232 & 301

  • Proposed 232 Rule Published 8/28

    Question: Does anyone know of an pro-import action committee? My company imports steel and we are looking to comment on the new proposed rule in hopes of lessening the impact. My main concern is the requirement to source from preferred countries (with quota ratings). We do source from them but also elsewhere. Everyone in the […]

  • 301 Tariffs

    Question: Does anyone know of an opportunity yet to make comments to extend the 301 tariff exclusions that end on 9/30/23?  Or of an opportunity to submit for a new exclusion?  Thank you! Answer 1: There has been no announcements from USTR on requests for comments to extend the existing 301 tariff exclusions that will […]

  • 301 Duty

    Question: We have 9 entries that we believed fit the exclusion and request the broker file a PSC, we received a refund. After an in-depth study and review we have now determined they do not fit the exclusion exactly. We have confirmed that all entries other than these 9 were filed correctly. We owe Customs […]

  • Section 232 exclusion requests

    Question: We are wanting to submit some Section 232 exclusion requests for various sizes of a particular steel.  We are wondering if it’s better to submit 1 request to make sure it is processed properly before submitting the other requests or is it better to submit all of the requests at once? Answer 1: Some […]

  • Product Classification & Section 301 Tariff on Non-China Origin Components

    Question: My questions relate to whether I can avoid paying Section 301 tariffs on the non-China origin components of an an import from China.  Classification comes into play as well.  I think I know the answer, which I don’t like, but I am going to ask the question anyway.  We are importing, from China, a […]

  • Section 232 Exclusion on 7501?

    Question: How are section 232 exclusions “claimed” on an entry? Is an HTS code used that references the exclusion, or is there some process in ACE/broker software for claiming the exclusion without it showing up on the 7501?  CSMS #39633923 does not really explain it. I ask because we have a customer telling us there […]

  • 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? […]


    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 […]


    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….. […]