The United States began imposing additional duties on certain goods manufactured in China in September 2018 as a result of the US Trade Representatives (USTR) article 301 investigation into China’s acts, policies and practices related to technology transfer, intellectual property and innovation. Since that initial implementation of additional duties, the USTR has expanded the number of imported products to include a significant percentage of all goods made in China. The USTR granted tariff and product specific exclusions to these additional duties. With the exception of eight products referenced in 85 FR 20332 which are excluded until April 18, 2021, these exclusions have expired or are set to expire on December 31, 2020. At this time we see no indication that these exclusions will be continued into 2021.
If you are an importer that is currently taking advantage of an article 301 exclusion for an eligible product please be aware that unless the USTR takes further action, your exclusion will no longer apply on goods imported on or after January 1, 2021. This will result in an increase in duty owed depending on the classification of your goods.
Please note that any shipments destined for the US must be entered prior to midnight December 31, 2020 in order to be eligible for the duty exclusion. This means entry must be filed and the freight arrived in the port prior to the end of the year. If you have goods on the water that may come close to this deadline please make sure you are coordinating with Delmar US in order to have the best opportunity to pay the lower rate.
If we can provide any guidance, please contact Delmar US Advisory Services.