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 […]
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 […]
QUESTION: Does anyone in the community have List A and List B in excel format? ========== Not available, you need an analyst to manipulate data from the PDF files to excel. This is time consuming though, but well worth it. In recommend this, since other groups within the company will certainly ask for an excel. […]
QUESTION: My understanding is that the 301 tariff List 4 is going to take effect on Sept 1, 2019. Does any members know the Sept 1 is based on the shipping date ship out from China or shipments that arrival after Sept 1? Is there a link that I can check for the above info? […]
QUESTION: Can a Canadian based Foreign IORs who do not have a presence in the US are considered for exclusion requests under Section 301 duties? From what I read, it’s pretty clear that it only applies to US companies? ========== Answers: If China product is being imported into the U.S., the entry is subject to […]
QUESTION: A few weeks ago I filed a PSC for a Section 301 exclusion refund and now have additional lines on the same entry where the Sixth Round of Section 301 List 1 Product Exclusions will apply. How can I apply for exclusion refunds for the other line items using 9903.88.11 when my previous PSC […]
