QUESTION: The third batch of product exclusions from the section 301 tariffs allowed for the exclusion of, “…tines, carriages, and other goods handling apparatus and parts designed for use on fork lift and other works trucks (HTSUS 8431.20.0000)”. We have interpreted this to mean that only the goods-handling apparatus for use on a forklift is […]
QUESTION: Our US supplier group assists our Mexican sister company manage its suppliers. Within the last six months, the US supplier attempted to use an FTZ strategy to avoid substantial 301 tariffs – but somehow didn’t import correctly, so got charged the tariffs, anyway. I was reading up on it since the US company doesn’t […]
QUESTION: We would appreciate input from the membership on the below scenario. Item X is a finished good imported from a factory in China. It consists of 68 parts including mounting brackets, screws, plastic parts etc. The factory plans to move to Thailand to produce item X. In the first phase of the move, the […]
QUESTION: Will there be an exclusion process for List 4 once it’s finalized? ========== Answers: Yes, it will likely mimic the one in place for lists 1 and 2. Bad news is, ONLY list one has received exclusions to date, list 2 is next, then list 3 and 4. It will be a very long […]
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 […]
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 – […]
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 […]
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 […]
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 […]
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. […]
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 […]
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 […]
