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: 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 […]
Question: EU reciprocal tariff is 15% but per the below, it seems that civil aircraft & parts are exempt per the “zero-for-zero” agreement. I cannot find anything in the Federal Register or CBP CSMS that shows this is correct. And, if correct. what is the exemption HTS code? A landmark EU–US trade agreement, finalized on July […]
Question: Regarding the calculations for steel/aluminum/copper and the smelt/pour/cast etc. requirements: Is anyone willing to share the verbiage of the letter they’ve sent to their suppliers letting them know that you will need this additional level of information? Answer 1: Here is my suggestion: [Date] [Supplier Contact Name] [Supplier Company Name] [Supplier Address] Subject: Request […]
Question: What is the difference between a tariff and a duty? This sounds very rudimentary, however, there are conflicting definitions. Answer 1: There are nuances and historical differences (especially outside of US), but for all practical purposes, duty rate or duty amount 100% same meaning as tariff rate or amount. Answer 2: Tariff – a […]
Question: Hello! How are teams currently communicating which provisional tariff codes apply to entry lines with their Customs brokers? Are you relying on the broker to determine the appropriate codes and then reviewing them after the entry is filed? Alternatively, are there any best practices you can share for proactively communicating the correct codes for […]
