232 & 301

  • SEC 301 WAIVER GRANTS

    QUESTION: With the onset of 301 duties, many companies are applying for exemptions for their products. The USTR has stated that if an exemption is granted for a specific item (tariff classification,) that anyone importing under that classification can use the waiver. Does anyone know where these exemptions might be posted so that one can […]

  • 301 AND CN GOODS SHIPPED FROM SINGAPORE

    Will a good with an origin of China, that meets the provisions under GN 25(m) to be considered an originating good of Singapore, be subject to the Section 301 tariffs upon import into the US? Example: Sockets of 8536.69.4040 Country of Mfg: China Shipped from Taiwan to Singapore to US ************* Answers: For FTA purposes […]

  • HTS MISTAKE IN SEC 301 LIST

    QUESTION: Researching 301 tariff codes I found something in the tariff that didn’t look like all the others…. 8419.90.8500  UOQ1: X  UOQ2: X Parts: Of electromechanical tools for working in the hand with self-contained electric motor Now I have seen descriptions like that in other parts of the tariff- but 8419 has nothing to do […]

  • Section 301 and TIB’s

    QUESTION: Can imports be protected by the Section 301 tariffs when imported as a TIB? ========== Answers: No, TIB imports are not subject to any duty payment, because technically they have not been entered into the commerce of the U.S.  BUT, you should be very careful about using TIBs.  Their label is literally what they […]

  • SEC 301 HTS DETERMINATIONS

    QUESTION: I was reviewing the list of HS Codes that are part of the Section 301 action and do not always see the connection between the purported reasons for action:   1) China uses joint venture requirements, foreign investment restrictions, and administrative review and licensing processes to force or pressure technology transfers from American companies. 2) […]

  • HS 84661001 AND SEC 301

    QUESTION: Has anyone heard anything further about applicability with regard to HTS 84661001? The description listed in the Notice of Determination says: Tool holders and self-opening dieheads for use solely or principally with machines of headings 8456 to 8465, nesoi However, what if your item doesn’t fall under parts and accessories suitable for use solely […]

  • CH 98 CLAIMS FOR 232 & 301 TARIFFS

    QUESTION: Are products that were exported from the United States and returned within 3 years (9801) in their same condition exempt from the 232/301 tariffs? Are products that were exported from the United States for rework or alteration (9802) in another country and are now being imported back to the USA exempt from the 232/301 […]

  • Sec 301 HTS in Excel

    QUESTION: Could a member share the updated list of HTS codes impacted by the section 301 tariff adjustments in EXCEL format or another usable format as soon as it is available? =========================== Answers: The U.S. Trade Representative recently published a notice (see https://ustr.gov/about-us/policy-offices/press-office/press-releases/2018/june/ustr-issues-tariffs-chinese-products) with a final list of 818 HTS numbers to which the China […]

  • 232 Exclusions

    QUESTION: Has anyone successfully applied for, and been granted, a 232 waiver for steel or aluminum?  Any advice? ====================== ANSWERS: Today, at a large scale trade consultant webcast, a low % reviewed by US Gov’t, and even lower % accepted. Add’l Answer: Yes.  You can find the approved requests at:  https://www.regulations.gov/docketBrowser?rpp=25&so=DESC&sb=postedDate&po=0&s=Decision%2BMemo&D=BIS-2018-0006  These roll out pretty […]

  • 301 DUTIES AND DRAWBACK

    QUESTION: 301 duties- will these additional duties  be able to be refunded through the drawback process? ========== Answers: No, 232 and 301 additional duties are not eligible for drawback. ========== No =========  

  • Section 232 Imports – CA, MX & NAFTA

    QUESTION: In lieu of the June 1st inclusion of Canada, Mexico & EU on the proclamation of Section 232 import tariffs on selected steel and aluminum, does anyone know if NAFTA (FTA) can be applied to offset the 10% or 25% import duty? It would not be logical that it would apply;  I have inquired […]

  • SECTION 301 SCENARIO

    QUESTION: We currently have contract manufacturer’s in China who prepare our FG.  We send them US materials and they combine with Chinese components.  The China CM’s manufacturing process does not result in a substantial transformation of the US material and the COO would be US. Our product’s HTS is included in the initial list of […]