Question: Has anyone pursued a preventative Court challenge in the U.S. Court of International Trade (CIT) to contest the legality of tariffs (e.g., IEEPA or Section 301) before liquidation?Trade lawyers are increasingly recommending this approach because it can: Preserve refund rights without waiting for liquidation and protest denial Enable importers to benefit from a favorable […]
Question: 232 tariffs on steel and aluminum do not apply to the packaging used to transport goods imported into the US, correct? We have products we import in steel 55 gallon drums, and the concern was raised is these imports are subject to 232 tariffs on the steel drums (normally we do not declare the […]
Question: We are a German owned company with a US location and tax ID. Our US location has customers in Canada, the Caribbean and South America. If we ship directly to a customer from Germany in one of these countries and our goods never enter the US commerce, are they subject to current US tariffs? […]
Question: Can you please help us clarify when the 10% reduction in duties for IEEPA takes place? Is the November 10 effective date determined by vessel arrival or date the entry summary is transmitted? From 19 CFR: 141.1 Liability of importer for duties. (a) Time duties accrue. Duties and the liability for their payment accrue upon imported […]
Question: Would anyone have insight into the latest Annex I (Sept 25th, EU import exclusions) and potential proposed Annex III exclusions for Pharma? We are wondering if some of our raw materials, which are used in Pharma applications and also for Medical Device manufacturing downstream, might be able to take advantage of the ‘Pharma’ scope. We aren’t […]
Question: How long is it taking for PSCs to be processed where additional tariffs should or should not have been claimed on original entry? What are people seeing? Answer 1: We submitted PSC’s for both should and should not have paid in August and September. Most have already liquidated with bills or refunds. We have […]
Question: Is there currently a process in place to request exclusion from the reciprocal tariffs for specific products? If so, what is the process? I’ve been asked by a customer to assist with a petition to USTR or Commerce to request inclusion in Annex II. However, I can’t find any information on a petition process. […]
Question: When entering material that falls on the new EU exemption list with pharma scope limitations – what documentation are you providing for proof and will you provide it per import or per material? If per import, I am thinking it doesn’t make sense as a distributor to claim the exclusion since we wouldn’t be […]
Question: I need clarification on a potential conflict in the July 31, 2025 Executive Order “Further Modifying the Reciprocal Tariff Rates”: Section 2(c) states that “the additional ad valorem rate of duty applicable to any good of the European Union” follows a 15% minimum combined rate structure Section 2(f) preserves “the terms of Executive Order […]
Question: RE: Section 232 I’ve seen one answer for this question using the beer and aluminum can as an example and I’m still needing to make sure I understand correctly. For a Derivative item – let’s say it is a tool with metal qualifying parts and the rest is plastic – when removing the plastic […]
Question: Has anyone attempted to mitigate the IEEPA reciprocal tariffs using the 20% US input exemption? I am mainly interested in how to calculate the input of US cotton used in a textile flat good or apparel product, but would be interested in how members have made the calculation and how it was documented. Answer […]
Question: Hi members, Any idea on the 40% transshipment tariff from Vietnam or are we all in the same boat on not understanding how this will be enforced? Any guidance is welcomed! Answer 1: It is not clear, and appears it is somewhat discretionary. What I have heard is there likely will an increased review […]
