictions; (v) our localised overseas production model, which mitigates cross-border trade barriers including tariffs; and (vi) the stability of our operating results during the Track Record Period.
浙江荣泰电工器材股份有限公司Zhejiang Rongtai Electric Material Co., Ltd.
产品不涉出口管制及美国关税影响
As advised by our PRC Legal Advisor, our products were not subject to export control restrictions under PRC laws and regulations during the Track Record Period and up to the Latest Practicable Date.
Business · 第 139 页
Based on advice from our legal advisor as to international sanctions laws, during the Track Record Period and up to the Latest Practicable Date, as our products are not of U.S. origin, are not within the U.S., and do not fall within the scope of either the De Minimis Rules (which subject certain foreign-made items to the EAR if they incorporate more than a de minimis level, typically 25%, of controlled U.S.-origin content by value) or the Foreign-Direct Product Rules (which extend EAR jurisdiction to certain foreign-produced items that are the direct product of specified U.S. technology or software), such products are not subject to the U.S. Export Administration Regulations (“EAR”) because none of the criteria set forth under the EAR has been met and, consequently, are not subject to U.S. export licensing requirements, as such licensing requirements under the EAR only apply strictly to items that are subject to the jurisdiction of the EAR.
Business · 第 163 页
As advised by our legal advisor as to international sanctions laws, during the Track Record Period and as of the Latest Practicable Date, the additional cumulative U.S. tariffs applicable to our products generally ranged from 20% to 37.5%.