QUESTION: With List 3 approaching, it will affect about 65% of the tariff, what actions are others taking to mitigate the higher duties? ========== Answers: There are fewer and fewer options available, and most likely are a waste of time as the administration may add even more duties. Only real option is to shift production […]
QUESTION: Assuming that the MTB is signed by the President soon, how does this impact 301 duties? Will the MTB duty apply to the current rate of duty, and if subject to 301, still be subject to the 25%? So, if normal rate of duty is 6%, and MTB takes that to 0%, the product […]
QUESTION: Does any member have an excel format of the updated List 3 that goes into effect 9/24? ========== Answers: http://www.icpainc.org/wp-content/uploads/2014/10/Section-301-lists.xls ========== Here you go! http://www.icpainc.org/wp-content/uploads/2014/10/301-NEW-LIST-09182018.xlsx ========== Here is a workbook with all 3 lists on separate tabs. http://www.icpainc.org/wp-content/uploads/2014/10/Chinese-301-tariffs-COMBINED-1.xls ==========
QUESTION: If our surety company advised us that our Customs bond is insufficient, but the pending List 3 of Sec 301 tariffs would greatly increase our total DTF (duties, taxes, fees) should we wait to see what happens with that, or increase now? I’m concerned with stacking our bond and having multiple layers of liability. […]
QUESTION: Our company will be purchasing sheet sets consisting of a flat sheet, a fitted sheet and 2 pillowcases of at least 55% cotton. These will not be packaged for retail sale at the time of import. There are multiple rulings in CROSS that show that the sheets should be classified separately as 6302.31.9020 and […]
QUESTION: Is there a problem with changing the Transfer Price of a product to account for unforeseen the Section 301 duty? The transfer prices have already been set and include an amount for duty. The current transfer price, inclusive of previous duty amount, results in leaving an agreed amount of profit at our related party […]
QUESTION: I’m struggling to understand the “lesser of 2 duties” rule, as it applies to the 301 tariffs. It looks like it only applies to mfg drawback. If I import in articles subject to the 301 tariffs, and I export them out in the exact same condition – Can I claim 99% drawback on the […]
QUESTION: 19 U.S. Code § 1862 specifically mentions “imports.” By what authority, then, is the President allowed to ban Drawback? Exports are not mentioned in that section at all. ========== Answers: I think that the question is not whether the president has the authority to “ban” drawback – he is not and he […]
QUESTION: Can foreign producers reimburse Section 301 duty payments made by importers? ========== Answers: I believe this would be considered a rebate and advise against it. ========== Yes. This is not like anti dumping or CVD. ========== Yes, it is legal for suppliers to reimburse importers for the Section 301 duties. We have had a […]
QUESTION: I understand the Section 301 exclusion request is product specific. But product specific does not seem to mean part number or company/submitter specific. If we import ABC item, which is exactly the same thing as one of our competitors imports, and we receive an exclusion does our competitor benefit from our exclusion? If so, […]
QUESTION: I was wondering if you get an exclusion on the 301 tariff is it transferrable to another company. We are in the process of being sold and was wondering if the acceptance letter is transferrable. ********* Answers: Exclusions under the 301 Investigation (and 232) are by tariff code. They are not personal to the […]
QUESTION: I am curious as to how other FTZ operators are handling finished goods containing foreign components as they leave the FTZ and are subject to Section 301. In this specific scenario, the finished good undergoes a substantial transformation in the FTZ but is made up of mostly Chinese and Korean components. What country of […]
