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 […]
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 […]
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 […]
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 […]
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 ==========
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. […]
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 […]
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 […]
QUESTION: I’m struggling to understand the “lesser of 2 duties” rule, as it applies to the 301 tariffs. It looks like it only applies to mfg drawback. If I import in articles subject to the 301 tariffs, and I export them out in the exact same condition – Can I claim 99% drawback on the […]
QUESTION: 19 U.S. Code § 1862 specifically mentions “imports.” By what authority, then, is the President allowed to ban Drawback? Exports are not mentioned in that section at all. ========== Answers: I think that the question is not whether the president has the authority to “ban” drawback – he is not and he […]
QUESTION: Can foreign producers reimburse Section 301 duty payments made by importers? ========== Answers: I believe this would be considered a rebate and advise against it. ========== Yes. This is not like anti dumping or CVD. ========== Yes, it is legal for suppliers to reimburse importers for the Section 301 duties. We have had a […]
QUESTION: I understand the Section 301 exclusion request is product specific. But product specific does not seem to mean part number or company/submitter specific. If we import ABC item, which is exactly the same thing as one of our competitors imports, and we receive an exclusion does our competitor benefit from our exclusion? If so, […]
