QUESTION: Have any members submitted an 301 exclusion refund? If so, how long did it take to get the funds back and was the refund request submitted through normal drawback filing channels? ************ Answers: Section 301 refund requests are not submitted through “drawback channels.” CBP has issued instructions on how to apply for refunds related […]
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 […]
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: […]
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 […]
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 […]
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. […]
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.
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 […]
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 […]
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 […]
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 […]
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 […]
