232 & 301

  • CROSS RULING DOUBLING 301 TARIFFS

    QUESTION: I am wondering what the membership’s thoughts are about CBP headquarters ruling H301769 from last month indicating that tool sets falling under heading 8206 should have the 301 tariff for both 8206 and the 301 tariff for the secondary HTS applied meaning that double tariffs are owed on the same item. Has anyone heard […]

  • ITEM ON BOTH 232 AND 301 LISTS

    QUESTION: What if something is on both lists? Will the 232 additional duties apply AND the 301 duties so it could be 25% plus 25% plus the regular duty rate? ========== Answers: Yes, the duties have separate purposes, you will need to add them together. ========== Yes, you get a double whammy. ========== correct – […]

  • Section 301 China origin vs China export

    QUESTION: How do the Section 301 tariffs deal with product that is processed/manufactured in China for which the processing/manufacturing does not change the customs origin of the manufactured good? For example, the rules of origin for goods of 6302.31 (woven, cotton-rich sheets and pillowcases) the country of origin is “the country, territory, or insular possession […]

  • Comments due for List 4

    QUESTION: It is my understanding final comments are due for List 4 by June 17th 2019. Has anyone in the membership submitted comments for previous lists and been successful with the outcome? Is there a special format? Where are the comments sent, etc. Basically, where can I find information or get an example of comments […]

  • HTSUS 9903.88.09

    QUESTION: We are a US manufacturer with a factory in Tijuana operating under the Maquiladora program. Our inventory of Buy Sell and Make products is heavily sourced from China. We import through the US and move in bond to Mexico to our non-bonded factory warehouse. Can we import our inventory held in Mexico that was […]

  • 25% tariff on Chinese goods

    QUESTION: I think I know the answer but want to get others’ opinions.  Let’s say we have a shipment of Chinese origin that is currently subject to the 10% tariff which will go to 25%.  The shipment left China before May 10 and was imported into Canada, where it was deconsolidated into an LTL shipment.  […]

  • 232 Exemption Requests

    QUESTION: We submitted several 232 steel exemption requests to BIS in late December. Although the shutdown did not help, we are well over the 90 day “review period” after receipt by BIS, and we have not received any information that CBP had any issues with the HTS codes, or that any of our data is […]

  • Section 232 Product Exclusion Request Granted – Timeline for Refunds

    QUESTION: Can anyone in the membership share their experience regarding the timeline to receive a retroactive refund on Section 232 duties paid, after an exclusion was granted and the PSC’s for refunds were submitted? Thank You! ========== Answer: We received most of ours 6-8 weeks after filing the PSC. We receive our refunds by direct […]

  • SEC 232 STEEL EXCLUSION REFUND TIMEFRAME

    QUESTION: Does anyone have direct knowledge of timeframe for receiving refunds one PSC has been filed and accepted for goods which were granted exclusion from Section 232 tariff? *************** Answers: We filed immediately and still wait for refunds. There is no guaranteed time line that I am aware of – you just have to wait […]

  • Non US Goods Returning to the US after being exported – Sect 232

    QUESTION: We have a shipment of Italian pipe that was originally import to the US and Sec 232 duties paid at that time. Pipe was exported to St. Croix to our customer. Upon arrival it was determined that the product was incorrect and needed to be returned back to the US. Can anyone in the […]

  • USING SEC. 232 EXCLUSION

    QUESTION: We recently received an exclusion for Section 232. When we told our customs broker, we were told that they were unable to apply the exclusion to the entries going forward. In addition, they told me they cannot go back and receive the refunds from previous entries. The broker is telling me that CBP is […]

  • 3rd List Section 301 and increase in duty. Procedures for 3/2

    QUESTION: During the GAC (Government Affairs Conference) last year, it was discussed if would be possible to claim an entry date prior to 03/2/19 to take advantage of the lower Section 301 duty. Attendees were told this was possible by uploading the documents and a request to DIS prior to clearance. Has anyone heard about […]