232 & 301

  • CUSTOMER REQUESTS FOR 7501 IMPORT DOCS FROM CHINA

    QUESTION: I have several customers asking for a copy of my 7501 and other import documents so they can verify the additional duty paid related to Section 301 imports from China. My documents show my inter-company pricing and we are not passing on the full amount of the duty increase. Obviously, I don’t want to […]

  • RULING NY N299096

    QUESTION: I am curious if others in the membership are as puzzled by this ruling (NY N299096). In my opinion, it essentially contradicts the NAFTA rules of origin laid out in 19 CFR 102 and furthermore suggests that the product can be marked “Made in Mexico” but the origin for Customs purposes is China. How […]

  • Section 301 tariff

    QUESTION: The third list of tariffs on Chinese goods went into effect on 9/24. We (sent) 2 entries prior to that date that ended up with a 9/25 entry date. When we attempted to pay our PMS, these entries were rejected because we did not transmit the entry with the additional tariff number. The message […]

  • 301 HTS FOR ISF

    QUESTION: Do the chapter 99 tariff numbers for the 301 tariffs and/or MTB tariffs need to be included in the ISF filing? **************** Answers: All of the answers said: No ************

  • Sec 232 Exclusion refund requests

    QUESTION: Does anyone know the time line to receive a refund on a PSC for these Sec 232 exclusions? (meaning, once the PSC is filed asking for the refund, what is the time line to receive your money back) Who will be handling the refunds?  The port where the entry is filed or the CEE? […]

  • ITEMS SUBJECT TO BOTH SEC 232 & 301

    QUESTION: I have a c/o China cast aluminum article classed at 7616.99.5160, subject to section 232. However, HTS 7616.99.51 is also covered under section 301 tranche 3. Is this subject to both section 232 AND section 301 additional duty? ========== Answer: Yes ==========    

  • COO Labeling Parts used in Production

    QUESTION: What are the COO rules as they apply to parts my company produces that are used ONLY in production of finished goods?  That is, they are not sold or re-sold to customers directly. I discovered that parts we’re producing in Europe did not have COO in system (I’ll address that myself), but COO is […]

  • SEC. 321 RELEASE FROM FTZ

    QUESTION: Does anyone in the membership know if Section 321 entry can be claimed on withdraws from an FTZ? If I understand correctly, most Section 321 entries are filed by carriers. In case of FTZ, normally who files for Customs release? FTZ operator or carrier? Is ACE ready for brokers to file Section 321 entries? […]

  • ACE BOND SUFFICIENCY REPORT

    QUESTION: What is the best ACE report for sanity check on sufficient bond amount?? ========== Contact your bond writer for a report, it’s a lot easier. ========== Any of the Entry Summary reports would work depending on how detailed you want to get (ES-7008 perhaps) – but don’t forget to factor forward based on the […]

  • Miscellaneous Tariff Bill – HTS Codes

    QUESTION: Does anyone have a list of the tariff numbers that will be impacted by the miscellaneous tariff bill 2018? ========== Answers: Attached is the link to the version passed by the Senate. https://www.congress.gov/115/bills/hr4318/BILLS-115hr4318rfs.pdf ========== Here is the full list of MTB HTS codes. http://www.icpainc.org/wp-content/uploads/2014/10/Copy-of-MTB-2018.xlsx ========== Hi, Attached is a spreadsheet showing the HTS, MTB […]

  • NAFTA SOLICITATION SCENARIO

    QUESTION: Topic: Annual solicitation and factories I’ll start with giving the context for my new company: 30+ years of growth in the US, quite a bit of exports and a larger handful of imports. Factories are in the Midwest and South. They have never had a dedicated compliance person. Lots of stuff gets done on […]

  • Section 301, Assists and Transfer Pricing

    QUESTION: We ship US component parts to a related foreign supplier in China who in turn incorporates them into a finished product and exports back to us. I see an opportunity to lower our customs value and therefore avoid Section 301 duties but not sure how we claim the assist value on the item if […]