CommentaryImport

Section 301 China Imports

Let’s debrief the Section 301 situation

List 1

Download List 1

List 2

  • effective August 23, 2018
  • places an additional duty rate of 25%
  • on $16 billion worth of goods from China.
  • Exclusion process closed
Download List 2

List 3

  • effective September 24, 2018
  • originally placed an additional 10%
  • and increased to 25% on May 10, 2019 June 15, 2019
  • on $200 billion worth of goods from China
  • Product Exclusion Process Announced
Download List 3

List 4

  • effective date TBD – Comments due June 2019
  • places an additional duty rate of 25%
  • on $267 billion worth of goods from China.
  • List 4 essentially encompasses all other goods originating from China.
  • Start prepping comments now
  • As of July 1, 2019, plans for List 4 has been suspended during trade negotiations with China
Download List 4

 

Section 301 Tariffs

Want to Recover Duty paid to CBP?

Duty Drawback is allowed on Section 301 products (but not on Section 232).  Ask our team for more information if you are using Chinese components to produce items that are re-exported out of the USA.  There are other ways to save money on duty.  Check out our recorded Duty Savings Opportunities Q&A Session.

Check out the MTB Act

On September 13, 2018, President Trump signed into law: H.R. 4318, the “Miscellaneous Tariff Bill Act of 2018,” which provides for duty suspensions and reductions for certain products entered into consumption on October 13, 2018 through December 31, 2020.

The Miscellaneous Tariff Bill (MTB) reduces or completely eliminates duty on 1,660 imported products not manufactured or available domestically.  This is BIG news for manufacturers!  Even if you’re a manufacturer importing from China, you can benefit!

Because several of the products that qualify for a reduced duty rate are from China, they are still subject to Section 301 additional tariffs.  So, although an importer may have just discovered its qualification for duty reduction, it will still need to consider the additional 25% on required HTS numbers from China…. but at least the importer will still benefit since it is not required to pay the entire sum of the two duty rates had the MTB Act not passed. You can view a valid example and download a handy spreadsheet here.

Product Exclusions

The exclusion process for List 1 closed for petitioners in October 2018. However, any organization that imports using the announced tariffs numbers, regardless if the organization was the actual exclusion petitioner or not, is able to use the general exclusions listed. Five batches of products in List 1 have been announced.  To view more about the process and what items are approved product exclusions, click here.

List 1 Announcement 1
List 1 Announcement 2
List 1 Announcement 3
List 1 Announcement 4
List 1 Announcement 5

Contact Us

Email consulting@scarbrough-intl.com for a free consultation.

If the Section 301 tariffs are affecting your company, watch this webinar recording to learn more.  Scarbrough’s President and COO, Adam Hill, along with Patrick Caulfield, an attorney at GDLSK, an international trade and customs law firm, talk about legal opportunities to recover or avoid paying duty to CBP.  This is an interactive webinar set up as a question/answer forum.

To review Section 301, visit this helpful Resource Page

Download each Section 301 List below:


Section 301 List 1
Section 301 List 2 Section 301 List 3

 

Scarbrough is offering a FREE 20-minute consultation to any importer affected by the Section 301 Tariffs. Email consulting@scarbrough-intl.com or fill out the form below.

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