The Office of the United States Trade Representative (USTR) recently announced a third set of product exclusions from Section 301 duties on Chinese products. These exclusions relate to items that were included in the first list (‘List 1’) of products enacted on July 6, 2018. Products in List 1 include many technology imports with a combined value of $34 billion.
Complete product exclusion information, including Harmonized Tariff System (HTS) numbers, may be found here.
The USTR has deemed the exclusions will apply to all imports regardless of applicant. The exclusions will cover imports retroactively to July 6, 2018, when List 1 products were initially assessed an additional 25% in Section 301 duties.
Importers should note the exclusions are available for any product that meets the description in the Annex to the Federal Register notice, regardless of whether the importer filed an exclusion request. Further, the scope of each exclusion is governed by the scope of the 10-digit headings and product descriptions in the Annex, and not by the product descriptions set out in any particular request for exclusion.
Importers should carefully review this information to determine if any opportunity exists for duty refunds under these exclusions. Delmar is proactively identifying applicable and potential refund opportunities for its clients. Clients will be contacted to confirm exemption scope (as applicable) and next steps in the refund process.
Please contact your local Delmar Representative or email our U.S. Customs Advisory Services Group for information and assistance.