232 & 301

  • Section 232 Exclusion Request Delay

    Question: We have two section 232 exclusion requests that have been pending, without objection, since May 2022; two other requests that were submitted at the same time were approved.  We were asked to provide additional information on the volumes requested and to re-confirm if we are the actual manufacturer- which was provided in October 2022. […]

  • Section 301 reinstatement of exclusions – Federal Register/Vol. 87, No. 244/Wednesday, December 21, 2022/Notices

    Question: Would anyone in the ICPA community be able to and be kind enough to send me the list of 352 HS Codes related to the Annex of this Fed Reg notification “OFFICE OF THE UNITED STATES TRADE REPRESENTATIVE Notice of Extensions for Reinstated Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, […]

  • Sect 232 and POs

    Question: When 232 first started, I did a bunch of exclusion requests and they were all granted. But then I stopped doing them for awhile. Recently, a friend applied for several and CBP asked her for proof of purchase orders before they’d grant the request. I’d never seen that before.  Is that a new request? […]

  • POTENTIAL DOUBLE TARIFFS

    QUESTION: Since the 232 and 301 tariffs are for different reasons, it seems to reason that if something is steel and has a 232 HTS and also has an HTS in list 4A and is being sourced out of China, then it would be subject to both tariffs.  However, a friend said that this isn’t […]

  • 232 EXCLUSION PROCESS MGMT

    QUESTION: Does anyone have some good insight to share on how their company is managing section 232 exclusions?  This process has not been managed well in my company and we’ve found we exceeded some of the exclusions and now owe duty.  I’m looking at different ways to handle this but am curious as to how […]

  • Section 232 Refunds

    QUESTION: Can anyone in the membership comment on the current overall status of section 232 refunds? In the beginning, the checks were consistent. Now, they seem to be very slow and not on any type of schedule at all. I understand that Covid 19 could be affecting this, as it has so many other things….. […]

  • Section 232 Refunds

    QUESTION: Can anyone in the membership comment on the current overall status of section 232 refunds? In the beginning, the checks were consistent. Now, they seem to be very slow and not on any type of schedule at all. I understand that Covid 19 could be affecting this, as it has so many other things….. […]

  • SEC. 232 AND 9801 ENTRIES

    QUESTION: if an item would be subject to additional duties under Section 232, but it is a return and 9801 also applies, if I import it under 9801, would the additional 232 duties apply? I think NO, right?  Because 232 is oriented on the declared HTS number? ************** Answers: The answer is found in CBP […]

  • SEC 232 PROTEST DENIAL

    QUESTION:  Our Sec 232 protest was denied due to an incorrect IOR on the entry documents. We were granted approval for our Section 232 requests, however they were specific to one IOR. We understand that we are able to amend the Section 232 Exclusion Application with the proper IOR, however I wanted to know if […]

  • Section 232/ Section 301 Refund Checks

    QUESTION: Does anyone know if the Treasury Department was closed during the month of April and was not issuing refund checks? %%%%%%%%%% ANSWERS: We received weekly Refund checks the April, so I would say no. %%%%%%%%%% No they were not closed, refunds are moving slower. ================================================================

  • SEC 232 Exclusion overages

    QUESTION: Has any members of the trade had US Customs come back and state that a specific exclusion has been overused and the IOR now owes duty on entries liquidated over 180 days ago?  We have been advised that until Jan 1. 2020,  programming was not available for tracking by Customs or Trade Remedy.  Customs […]

  • SEC. 232 EXCLUSION WEIGHT TRACKING

    QUESTION: A 232 exclusion is limited both by weight and date. Does CBP track the weight, in which case they’ll deny the use of an exclusion once the weight is reached? Or do they rely on the importer to track the weight and self-limit? ========== Answer: Customs does track the weight for each Section 232 […]