232 & 301

  • SEC. 301 EXCLUSION REQUEST

    QUESTION: With regard to the section 301 China tariffs exclusion form question 10, it asks you to provide the value for the previous 3 years. If the HTS code calls for “X” as the quantity, do you leave the quantity blank or would you provide some type of quantity such as how much you ordered […]

  • 301 entry pre-filing

    QUESTION: Looking to settle a debate: Can we pre-file entries using the 5 day parameter, selecting an entry date prior to 9/24 to avoid paying the additional 10% duty?   Or would AMS reject the entry when the vessel arrives 9/24 or later and force the additional duty due? ========== Answers: You can file and get […]

  • SEC. 301 DUTIES AND DFARS [S]

    QUESTION: I’m trying to confirm whether imported goods from China which would normally be exempt from duty under DFARS are now subject to the 25% tariff. My presumption is the normal duty rate is still exempt, but the 25% now applies. Can anyone confirm that?  I’ve not been able to find a specific statement addressing […]

  • Section 301 Duty Reimbursement [S]

    QUESTION: A question was asked recently as to if foreign producers can reimburse Section 301 duties paid by US importers.  Half the responses answered “yes” and the other half answered “no”. Can anyone provide the citation to support the correct answer? %%%%%%%%%% Addl ANSWERS: Legally you can be reimbursed.  It is not the same as […]

  • Section 232/301 Enforcement

    QUESTION: With increased enforcement on Section 232 and 301 expected, I heard there may be increased level of penalties for non-compliance with Section 232 and 301.  I heard during the 232 webinar from CBP, the increased penalties could be as high as 3X the value of the goods. Can anyone provide additional references, support or […]

  • SEC. 301 BOND INCREASE

    QUESTION: With the recent passing of the 3rd Section 301 list, our company will be affected and our import duty will increase. To assess the correct import bond amount, should we wait a year to have a full year’s worth of data with increased duties paid or should we do a projection now and increase […]

  • SEC. 301 LIST # 3 ACTIONS

    QUESTION: With List 3 approaching, it will affect about 65% of the tariff, what actions are others taking to mitigate the higher duties? ========== Answers: There are fewer and fewer options available, and most likely are a waste of time as the administration may add even more duties. Only real option is to shift production […]

  • MTB impact to 301 Tariffs

    QUESTION: Assuming that the MTB is signed by the President soon, how does this impact 301 duties?  Will the MTB duty apply to the current rate of duty, and if subject to 301, still be subject to the 25%?  So, if normal rate of duty is 6%, and MTB takes that to 0%, the product […]

  • SEC. 301 LIST # 3 IN EXCEL

    QUESTION: Does any member have an excel format of the updated List 3 that goes into effect 9/24? ========== Answers: http://www.icpainc.org/wp-content/uploads/2014/10/Section-301-lists.xls ========== Here you go! http://www.icpainc.org/wp-content/uploads/2014/10/301-NEW-LIST-09182018.xlsx ========== Here is a workbook with all 3 lists on separate tabs. http://www.icpainc.org/wp-content/uploads/2014/10/Chinese-301-tariffs-COMBINED-1.xls ==========  

  • INCREASING CUSTOMS BOND

    QUESTION: If our surety company advised us that our Customs bond is insufficient, but the pending List 3 of Sec 301 tariffs would greatly increase our total DTF (duties, taxes, fees) should we wait to see what happens with that, or increase now? I’m concerned with stacking our bond and having multiple layers of liability. […]

  • Valuation for Sheet Set components

    QUESTION: Our company will be purchasing sheet sets consisting of a flat sheet, a fitted sheet and 2 pillowcases of at least 55% cotton. These will not be packaged for retail sale at the time of import. There are multiple rulings in CROSS that show that the sheets should be classified separately as 6302.31.9020 and […]

  • SEC. 301 DUTIES AND TRANSFER PRICING

    QUESTION: Is there a problem with changing the Transfer Price of a product to account for unforeseen the Section 301 duty? The transfer prices have already been set and include an amount for duty.  The current transfer price, inclusive of previous duty amount, results in leaving an agreed amount of profit at our related party […]