• SEARCHABLE 301 EXCLUSION DATABASE

    QUESTION: The only place I can find exclusions to the 301 tariffs are in the Federal Register, which is not exactly very searchable. Does anybody have a single master list of all the exclusions in one place? ========== Answers: The US Trade Representative website on How to Navigate the Section 301 Tariff Process https://ustr.gov/issue-areas/enforcement/section-301-investigations/search includes […]

  • 232 & 301 TARIFF PROCESS

    QUESTION: I would like to know how other companies are managing the 301 and 232 lists of HTS codes affected by the new tariffs. Is your ERP system capable of incorporating of flagging the lists of HTS codes affected or are you handling the process manually with spreadsheets? I would appreciate your guidance. =========== Answers: […]

  • List 4A

    QUESTION: 1). Does anyone have list 4A in Excel? 2). Does anyone have list 4A with all 10 digits of the HTS? I have list 3 showing all 10 digits but I can’t find list 4A with all 10 digits ************ Answers: https://www.icpainc.org/wp-content/uploads/2014/10/ICPA-Chinese-301-tariffs-ALL-4-LISTS-COMBINED-1-2.xlsx ***************** List 1-4 below: No 10 digit codes are available. What you […]

  • 301 EXCLUSION CONFIDENTIALITY

    QUESTION: How is importer confidentiality treated when submitting a Section 301 exclusion request and when CBP approves an exclusion request? I am concerned with including proprietary technical and visual information with my exclusion request and it becoming public information. Can the trade offer advice how to request this be kept confidential? Will having a manifest […]

  • SEC 301 & SUBSTANTIAL TRANSFORMATION

    QUESTION: Chinese component part “A” imported into Mexico for assembly into Finished End Item “B”. Finished End Item B is exported to the US. However, Chinese component part A does NOT substantially transform during assembly. This means Finished End Item assembly B would be subject to List 3 tariffs (25%–>30%) when imported into the US. […]

  • List 4A 4B Exclusion Process vs Deferral

    QUESTION: Is anyone pursuing a deferral on implementation of List 4A and 4B tariffs? If so, any details would be welcome e.g. external party, congressman etc. ************** Answers: Deferral, that’s funny. That ship has sailed, in fact, rates are more likely to increase.

  • Section 232 Refunds- ACE Issues

    QUESTION: The customs broker that is filing the PSC’s for refunds on 232 duties is telling us that there is one ACE issue after another slowing down the refund process. The latest “glitch” , according to the ACE help desk, is due to be corrected “by 9-21-19” which significantly impacts our refund timing…… Last week […]

  • SUCCESSFUL EXCLUSION REQUESTS

    QUESTION: I’m asking members who had approvals on their exclusion request: 1) Do you have to provide evidence on why the product is unique and cannot be sourced from outside of China? 2) Do you need letters of support from members of congress from your state? 3) Do you have to show the tariffs would […]

  • How does one locate and view the Section 301 Exclusion Requests file so far?

    QUESTION: I would like to read some of the exclusion requests that have been successful or denied. Where can one locate and view those filed to date? ************* Add’l Answer: How to locate List 1 and List 2 Exclusion Granted & Denied www.regulations.gov. For list 1 ($34BN list) in the search box type – USTR-2018-0025 […]

  • SUBMITTING COMMENTS ON CHINA TARIFFS

    QUESTION: I understand that comments can be submitted to the USTR regarding the China tariffs. Question: Are comments to be filed on the USTR site where exclusion request are filed? If not, then where? *************** Answers: Comment filing instructions are in the Federal Register Notice that was issued on September 3. Paul Vandevert, Principal paul@ochimtradelaw.com […]

  • Section 301 exclusion

    QUESTION: Does anyone know if we can use the section 301 exclusion if the product HTS fits to the exclusion HTS code, or if our product has to match exactly with the description listed on the exclusion. ========== Answers: Both. Your product needs to the HTS code and fit within the description listed on the […]

  • DEADLINES FOR 301 EXCLUSIONS

    QUESTION: Does anyone have a cheat sheet on the Federal Register published dates listing the official deadlines to file for exclusions relative to the Section 301 Trump Tariffs? *************** Only List #3 is open for exclusion requests. The exclusion request window opened on June 30 and closes on September 30. Paul Vandevert, Principal paul@ochimtradelaw.com +1 […]