232 & 301

  • Sec 232 Exclusion refund requests

    QUESTION: Does anyone know the time line to receive a refund on a PSC for these Sec 232 exclusions? (meaning, once the PSC is filed asking for the refund, what is the time line to receive your money back) Who will be handling the refunds?  The port where the entry is filed or the CEE? […]

  • ITEMS SUBJECT TO BOTH SEC 232 & 301

    QUESTION: I have a c/o China cast aluminum article classed at 7616.99.5160, subject to section 232. However, HTS 7616.99.51 is also covered under section 301 tranche 3. Is this subject to both section 232 AND section 301 additional duty? ========== Answer: Yes ==========    

  • COO Labeling Parts used in Production

    QUESTION: What are the COO rules as they apply to parts my company produces that are used ONLY in production of finished goods?  That is, they are not sold or re-sold to customers directly. I discovered that parts we’re producing in Europe did not have COO in system (I’ll address that myself), but COO is […]

  • SEC. 321 RELEASE FROM FTZ

    QUESTION: Does anyone in the membership know if Section 321 entry can be claimed on withdraws from an FTZ? If I understand correctly, most Section 321 entries are filed by carriers. In case of FTZ, normally who files for Customs release? FTZ operator or carrier? Is ACE ready for brokers to file Section 321 entries? […]

  • ACE BOND SUFFICIENCY REPORT

    QUESTION: What is the best ACE report for sanity check on sufficient bond amount?? ========== Contact your bond writer for a report, it’s a lot easier. ========== Any of the Entry Summary reports would work depending on how detailed you want to get (ES-7008 perhaps) – but don’t forget to factor forward based on the […]

  • Miscellaneous Tariff Bill – HTS Codes

    QUESTION: Does anyone have a list of the tariff numbers that will be impacted by the miscellaneous tariff bill 2018? ========== Answers: Attached is the link to the version passed by the Senate. https://www.congress.gov/115/bills/hr4318/BILLS-115hr4318rfs.pdf ========== Here is the full list of MTB HTS codes. http://www.icpainc.org/wp-content/uploads/2014/10/Copy-of-MTB-2018.xlsx ========== Hi, Attached is a spreadsheet showing the HTS, MTB […]

  • NAFTA SOLICITATION SCENARIO

    QUESTION: Topic: Annual solicitation and factories I’ll start with giving the context for my new company: 30+ years of growth in the US, quite a bit of exports and a larger handful of imports. Factories are in the Midwest and South. They have never had a dedicated compliance person. Lots of stuff gets done on […]

  • Section 301, Assists and Transfer Pricing

    QUESTION: We ship US component parts to a related foreign supplier in China who in turn incorporates them into a finished product and exports back to us. I see an opportunity to lower our customs value and therefore avoid Section 301 duties but not sure how we claim the assist value on the item if […]

  • 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 […]