• 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 […]

  • China Tariff Exclusions

    QUESTION: How or where can one find out if exclusions have been granted or denied for the China tariffs ? A buyer reported that an exclusion has been granted for chenille. I understand that to mean that the chenille or similar fabric is not available in the U.S. or in a third country. I find […]

  • 9903.88.06 EXCLUSION

    QUESTION: We have a product from China that is similar to the exclusion under 9903.88.06 which states: Articles the product of China, as provided for in U.S. note 20(i) to this subchapter, each covered by an exclusion granted by the U.S. Trade Representative………………………………. U.S. Note 20(i) states: (25)Electrical transformers, each with a power handling capacity […]

  • Full hts sec 301 exclusions automatic?

    QUESTION: If they issue a full exclusion for an entire HTS (example, 8537.10.8000), do we need to affirmatively take that exclusion at import or will it be entered automatically? =========== Answers: You will need to affirmatively take the exclusion with the appropriate 9903 tariff number assigned. =========== It must be taken affirmatively by also indicating […]

  • Sec. 301 Clarification on Export Date

    QUESTION: In the recent announcement covering the 3rd tranche that goods exported before May 10th would still be subject to the 10% additional tariff, is it the bill of lading date or the Customs definition of export date which determines applicability? For example, goods are shipped on 5/3/19 from Ningbo port on a feeder vessel […]

  • Section 301 List 3 Exclusion Request

    QUESTION: Does any member in the ICPA community know when we can apply for Section 301 List 3 exclusion? My products imported from China are List 1 item and the tariff code is an exclusion but my product is not the same or similar products as exclusion described. Since it is the same HTS classification, […]

  • Section 301 Exclusion, 8431.20.0000

    QUESTION: The third batch of product exclusions from the section 301 tariffs allowed for the exclusion of, “…tines, carriages, and other goods handling apparatus and parts designed for use on fork lift and other works trucks (HTSUS 8431.20.0000)”. We have interpreted this to mean that only the goods-handling apparatus for use on a forklift is […]

  • FTZ AND 301 DUTIES

    QUESTION: Our US supplier group assists our Mexican sister company manage its suppliers. Within the last six months, the US supplier attempted to use an FTZ strategy to avoid substantial 301 tariffs – but somehow didn’t import correctly, so got charged the tariffs, anyway. I was reading up on it since the US company doesn’t […]