Sec 301

  • Do China 301 duties apply to Malaysia assembly

    QUESTION: We have a $150,000 machine that takes about 30 hours to machine and assemble in Malaysia. The 3 key of its 12 parts come from China, and they add up to about $60,000. Can we claim this as made in Malaysia or do we have to pay 301 duties on it? ========== Answers: Made […]

  • 4-year review of the 1st two tranches

    QUESTION: Can the membership please advise on the likely outcome of the Section 301 4 year review of the tranches?  Is there a chance that the 25% duty will go away? %%%%%%%%%% ANSWERS: Tariff Lists 3 and 4A will undergo the same review that Lists 1 and 2 are going through now. All tariffs will […]


    QUESTION: What does this notice mean to importers currently paying China tariffs on products which are not part of the current exclusions (due to description not matching exactly)?  Our tariff code is excluded, but since the description doesn’t match we can’t use the current exclusion.  The way I interpret is that only domestic manufacturers which […]

  • 301 Refunds

    QUESTION: Is anyone else experiencing a slow down in having their 301 tariff refund PSC’s approved and refunded from the first round of exclusions?   We have not seen anything approved for 3 months and have a large volume we are waiting for and anxious to receive. ========== Answer: Yes – same boat.  We have about […]

  • Section 301 tariffs exclusion extension

    QUESTION: Is this notice a result of the longstanding dispute in the US Court of International Trade?  If so, will the exclusion only apply to plaintiffs in the litigation or can any importer use it for refunds and future entries? FRN for Notice of Reinstatement.pdf ( ========== Answer: The reinstatements are not a result of […]

  • Section 301 HS & HTSUS 2022 Changes

    Question: Is anyone aware of a newly published Section 301 list that reflects the new 2022 HS subheadings? Or have a sense of when this will be published? ========== Answers: Customs yesterday published the updates for 301 items on exemptions. Otherwise, I’ve been referred to the official HTS update release. In the footnotes it does […]

  • Sec 301 duties and new tariff schedule

    QUESTION: Will the new split of 8517.70 due to WCO updates be applicable to Sec 301 duties?  That is, will 8517.79 and 8517.71 have Sec 301 duties? Is there a document that someone can share showing Sec 301 duties cross-referenced with the new HS schedule? ================================================ Answer: The short answer is yes, 301 duties apply […]


    QUESTION: Need help from the membership to identify the basis for identifying the value subject to Section 301 duties. Specifically, if an imported good includes a China-origin component that was sent to a third country for further assembly, but not substantially transformed, what value is subject to Section 301 duties? Logic may dictate that only […]


    QUESTION: Does an IOR have any recourse to get the Sec. 301 duties back under the below scenario?  Thanks. The vessel arrived port on 11/27/21. The container discharged on 11/28/21. The broker didn’t file the entry until 12/2/21 and it released the same day. The Exclusion was effective until Nov. 30, 2021. The HTS#’s in […]

  • Section 301 and HTS footnotes

    QUESTION: Is it true that List 4 goods do not come under the 301 tariffs at 25%? My question has to do with specific HTS code 84819030. It refers you to note 4, which refers you to 9903.88.15, which says the tariff is what is provided in subheadings plus 7.5%. =========================================== ANSWERS: That’s correct, 9903.88.15 […]


    QUESTION: If a Canadian company ordered component parts [frames] directly from our subsidiary company in China and had those parts shipped to our US parent company to be assembled with the component parts [rolls] ordered directly from this US based company, would section 301 tariffs or any tariffs apply to the frames ordered from China. […]

  • Sec 301 Tariff litigation lawsuit

    QUESTION: Does anyone have the number of importers/plaintiffs that were involved in this lawsuit?  Or is there a list of those importers who jumped on the bandwagon?  Also, I would like to know what the percentage of plaintiffs may be in reference to the importing community in its entirety if available.   =========== Answers: There are hundreds…we filed…it […]