232 & 301

  • SUCCESSFUL EXCLUSION REQUESTS

    QUESTION: I’m asking members who had approvals on their exclusion request: 1) Do you have to provide evidence on why the product is unique and cannot be sourced from outside of China? 2) Do you need letters of support from members of congress from your state? 3) Do you have to show the tariffs would […]

  • How does one locate and view the Section 301 Exclusion Requests file so far?

    QUESTION: I would like to read some of the exclusion requests that have been successful or denied. Where can one locate and view those filed to date? ************* Add’l Answer: How to locate List 1 and List 2 Exclusion Granted & Denied www.regulations.gov. For list 1 ($34BN list) in the search box type – USTR-2018-0025 […]

  • SUBMITTING COMMENTS ON CHINA TARIFFS

    QUESTION: I understand that comments can be submitted to the USTR regarding the China tariffs. Question: Are comments to be filed on the USTR site where exclusion request are filed? If not, then where? *************** Answers: Comment filing instructions are in the Federal Register Notice that was issued on September 3. Paul Vandevert, Principal paul@ochimtradelaw.com […]

  • Section 301 exclusion

    QUESTION: Does anyone know if we can use the section 301 exclusion if the product HTS fits to the exclusion HTS code, or if our product has to match exactly with the description listed on the exclusion. ========== Answers: Both. Your product needs to the HTS code and fit within the description listed on the […]

  • DEADLINES FOR 301 EXCLUSIONS

    QUESTION: Does anyone have a cheat sheet on the Federal Register published dates listing the official deadlines to file for exclusions relative to the Section 301 Trump Tariffs? *************** Only List #3 is open for exclusion requests. The exclusion request window opened on June 30 and closes on September 30. Paul Vandevert, Principal paul@ochimtradelaw.com +1 […]

  • SEC. 301 LIST FOUR IN EXCEL

    QUESTION: Does anyone in the community have List A and List B in excel format? ========== Not available, you need an analyst to manipulate data from the PDF files to excel. This is time consuming though, but well worth it. In recommend this, since other groups within the company will certainly ask for an excel. […]

  • 301 TARIFF LIST 4 – FOR SEPT 1

    QUESTION: My understanding is that the 301 tariff List 4 is going to take effect on Sept 1, 2019. Does any members know the Sept 1 is based on the shipping date ship out from China or shipments that arrival after Sept 1? Is there a link that I can check for the above info? […]

  • EXCLUSION REQUESTS FOR NRIs

    QUESTION: Can a Canadian based Foreign IORs who do not have a presence in the US are considered for exclusion requests under Section 301 duties? From what I read, it’s pretty clear that it only applies to US companies? ========== Answers: If China product is being imported into the U.S., the entry is subject to […]

  • List three exclusions

    QUESTION: For requesting an exclusion is the trade community expected to fill out the fields on the exclusion request form AND submit a formal business confidential, and public document? If we are to submit by attachment confidential and public documents, who should these be addressed to? Should the information in the attachments provide something not […]

  • Comprehensive List of Excluded Products – China Tariff

    QUESTION: Where can I find a comprehensive list of the HTS subheadings that have been excluded from the China tariffs ? ========== Answers: I’ve been trying to keep up with it. Attached Excel with exclusions as of Federal Register notice from 7/9. o https://www.icpainc.org/wp-content/uploads/2014/10/Copy-of-Section-301-Lists-ICPA.xlsx ========== Our firm maintains an updated list on the Tariff Actions […]

  • Section 301 Exclusion Extension Process

    QUESTION: We have been fortunate enough to secure a couple of exclusion for some Chinese origin major equipment that are subject to Section 301 list 2 tariffs. Our issue is that our equipment will not be shipping for another 18 months. Can anyone advise if there has been a process announced for requesting an extension […]